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aa5f433d243c81b15a123dfddb16b3c3b256554a | The English Indices of Deprivation 2015
Technical report
## Contents
| Section | Page | |---------|------| | Contents | 3 | | Preface | 6 | | Acknowledgements | 7 | | Chapter 1. Introduction | 8 | | 1.1 Introduction | 8 | | 1.2 Overview of the Indices of Deprivation 2015 | 8 | | 1.3 Research leading up to publication of the Indices of Deprivation 2015 | 9 | | 1.4 About this Technical Report | 9 | | Chapter 2. Measuring deprivation at the small area level: The conceptual framework | 11 | | 2.1 Overview | 11 | | 2.2 Poverty, deprivation and multiple deprivation | 11 | | 2.3 Dimensions of deprivation | 12 | | 2.4 Combining dimensions of deprivation into a multiple deprivation measure | 12 | | 2.5 An area-based model of multiple deprivation | 13 | | Chapter 3. Methods | 14 | | 3.1 Overview of the methodology used to construct the Indices of Deprivation 2015 | 14 | | 3.2 Stage 1: Domains of deprivation are clearly identified | 16 | | 3.3 Stage 2: Indicators are chosen which provide the best possible measure of each domain of deprivation | 16 | | 3.4 Stage 3: ‘Shrinkage estimation’ is used to improve reliability of the small area data | 20 | | 3.5 Stage 4: Indicators are combined to form the domains, generating separate domain scores | 21 | | 3.6 Stage 5: Domain scores are ranked and the domain ranks transformed to a specified exponential distribution | 22 | | 3.7 Stage 6: The exponentially transformed domain scores are combined using appropriate domain weights to form an overall Index of Multiple Deprivation | 23 | | 3.8 Stage 7: The overall Index of Multiple Deprivation and domains are summarised for larger areas such as local authority districts | 24 | | 3.9 Summary of the domains, indicators and methods used to construct the Indices of Deprivation 2015 | 27 | Appendix N. History of the Indices of Deprivation 119 Appendix O. What data has been published? 121 Appendix P. Worked examples of the higher-level summary measures 123 Preface
The English Indices of Deprivation are an important tool for identifying the most deprived areas in England. Local policy makers and communities can also use this tool for the effective targeting of resources.
The English Indices of Deprivation 2015 is the fifth release in a series of statistics produced to measure multiple forms of deprivation at the small spatial scale. Following engagement with users and a significant programme of work by the research team, the Indices of Deprivation 2015 retain broadly the same methodology, domains and indicators as the earlier Indices of Deprivation 2010, 2007, 2004 and 2000.
This report outlines the theory underpinning the model of multiple deprivation, the methods that were used, and describes the domains and indicators that make up the Indices of Deprivation 2015. A small number of changes to the indicators have been made, for example due to better availability of data, which are described in this report.
In addition to the technical details presented in this report, the Statistical Release produced by the Department of Communities and Local Government (DCLG) contains information on how to use and interpret the Indices, and there is further detail in the Research Report. DCLG has also produced short, accessible guidance and responses to frequently asked questions.
All of the supporting documents and datasets for the Indices of Deprivation 2015 are available from: www.gov.uk/government/statistics/english-indices-of-deprivation-2015
The data has also been loaded into the DCLG’s Open Data Communities platform¹ and made available on the Neighbourhood Statistics website².
¹ UK Department for Communities and Local Government's official Linked Open Data website http://opendatacommunities.org/ ² ONS Neighbourhood Statistics http://www.neighbourhood.statistics.gov.uk/dissemination/ Acknowledgements
The English Indices of Deprivation 2015 were constructed by Oxford Consultants for Social Inclusion (OCSI). The research team comprised: Tom Smith, Michael Noble, Stefan Noble, Gemma Wright, David McLennan and Emma Plunkett.
In addition, some indicators from the Health Deprivation and Disability Domain were constructed by Karen Bloor, Nils Gutacker and Richard Cookson at the University of York; the air quality indicator by Jon Fairburn at Staffordshire University; the housing affordability indicator by Glen Bramley at Heriot-Watt University; and the housing condition indicator by the Building Research Establishment.
Chris Dibben at the University of Edinburgh acted as statistics and methodology advisor, external quality assurance was carried out by Alex Sutherland at Cambridge University, and geographic information system work was undertaken by David Avenell. Julia Griggs and Kirby Swales at the National Centre for Social Research carried out the user survey and engagement. Additional support at Oxford Consultants for Social Inclusion was provided by Sophie Hale, Dan Kidby and Paul Shanks.
The research team would also like to thank the Strategic Statistics Division and the Project Board within the Department for Communities and Local Government, the project Advisory Group, and all the suppliers of data.
We would like to thank all those who assisted in the production of the Indices of Deprivation 2015, in particular all those who responded to the survey of users, the consultation and/or attended user events. Chapter 1. Introduction
1.1 Introduction
1.1.1 The Department for Communities and Local Government commissioned Oxford Consultants for Social Inclusion (OCSI) to review and update the English Indices of Deprivation 2010. The project remit was to:
- review the indicators included in the Indices of Deprivation 2010 to determine if they remain fit for purpose, and where there is a clear rationale for doing so, identify potential changes to the basket of indicators in each domain;
- assess the current data landscape, identify changes to (or outdatedness of) previously used sources, as well as any new sources;
- review whether the statistical methods used in the production of the Indices of Deprivation 2010 are still justified and assess if alternative methods are available and the strengths and weaknesses of any such alternatives;
- produce the updated Indices of Deprivation 2015.
1.1.2 Following engagement with users and a significant programme of work by the research team, the Indices of Deprivation 2015 have been produced using the same approach, structure and methodology used to create the previous Indices of Deprivation 2010. Changes to existing domains and sub-domains were outside the scope of the update, although there have been a modest number of changes to the basket of indicators used in the domains.
1.1.3 Feedback from users was supportive of the decision not to make major changes to the Indices. Maintaining comparability with previous versions of the Indices is important to them. The updated Indices continue to be based on the Lower-layer Super Output Area geography, although the updated Indices use the new 2011 version of the Lower-layer Super Output Area geography.
1.2 Overview of the Indices of Deprivation 2015
1.2.1 The Indices of Deprivation 2015 provide a set of relative measures of deprivation for small areas (Lower-layer Super Output Areas) across England, based on seven different domains of deprivation:
- Income Deprivation
- Employment Deprivation
- Education, Skills and Training Deprivation
- Health Deprivation and Disability
- Crime
- Barriers to Housing and Services
- Living Environment Deprivation
1.2.2 Each of these domains is based on a basket of indicators. As far as is possible, each indicator is based on data from the most recent time point available; in practice most indicators in the Indices of Deprivation 2015 relate to the tax year 2012/13.
1.2.3 The Index of Multiple Deprivation 2015 combines information from the seven domains to produce an overall relative measure of deprivation. The domains are combined according to their respective weights as described in section 3.7. In addition, there are seven domain-level indices, and two supplementary indices: the Income Deprivation Affecting Children Index and the Income Deprivation Affecting Older People Index.
1.2.4 A range of summary measures are available for higher-level geographies including local authority districts and upper tier local authorities, local enterprise partnerships, and clinical commissioning groups. These summary measures are produced for the overall Index of Multiple Deprivation, each of the seven domains and the supplementary indices.
1.2.5 The Index of Multiple Deprivation 2015, domain indices and the supplementary indices, together with the higher area summaries, are collectively referred to as the Indices of Deprivation 2015.
1.3 Research leading up to publication of the Indices of Deprivation 2015
1.3.1 The development of the Indices of Deprivation follows extensive exploration of data sources, review of methodology and testing and quality assurance of data sources and indicators. The development also takes into account the range of views gathered prior to and during the earlier phases of this project, including:
- feedback from users gathered during a session on the Indices at the DCLG Statistics User Engagement Day in November 2013
- the views of the Government Statistical Service Methodology Advisory Committee on a paper on methodology and indicators presented in November 2013
- responses from almost 250 users to a survey which took place in July 2014
- the views of the department’s Project Board and its Advisory Group, comprising representatives from central and local government and other interest groups, including the voluntary and community sector
- feedback from users on dissemination and outputs gathered during three user events held in November 2014
- 100 responses to the consultation which took place in November and December 2014.
1.4 About this Technical Report
1.4.1 This report presents the conceptual framework of the Indices of Deprivation 2015; the methodology for creating the domains and the overall Index of Multiple Deprivation; the component indicators and domains and the quality assurance carried out to ensure reliability of the data outputs.
1.4.2 The main findings from the Indices of Deprivation are presented in the DCLG Statistical Release, and an accompanying research report gives a fuller account with examples of how to use the Indices.
3 Government Statistical Service Methodology Advisory Committee 26 minutes and papers: http://www.ons.gov.uk/ons/guide-method/method-quality/advisory-committee/26th-meeting/index.html 1.4.3 Improvements to the reports have been made in response to demand from users. The majority of users reported finding the Indices easy to use and interpret in the user survey. But there was demand for short and clearer guidance on how to use the Indices and for support in communicating this to others, particularly non-specialists.
1.4.4 All project outputs are available to download from www.gov.uk/government/statistics/english-indices-of-deprivation-2015
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1 Department of Communities and Local Government (2015). The English Indices of Deprivation 2015, Statistical Release. 2 Department of Communities and Local Government (2015). The Indices of Deprivation 2015. Research Report. Chapter 2. Measuring deprivation at the small area level: The conceptual framework
2.1 Overview
2.1.1 The Index of Multiple Deprivation 2015 is a measure of multiple deprivation at the small area level. The model of multiple deprivation which underpins the Index is the same as that which underpinned its predecessors(^6) and is based on the idea of distinct dimensions of deprivation which can be recognised and measured separately.
2.1.2 These dimensions (or domains) of deprivation are experienced by individuals living in an area. The overall Index of Multiple Deprivation is a measure of multiple deprivation based on combining together these specific dimensions of deprivation.
2.2 Poverty, deprivation and multiple deprivation
2.2.1 In his 1979 account of *Poverty in the United Kingdom* Townsend sets out the case for defining poverty in relative terms: ‘Individuals, families and groups can be said to be in poverty if they lack the resources to obtain the types of diet, participate in the activities and have the living conditions and amenities which are customary, or at least widely encouraged or approved in the societies to which they belong’(^7). Townsend further argues that ‘people can be said to be deprived if they lack the types of diet, clothing, housing, household facilities and fuel and environmental, educational, working and social conditions, activities and facilities which are customary …’(^8)
2.2.2 Though ‘poverty’ and ‘deprivation’ have often been used interchangeably, many have argued that a clear distinction should be made between them(^9). People are in poverty if they lack the financial resources to meet their needs, whereas people can be regarded as deprived due to a lack of resources of all kinds, not just income. The Index of Multiple Deprivation framework follows Townsend, in defining
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(^6) The previous versions of the Index of Multiple Deprivation 2015 which broadly follow the same framework and methodology for measuring multiple deprivation are the Index of Multiple Deprivation 2010, 2007, 2004 and 2000. See McLennan et al. (2011) [https://www.gov.uk/government/statistics/english-indices-of-deprivation-2010](https://www.gov.uk/government/statistics/english-indices-of-deprivation-2010); Noble et al. (2008) [http://webarchive.nationalarchives.gov.uk/+/http://www.communities.gov.uk/communities/neighbourhoodrenewal/deprivation/deprivation07/](http://webarchive.nationalarchives.gov.uk/+/http://www.communities.gov.uk/communities/neighbourhoodrenewal/deprivation/deprivation07/); Noble et al. (2004) [http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/archived/general-content/communities/indicesofdeprivation/216309/](http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/archived/general-content/communities/indicesofdeprivation/216309/) and Noble et al (2000) [http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/archived/general-content/communities/indicesofdeprivation/indicesofdeprivation/](http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/archived/general-content/communities/indicesofdeprivation/indicesofdeprivation/).
(^7) Townsend (1979), *Poverty in the United Kingdom*, p.31.
(^8) Townsend (1987), *Deprivation*, p.125-126, our italics.
(^9) See for example the discussion in Nolan and Whelan (1996). deprivation in a broad way to encompass a wide range of aspects of an individual’s living conditions.
2.2.3 Townsend also lays down the foundation for articulating multiple deprivation as an accumulation of several types of deprivation. This formulation of multiple deprivation is the starting point for the model of small area deprivation which is presented here.
2.3 Dimensions of deprivation
2.3.1 The approach allows the separate measurement of different dimensions of deprivation. Seven main types of deprivation are considered in the Index of Multiple Deprivation 2015 – income, employment, education, health, crime, access to housing and services, and living environment – and these are combined to form the overall measure of multiple deprivation.
2.3.2 There is a question as to whether low income or the lack of socially perceived necessities (for example adequate diet, consumer durables, ability to afford social activities etc) should be one of the dimensions(^\\text{10}). To follow Townsend, within a multiple deprivation measure only the types of deprivation resulting from a low income would be included. So low income itself would not be a component, but lack of socially perceived necessities would. However, there is no readily available small area data on the lack of socially perceived necessities, and therefore low income is an important proxy for these aspects of material deprivation.
2.3.3 Despite recognising income deprivation in its own right, it should not be the only measure of area deprivation. Other dimensions of deprivation contribute crucial further information about an area. However, low income remains a central component of the definition of multiple deprivation used here. As Townsend writes ‘while people experiencing some forms of deprivation may not all have low income, people experiencing multiple or single but very severe forms of deprivation are in almost every instance likely to have very little income and little or no other resources(^\\text{11}).
2.4 Combining dimensions of deprivation into a multiple deprivation measure
2.4.1 Measuring different aspects of deprivation and combining these into an overall multiple deprivation measure raises a number of questions. Perhaps the most important one is the extent to which area deprivation in one dimension can be cancelled out by lack of deprivation in another dimension. Thus if an area is found to have high levels of income deprivation but relatively low levels of education deprivation, should the latter cancel out the former and if so to what extent? The Index of Multiple Deprivation 2015 is essentially based on a weighted cumulative
(^{10}) Gordon et al. (2000).
(^{11}) Townsend (1987), Deprivation, p.131. model and the methodology is designed to ensure that cancellation effects are minimised\\textsuperscript{12}.
2.4.2 Another question concerns the extent to which the same people or households are represented in more than one of the dimensions of deprivation. The position taken in the Index of Multiple Deprivation 2015 is that if an individual, family or area experiences more than one form of deprivation this is ‘worse’ than experiencing only one form of deprivation. The aim is not to eliminate double counting between domains – indeed it is desirable and appropriate to measure situations where deprivation occurs on more than one dimension.
2.4.3 On the other hand, it is desirable to eliminate double counting of people or households within domains. So for example, the Income Deprivation and Employment Deprivation domains, and the Adult Skills sub-domain, are constructed from non-overlapping counts of people experiencing such deprivation. However in practice, it is not always possible to avoid double counting in the indicators within domains.
2.5 An area-based model of multiple deprivation
2.5.1 The model of multiple deprivation is based on the idea of separate dimensions of deprivation which can be recognised and measured separately. These are experienced by individuals living in an area, and an area-level measure of deprivation for each of the dimensions (or domains) can in principle be measured.
2.5.2 An area can be characterised as deprived relative to other areas on a particular dimension of deprivation, on the basis that a higher proportion of people in the area are experiencing the type of deprivation in question. In other words, the experience of the people in an area gives the area its deprivation characteristics.
2.5.3 The area itself is not deprived, though the presence of a concentration of people experiencing deprivation in an area may give rise to a compounding deprivation effect, but this is still measured by reference to those individuals. Having attributed the aggregate of individual experience of deprivation to the area, it is possible to say that an area is deprived in that particular dimension.
2.5.4 Having measured specific dimensions of deprivation, these can be understood as separate domains of multiple deprivation. The overall Index of Multiple Deprivation is constructed by combining together these specific dimensions to produce an area-level measure of multiple deprivation. As with the individual dimensions of deprivation, an area can be characterised as deprived relative to other areas, but is not in itself deprived.
2.5.5 The following chapters outline how the Indices of Deprivation 2015 and Index of Multiple Deprivation 2015 have been designed and developed based on the conceptual model of multiple deprivation outlined in this chapter.
\\textsuperscript{12} See Appendix F for details of how the Indices of Deprivation 2015 methodology minimises cancellation effects across the domains. Chapter 3. Methods
3.1 Overview of the methodology used to construct the Indices of Deprivation 2015
3.1.1 The construction of the Indices of Deprivation 2015(^{13}), including the Index of Multiple Deprivation broadly consists of the following seven stages. As shown in Figure 3.1, these stages fulfil the purposes of defining the Indices, data processing, and producing the Index of Multiple Deprivation and summary measures. Each stage is described in the following sections. Figure 3.3 summarises how these stages are applied in producing each of the domain indices and the Index of Multiple Deprivation.
1. Dimensions (referred to as domains) of deprivation are clearly identified.
2. Indicators are chosen which provide the best possible measure of each domain of deprivation.
3. ‘Shrinkage estimation’ is used to improve reliability of the small area data(^{14}).
4. Indicators are combined to form the domains, generating separate domain scores. These can be regarded as indices in their own right – the domain indices(^{15}).
5. Domain scores are ranked and the domain ranks are transformed to a specified exponential distribution(^{16}).
6. The exponentially transformed domain scores are combined using appropriate domain weights to form an overall Index of Multiple Deprivation at small area level(^{17}). This stage completes the construction of the Indices of Deprivation 2015 at Lower-layer Super Output Area level.
7. The overall Index of Multiple Deprivation, the domains and the supplementary indices are summarised for higher level geographical areas such as local authority districts.
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(^{13}) The Index of Multiple Deprivation 2015, domain indices and the supplementary indices, together with the higher area summaries, are collectively referred to as the Indices of Deprivation 2015.
(^{14}) See Section 3.4 and Appendix D for description of the shrinkage technique.
(^{15}) In domains where there are sub-domains, this stage involves first combining the indicators into a sub-domain score. The sub-domain scores are then ranked and transformed to an exponential distribution before being combined into their respective domain scores. The supplementary indices are also created at this stage as a subset of Income Domain scores.
(^{16}) See Section 3.6 and Appendix F for description of the exponential transformation.
(^{17}) See Section 3.7 and Appendix G for description of the domain weights. Robustness of the methods and datasets
3.1.2 The methods used to construct the Indices of Deprivation 2015 have been carefully designed to ensure the robustness and reliability of the output datasets. Chapter 5 describes how the design of the Indices contributes to this, along with many other quality management actions and quality assurance checks.
3.1.3 As will be reiterated when considering the selection of indicators, the robustness of the index methodology is reinforced by the fact that a consistent and uniform methodology is applied across the country. The indices are a relative measure of multiple deprivation. The national comparisons that such a relative measure enables are only possible if the same methodology is consistently applied irrespective of local conditions or the local availability of data.
Changes since the Indices of Deprivation 2010
3.1.4 Maintaining comparability with previous versions of the Indices is important to users. Scoping work undertaken for this project did not identify ways to improve the methodology, and feedback from users during the consultation stages of this project was supportive of the decision not to make major changes to the Indices. For these reasons, the methods used in developing the Indices of Deprivation 2015 update have remained consistent with those used in 2010. 3.1.5 Changes since the Indices of Deprivation 2010 are therefore mainly confined to updates to the data used to create the indicators, and a small number of new, modified and dropped indicators. These are outlined in Stage 2 below, and discussed in more detail in Chapter 4 and Appendix C under the appropriate domains.
3.2 Stage 1: Domains of deprivation are clearly identified
3.2.1 The central idea of the Index of Multiple Deprivation is that deprivation is multi-dimensional and can be experienced in relation to a number of distinct domains. Multiple deprivation is measured at an area level by combining these domains. It is therefore important that each dimension of deprivation is clearly identified and reflects a particular aspect of deprivation.
3.2.2 The Indices of Deprivation 2015 are based on the same seven domains used in the previous 2010 and 2007 Indices:
- Income Deprivation
- Employment Deprivation
- Education, Skills and Training Deprivation
- Health Deprivation and Disability
- Crime
- Barriers to Housing and Services
- Living Environment Deprivation.
3.2.3 Appendix N on the history of the indices gives a high level account of the changes to domains and component indicators since the inception of the indices in their current form with the Indices of Deprivation 2000.
3.3 Stage 2: Indicators are chosen which provide the best possible measure of each domain of deprivation
Indicator criteria
3.3.1 For each of the seven domains of deprivation, an assessment has been made about whether the indicators in the Indices of Deprivation 2010:
- are still appropriate measures of deprivation for that domain
- can be updated
- can be strengthened, for example due to better available data.
3.3.2 In addition, the research team has conducted considerable work to explore whether there are possible new indicators which would improve the measure of deprivation captured by each domain. Appendix M contains information on indicators explored which were for the reasons indicated not considered suitable for inclusion in the current indices.
3.3.3 To be considered for inclusion, any new or modified indicators had to meet the same criteria as for the Indices of Deprivation 2010 and its predecessors. Indicators should:
- be ‘domain specific’ and appropriate for the purpose (as far as possible, being direct measures of that form of deprivation) • measure major features of that deprivation (not conditions just experienced by a small number of people or areas) • be up-to-date and (as far as possible) updateable(^{18}) • be statistically robust at the small area level • be available for the whole of England at a small area level in a consistent form • In addition, to be considered for inclusion in the Indices of Deprivation 2015, indicators had to have sufficiently robust data that was readily available to use in updating the Indices without significant extra work.
3.3.4 The aim for each domain was to include a parsimonious selection of indicators that comprehensively captured the deprivation for each domain, within the constraints of data availability and the criteria listed above.
Indicators used in the Indices of Deprivation 2015
3.3.5 There are 37 indicators in total in the Indices of Deprivation 2015. Almost all of the indicators in the Indices of Deprivation 2010 have been updated with little or, at most, minor changes. In addition, there are a small number of new, modified or dropped indicators: • two new indicators have been included, based on improved availability of robust data • four indicators have been modified, due to improved data or estimation methods • four indicators have been dropped, as these are no longer available or appropriate to include.
3.3.6 Appendix C provides details of the changes to the indicators the Indices of Deprivation 2010 occasioned by this update. This includes minor changes made to indicators, for example due to changes in available data.
3.3.7 Figure 3.2 summarises the updated, new and modified indicators for each of the domains. Details are given in the appropriate place in Chapter 4.
(^{18}) Wherever possible, indicators are used that can be regularly updated. However not all indicators can be regularly updated, for example those based on Census 2011. Census data is used only when alternative data from administrative sources is not available. **Figure 3.2. Domains and indicators for the Indices of Deprivation 2015**
| Domain | Indicators | |---------------------------------------------|-----------------------------------------------------------------------------| | **Income Deprivation 22.5%** | Adults and children in Income Support families | | | Adults and children in income-based Jobseeker’s Allowance families | | | Adults and children in income-based Employment and Support Allowance families| | | Adults and children in Pension Credit (Guarantee) families | | | Adults and children in Child Tax Credit and Working Tax Credit families, | | | below 60% median income not already counted | | | Asylum seekers in England in receipt of subsistence support, accommodation | | | support, or both | | **Employment Deprivation 22.5%** | Claimants of Jobseeker’s Allowance, aged 18-59/64 | | | Claimants of Employment and Support Allowance, aged 18-59/64 | | | Claimants of Incapacity Benefit, aged 18-59/64 | | | Claimants of Severe Disablement Allowance, aged 18-59/64 | | | Claimants of Carer’s Allowance, aged 18-59/64 | | **Health Deprivation & Disability 13.5%** | Years of potential life lost | | | Comparative illness and disability ratio | | | Acute morbidity | | | Mood and anxiety disorders | | **Education, Skills & Training Deprivation 13.5%** | Key stage 2 attainment: average points score | | | Key stage 4 attainment: average points score | | | Secondary school absence | | | Staying on in education post 16 | | | Entry to higher education | | | Adults with no or low qualifications, aged 25-59/64 | | | English language proficiency, aged 25-59/64 | | **Crime 9.3%** | Recorded crime rates for: Violence; Burglary; Theft; Criminal damage | | **Barriers to Housing & Services 9.3%** | Road distance to: post office; primary school; general store / supermarket; | | | GP surgery | | | Household overcrowding | | | Homelessness | | | Housing affordability | | **Living Environment Deprivation 9.3%** | Housing in poor condition | | | Houses without central heating | | | Air quality | | | Road traffic accidents |
The percentages reported in each domain box show the weight the domain receives in the Index of Multiple Deprivation 2015. See Section 3.7 and Appendix G for a description of the domain weights. Data time point
3.3.8 As far as is possible, each indicator was based on data from the most recent time point available. Using the latest available data in this way means that there is not a single consistent time point for all indicators. However in practice most indicators in the Indices of Deprivation 2015 relate to 2012/13. For example, the most recent finalised tax credit data available from HMRC at the time of construction of the Indices of Deprivation 2015 was for the 2012/13 tax year.
3.3.9 As with previous Indices, the Indices of Deprivation 2015 use Census data only when alternative data from administrative sources was not available. Four such indicators were derived from the 2011 Census: adult skill levels and English language proficiency in the Education, Skills and Training Deprivation Domain; household overcrowding in the Barriers to Housing and Services Domain; and houses without central heating in the Living Environment Deprivation Domain.
3.3.10 As a result of the time points for which data was available, the indicators do not take into account changes to policy since the time point of the data used. For example, the 2012/13 benefits data used do not include the impact of Universal Credit, which only began replacing certain income related benefits from April 2013.
Geography and spatial scale
3.3.11 The Indices of Deprivation 2015 have been produced at Lower-layer Super Output Area level, using the current (2011) Lower-layer Super Output Areas.
3.3.12 Guidance is provided in the research report Appendix A on how to aggregate the Lower-layer Super Output Area data to other geographies such as wards or bespoke local areas, as requested by a number of users.
3.3.13 Summary measures for the Index of Multiple Deprivation, domains and supplementary Indices have been produced for the following higher-level geographies: local authority districts, upper tier local authorities, Local Enterprise Partnerships and Clinical Commissioning Groups.
Denominators
3.3.14 Denominators are an integral and important component of almost all indicators included in the Indices of Deprivation. For each indicator, the denominator seeks to measure the number of people (or households etc.) that are ‘at-risk’ of being defined as deprived, in other words that are at-risk of being included in the numerator. The denominator for each indicator is expressed on the same geographical scale as the numerator (for example Lower-layer Super Output Areas or local authority districts) and is usually measured for the same year as the numerator.
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19 The previous Indices of Deprivation 2010 were based mainly on data from 2008/9. 20 Lower-layer Super Output Areas are homogenous small areas of relatively even size containing approximately 1,500 people. The Indices of Deprivation 2010 and earlier versions used the 2001 Lower-layer Super Output Area geography. However the Office for National Statistics has produced an updated version of the Lower-layer Super Output Area geography using population data from the 2011 Census. The changes made between the 2001 and 2011 versions were minimal: 96.4 per cent of the 32,844 Lower-layer Super Output Areas in 2011 remain the same as the 2001 version used in the Indices of Deprivation 2010. 3.3.15 The majority of the indicators in the Indices of Deprivation are measured as proportions or rates of the population that are deprived, and therefore use denominators based on population. To give a more accurate measure of the population ‘at-risk’ of being defined as deprived, these population-based denominators are calculated by taking the small area mid-year population estimates from the Office for National Statistics, and removing prison populations (as provided by the Ministry of Justice). This step is undertaken because prisoners are typically not at-risk of being included in the numerator counts for the indicators. For example, individuals who are in prison are not eligible to claim means-tested out-of-work benefits.
3.3.16 Some of the indicators use denominators other than the resident population. For example, some indicators draw denominators from within the same dataset as the numerator (such as pupil attainment datasets); some are expressed as the proportion of households rather than people; and some incorporate special adjustments to better reflect the population at risk.
3.3.17 Details of the exact denominators that are used for each numerator are discussed in the indicator descriptions in Chapter 4, and a full list given in Appendix A. A more detailed explanation of the denominators used can be found in Appendix B.
3.3.18 Population-based denominators as referred to in paragraph 3.3.15 are also published, as they were for the Indices of Deprivation 2010. Denominators are unrounded except for those which include prison populations which have been rounded to the nearest three.
3.4 Stage 3: ‘Shrinkage estimation’ is used to improve reliability of the small area data
3.4.1 Where a rate or other measure of deprivation for a small area is based on small numbers, the resulting estimate may be unreliable, with an unacceptably high standard error. The technique of shrinkage estimation is used to ‘borrow strength’ from larger areas to avoid creating unreliable small area data; the impact of shrinkage may be to move a Lower-layer Super Output Area’s score towards more deprivation or towards less deprivation.
3.4.2 Without shrinkage, some Lower-layer Super Output Areas would have scores which do not reliably describe the deprivation in the area due to chance fluctuations from year to year. Such scores occur most commonly where numbers are small at Lower-layer Super Output Area level and the event is thus relatively rare. This may be the case for the indicator as a whole or only for particular Lower-layer Super Output Areas. In shrinkage estimation the score for a small area is estimated as a weighted combination of that small area’s score and the mean value for a larger area from which the smaller areas within the larger area borrow strength.
3.4.3 As with previous Indices, the larger areas used for shrinkage in the Indices of Deprivation 2015 are local authority districts. The Lower-layer Super Output Areas within a single district share issues relating to local governance and possibly to economic sub-climates. To a certain extent, they may also share issues relating to labour market sub-climates. During the development of the indices, the possibility of using other large areas as the areas from which to borrow strength was explored. Appendix D provides a summary of this exploration and the conclusion was to continue to use local authority districts as the larger areas for the shrinkage process.
3.4.4 In the Indices of Deprivation 2015 the shrinkage technique is applied to the majority of indicators. Those which are not subjected to shrinkage include the modelled indicators, the road distance indicators and the indicators supplied at local authority district level. Specific information about the indicators to which shrinkage is applied is given in the indicator descriptions in Chapter 4. Further details about the shrinkage technique, including examples of the impact of shrinkage and work undertaken to explore alternatives to using local authority districts as the areas from which to ‘borrow strength’, are given in Appendix D.
3.5 Stage 4: Indicators are combined to form the domains, generating separate domain scores
3.5.1 For each domain of deprivation the aim is to obtain a single measure which is straightforward to interpret in that it is, if possible, expressed in meaningful units (for example the proportion of people or of households experiencing that form of deprivation). This was achieved in the Income and Employment Domains, but was not possible in the other five domains.
3.5.2 The Income Deprivation Domain and Employment Deprivation Domain are constructed as simple rates of the population at-risk. Separate indicators in these domains are constructed as non-overlapping counts, and are simply summed together to identify the total at-risk population for the domain.
3.5.3 In the other domains the indicators are on different metrics and therefore it is not possible to calculate a simple rate. The indicators are therefore standardised by ranking and transforming to a standard normal distribution based on their ranks, before combining with selected weights to form the domain score:
- Maximum Likelihood factor analysis is used to determine what weight to give each of these indicators when combining them. It does this by testing the extent to which each of the indicators measure the underlying aspect of deprivation(^{21}). In three domains – the Children and Young People sub-domain of the Education, Skills and Training Deprivation Domain, the Health Deprivation and Disability Domain, and the Crime Domain – factor analysis is used to generate appropriate weights for combining the standardised indicators into a single score per domain, or sub-domain. Factor analysis is described in Appendix E.
- In the remaining domains, equal weights or weights based on a theoretical premise have been applied.
- In domains where there are sub-domains, this stage involves first combining the indicators into sub-domain scores. The sub-domain scores are then ranked and transformed to an exponential distribution for the reasons given in Section 3.6 before being combined into their respective domain scores.
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(^{21}) The method of factor analysis used in the 2015 Indices and earlier versions is the Maximum Likelihood method. Unlike Principal Components Analysis, which is the main alternative, the Maximum Likelihood method does not require the assumptions that all indicators are perfectly reliable and measured without error. For further details about the factor analysis technique, please see Appendix E. 3.5.4 Details of the specific steps taken to arrive at the domain scores are given in the appropriate places in Chapter 4. This approach to combining the indicators into the domains replicates that taken in the Indices of Deprivation 2010 and earlier Indices.
3.5.5 The domain scores and ranked indices that are generated as a result of this stage, and the sub-domain scores before ranking and transforming to an exponential distribution, are published outputs (see Appendix O for details of the published data and spreadsheets). These domain indices can be used in the own right by users interested in particular dimensions of deprivation rather than the overall Index of Multiple Deprivation.
3.6 Stage 5: Domain scores are ranked and the domain ranks transformed to a specified exponential distribution
3.6.1 When combining the domains to form an overall index, it is important that the scores of each domain are comparable and that the weighting of domains is not distorted by the fact that the domains may have very different distributions. It is also important to select a method of combination that does not result in deprivation on one domain being cancelled out by lack of deprivation on another domain. It is fundamental to the model of deprivation employed in the Indices that deprivations are cumulative.
3.6.2 In order to combine the domains, a number of steps are necessary. First the domain scores must be standardised, that is converted in such a way that they are measured on the same metric. Second, the standardised domain scores must be transformed to the same distribution. The different distributions would otherwise distort the impact of the explicit weights used in the final stage to combine the domains into the overall Index of Multiple Deprivation.
3.6.3 There are a number of different statistical techniques that can be employed to standardise and transform the domain scores to prepare them for combination. The method which has been employed since the Indices of Deprivation 2000 – exponential transformation of the ranked domain score – was explicitly designed to reduce ‘cancellation effects’. So, for example, high levels of deprivation in one domain are not completely cancelled out by low levels of deprivation in a different domain. Also the exponential transformation applied puts more emphasis on the deprived end of the distribution and so facilitates identification of the most deprived areas.
3.6.4 The property of the exponential distribution which effectively emphasises the most deprived part of the distribution means that the Indices are specifically constructed to identify deprivation and not affluence. Put another way, the Indices discriminate well between deprived neighbourhoods but not between those in the less deprived part of the distribution.
3.6.5 The Indices of Deprivation 2015 uses exponential transformation of the ranks, as in the previous Indices. A more extensive account of the exponential transformation procedure is given in Appendix F. 3.6.6 In order to allow users to combine domains using alternative weights for specific purposes, the exponentially transformed scores are made available in file 9 (see Appendix O for details of the published data and spreadsheets).
3.7 Stage 6: The exponentially transformed domain scores are combined using appropriate domain weights to form an overall Index of Multiple Deprivation
3.7.1 Combining the different domains into an overall index always involves weighting the domains, whether the weights are set explicitly or not. Greater weight on a specific domain gives greater importance to that domain in the overall index. Weights may be set explicitly, as they were in the Indices of Deprivation 2000 and subsequent updates. If domain scores were simply added together (after standardisation), this explicitly gives each domain an equal weight. Conversely, if domains are not standardised to lie on the same scale or distribution, then weights are set implicitly by the domain distributions.
3.7.2 The weights used for the Indices of Deprivation 2000 were derived from consideration of the academic literature on poverty and deprivation, as well as consideration of the levels of robustness of the indicators. This resulted in a decision to give the greatest weight to the Income Deprivation Domain and Employment Deprivation Domain. A fuller account of this is given in Appendix G.
3.7.3 The weights employed in the construction of the Index of Multiple Deprivation 2015 are shown in the table below. These weights are unchanged since the construction of the Index of Multiple Deprivation 2004 when the Crime Domain was introduced and the seven current domains established.
| Domain | Domain weight (%) | |---------------------------------------------|-------------------| | Income Deprivation Domain | 22.5 | | Employment Deprivation Domain | 22.5 | | Health Deprivation and Disability Domain | 13.5 | | Education, Skills and Training Deprivation Domain | 13.5 | | Barriers to Housing and Services Domain | 9.3 | | Crime Domain | 9.3 | | Living Environment Deprivation Domain | 9.3 |
3.7.4 While applying different weights would affect the Index of Multiple Deprivation, the impact may not be large. Research into the issue of weighting was carried out by the University of St Andrews (Dibben et al., 2007)(^{22}). Sensitivity testing on three different approaches to weighting showed that although a small adjustment could be made to the weights (in effect swapping the weights for the Employment
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(^{22}) Dibben, C., Atherton, I., Cox, M., Watson, V., Ryan, M. and Sutton, M. (2007) Investigating the Impact of Changing the Weights that Underpin the Index of Multiple Deprivation 2004, [http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/publications/communities/investigatingimpact](http://webarchive.nationalarchives.gov.uk/20100410180038/http://www.communities.gov.uk/publications/communities/investigatingimpact). Deprivation Domain and the Health Deprivation and Disability Domain) it did not have a large impact on the final Index of Multiple Deprivation ranks. This work is described in greater detail in Appendix G.
3.7.5 With reference to these research findings, the use of these weights was revisited in the most recent consultations preceding the release of the Indices of Deprivation 2007(^{23}) and Indices of Deprivation 2010(^{24}). Both consultations found 89 per cent of respondents were in favour of keeping the weights the same. Furthermore, the survey of users in July 2014 did not reveal significant support for moving to new weights. In light of the very high level of user support, the weights used in the Indices of Deprivation 2015 remain as used in the Indices of Deprivation 2010.
3.7.6 Based on these weights, the Index of Multiple Deprivation will suit the purposes of most users. But it is recognised that some users may wish to analyse deprivation using only a subset of the deprivation domains or to apply different weights. For example, analysts working in public health may wish to create a combined index that excludes the Health Deprivation and Disability Domain, allowing them to explore other forms of deprivation as a determinant of health outcomes. To facilitate users in applying alternative weights, the exponentially transformed domain scores (from stage 5) are published along with the appropriate population sizes; guidance on how to combine the domains together using different weights is provided in Appendix B of the Research Report.
3.8 Stage 7: The overall Index of Multiple Deprivation and domains are summarised for larger areas such as local authority districts
3.8.1 The previous stages produce the small area (Lower-layer Super Output Area) data for the Indices of Deprivation 2015. In this final stage, the small area statistics are summarised for larger areas such as local authority districts.
3.8.2 For larger areas, a single deprivation score (or rank) may not be adequate to accurately describe levels of deprivation across the area. Local authority districts can vary enormously in both geographic and population size, and may have very different patterns of deprivation. Some areas are deprived but contain relatively little variation in deprivation across their neighbourhoods; in other places deprivation may be concentrated in pockets of severe deprivation rather than being more evenly spread.
3.8.3 To summarise the level of deprivation in larger areas, a range of summary measures of the Index of Multiple Deprivation 2015, the domains and the two supplementary indices (Income Deprivation Affecting Children Index and Income
(^{23}) Department for Communities and Local Government (2007) Updating the English Indices of Deprivation 2004: Stage Two ‘Blueprint’ Consultation Report – Summary of Responses. http://webarchive.nationalarchives.gov.uk/20120919132719/http://www.communities.gov.uk/publications/communities/indicesdeprivationresponses
(^{24}) Department for Communities and Local Government (2011) English Indices of Deprivation consultation: summary of responses. https://www.gov.uk/government/consultations/english-indices-of-deprivation. Deprivation Affecting Older People Index) have been created\\textsuperscript{25}, see table below. No single summary measure is the ‘best’ measure. Each highlights different aspects of deprivation, and comparison of the different measures is needed to give a fuller description of deprivation in a large area. In addition, it is important to remember that the higher-area measures are summaries; the Lower-layer Super Output Area level data provides more detail than is available through the summaries.
\\textsuperscript{25} For the Indices of Deprivation 2010 and previous versions, the majority of summary measures published were for the Index of Multiple Deprivation only. In response to demand from users, additional summary measures for the domains and supplementary indices have been published here.
### Table 3.2. The higher-area summary measures
| Summary measure | Description | |-----------------|-------------| | Average rank | The average rank measure summarises the average level of deprivation across the higher-level area, based on the ranks of the Lower-layer Super Output Areas in the area. As all Lower-layer Super Output Areas in the higher-level area are used to create the average rank, this gives a measure of the whole area covering both deprived and non-deprived areas. The measure is population-weighted, to take account of the fact that Lower-layer Super Output Area population sizes can vary. | | Average score | The average score measure summarises the average level of deprivation across the higher-level area, based on the scores of the Lower-layer Super Output Areas in the area. As all Lower-layer Super Output Areas in the higher-level area are used to create the average score, this gives a measure of the whole area covering both deprived and non-deprived areas. The measure is population-weighted, to take account of the fact that Lower-layer Super Output Area population sizes can vary. | | Proportion of Lower-layer Super Output Areas in most deprived 10 per cent nationally | The proportion of Lower-layer Super Output Areas that are in the most deprived 10 per cent nationally. | | Extent | The extent measure is a summary of the proportion of the local population that live in areas classified as among the most deprived in the country. The extent measure uses a weighted measure of the population in the most deprived 30 per cent of all areas:
- The population living in the most deprived 10 per cent of Lower-layer Super Output Areas in England receive a ‘weight’ of 1.0;
- The population living in the most deprived 11 to 30 per cent of Lower-layer Super Output Areas receive a sliding weight, ranging from 0.95 for those in the most deprived eleventh percentile, to 0.05 for those in the most deprived thirtieth percentile. | | Local concentration | The local concentration measure is a summary of how the most deprived Lower-layer Super Output Areas in the higher-level area compare to those in other areas across the country. This measures the population-weighted average rank for the Lower-layer Super Output Areas that are ranked as most deprived in the higher-area, and that contain exactly 10 per cent of the higher-area population. | | Income scale and employment scale (two measures) | The two scale measures summarise the number of people in the higher-level area who are income deprived (the income scale) or employment deprived (the employment scale). |
3.8.4 In response to feedback from users, clearer guidance is provided on how to use and interpret these measures in the research report Section 3.3.
3.8.5 The table below sets out which summary measures have been published for the Index of Multiple Deprivation, the domains and supplementary indices. Table 3.3. The summary measures published for the Index of Multiple Deprivation, the domains and supplementary indices
| | Average rank | Average score | Proportion of Lower-layer Super Output Areas in most deprived 10 per cent nationally | Extent | Local concentration | Scale | |--------------------------|--------------|---------------|-------------------------------------------------------------------------------------|--------|---------------------|-------| | Index of Multiple Deprivation | x | x | x | x | x | x | | Income | x | x | x | | | x | | Employment | x | x | x | | | x | | Education | x | x | x | | | x | | Health | x | x | x | | | x | | Crime | x | x | x | | | x | | Living | x | x | x | | | x | | Barriers | x | x | x | | | x | | IDACI | x | x | x | | | x | | IDAOPI | x | x | x | | | x |
3.8.6 The higher-level geographical areas at which the Indices have been summarised are as follows: local authority districts, upper tier local authorities, local enterprise partnerships and clinical commissioning groups. These are published in files 10 - 13 (see Appendix O for details of the data and spreadsheets that have been published).
3.8.7 The population denominators used for the construction of the higher level geographies for the Index of Multiple Deprivation and all domains other than the Employment Deprivation domain are the mid-2012 Lower-layer Super Output Area population estimates, minus any prison populations. For the Employment Deprivation domain the working-age population aged 18 to 59/64 for mid-2012 and mid-2013 was used, minus any prison populations for that age group. For the supplementary indices the appropriate age group population estimate for mid-2012 was used, minus any prison populations for those age groups. These are published in file 6; see Appendix O for details of the published data and spreadsheets.
3.8.8 In order to construct these high-level geographical summaries, look-up tables were constructed to indicate which Lower-layer Super Output Areas nest within each of the high-level geographies. This nesting was precise except in the case of the Local Enterprise Partnerships, where a "best fit" Lower-layer Super Output Area lookup was provided by the Office for National Statistics.
3.9 Summary of the domains, indicators and methods used to construct the Indices of Deprivation 2015
3.9.1 Figure 3.3 summarises the domains, indicators and methods used to construct the Lower-layer Super Output Area level Indices of Deprivation 2015.
### Figure 3.3. Summary of the domains, indicators and statistical methods used to create the Indices of Deprivation 2015
| Income Deprivation Domain | Employment Deprivation Domain | Health Deprivation & Disability Domain | Education, Skills & Training Deprivation Domain | Crime Domain | Barriers to Housing & Services Domain | Living Environment Deprivation Domain | |---------------------------|-------------------------------|----------------------------------------|-----------------------------------------------|--------------|--------------------------------------|---------------------------------------| | Adults & children in Income Support families | Adults & children in Income-based Jobseeker’s Allowance families | Claimants of Jobseeker’s Allowance | Children & young people: | Recorded crime rates for: | Geographical barriers: | Indoors living environment | | Adults & children in Income-based Jobseeker’s Allowance families | Adults & children in Income-based Employment and Support Allowance families | Claimants of Employment and Support Allowance | Key stage 2 attainment | Violence | Road distance to: | Housing in poor condition | | Adults & children in Income-based Employment and Support Allowance families | Adults & children in Pension Credit (Guarantee) families | Claimants of Incapacity Benefit | Key stage 4 attainment | Burglary | Post office; primary school; general store or supermarket; GP surgery | | Adults & children in Pension Credit (Guarantee) families | Adults & children in Child Tax Credit and Working Tax Credit families not already counted | Claimants of Severe Disablement Allowance | Secondary school absence | Theft | Wider barriers: | Wider barriers: | | Asylum seekers in England in receipt of subsistence support, accommodation support, or both | SUM / LSOA total population | Claimants of Carer’s Allowance | Staying on in education | Criminal damage | Household overcrowding | Homelessness | | SUM / LSOA total population | Apply ‘shrinkage’ procedure to this rate | Apply ‘shrinkage’ procedure to all data | Entry to higher education | | Housing affordability | | | Apply ‘shrinkage’ procedure to this rate | SUM / LSOA population aged 18-64 | SUM / LSOA population aged 18-64 | Adults skills: | Constrain numerators to CDRP totals, create rates then apply ‘shrinkage’ procedure to the four rates | Apply ‘shrinkage’ procedure to overcrowding | | | Income Deprivation Domain Index | Employment Deprivation Domain Index | Health Deprivation & Disability Domain Index | | Factor analysis used to generate weights to combine indicators | Standardise indicators in sub-domains and combine with equal weights | | | Employment Deprivation Domain Index | Health Deprivation & Disability Domain Index | Education, Skills & Training Deprivation Domain Index | | Factor analysis used to generate weights to combine indicators | | | | Health Deprivation & Disability Domain Index | Education, Skills & Training Deprivation Domain Index | Crime Domain Index | | Factor analysis used to generate weights to combine indicators | | | | Education, Skills & Training Deprivation Domain Index | Crime Domain Index | Barriers to Housing & Services Domain Index | | Two sub-domains standardised, exponentially transformed and combined with equal weights | | | | Crime Domain Index | Barriers to Housing & Services Domain Index | Living Environment Deprivation Domain Index | | Two sub-domains standardised, exponentially transformed and combine using weights (0.66 ‘indoors’ and 0.33 ‘outdoors’) | | |
Domain scores ranked and transformed to exponential distribution
| 22.5% | 22.5% | 13.5% | 13.5% | 9.3% | 9.3% | 9.3% |
Domain scores are weighted and combined in the proportions above. The resulting Index of Multiple Deprivation 2015 scores are then ranked. Chapter 4. The domains and indicators
4.1 Introduction
4.1.1 This chapter describes the 37 component indicators in the Indices of Deprivation 2015 and how these were combined to create each domain. Appendix A lists the data sources used for each indicator and Appendix B describes how denominators for indicators were selected.
4.1.2 In this chapter, a section at the end of each domain summarises changes made to indicators since the Indices of Deprivation 2010. This summary covers new or dropped indicators and briefly describes modifications to indicators; more detail is presented in Appendix C which contains a full description of the changes. Where benefits have been replaced or there have been eligibility changes since the Indices of Deprivation 2010, this is discussed in the main text.
4.2 Domains
4.2.1 The Indices of Deprivation 2015 are a relative measure of deprivation for small areas (Lower-layer Super Output Areas) across England. The overall Index of Multiple Deprivation 2015 combines together indicators under seven different domains of deprivation, detailed in the following sections:
- Income Deprivation
- Employment Deprivation
- Education, Skills and Training Deprivation
- Health Deprivation and Disability
- Crime
- Barriers to Housing and Services
- Living Environment Deprivation.
4.2.2 In addition there are two supplementary indices: the Income Deprivation Affecting Children Index and the Income Deprivation Affecting Older People Index. These are described under the Income Deprivation Domain, since they are subsets of this domain.
4.3 Income Deprivation Domain
4.3.1 The Income Deprivation Domain measures the proportion of the population in an area experiencing deprivation relating to low income. The definition of low income used includes both those people that are out-of-work, and those that are in work but who have low earnings (and who satisfy the respective means tests).
The indicators
- Adults and children in Income Support families
- Adults and children in income-based Jobseeker’s Allowance families
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26 The word ‘family’ is used to designate a ‘benefit unit’, that is the claimant, any partner and any dependent children (those for whom Child Benefit is received). • Adults and children in income-based Employment and Support Allowance families • Adults and children in Pension Credit (Guarantee) families • Adults and children in Working Tax Credit and Child Tax Credit families not already counted, that is those who are not in receipt of Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee) and whose equivalised income (excluding housing benefit) is below 60 per cent of the median before housing costs • Asylum seekers in England in receipt of subsistence support, accommodation support, or both
Indicator details
Adults and children in Income Support families
Adults and children in income-based Jobseeker’s Allowance families
Adults and children in income-based Employment and Support Allowance families
Adults and children in Pension Credit (Guarantee) families
4.3.2 These four indicators comprise a non-overlapping count of the number of adults and children in a Lower-layer Super Output Area living in families claiming Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee). Data for August 2012 was sourced from databases held by the Department for Work and Pensions and HM Revenue & Customs.
4.3.3 Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance and Pension Credit (Guarantee) are means-tested social security benefits. The benefits are mutually exclusive so there is no double counting involved. To be eligible for these benefits, claimants must be able to demonstrate that their income and savings are below specified thresholds.
4.3.4 Income-based Employment and Support Allowance replaced Income Support paid because of an illness or disability for new claims (from October 2008). To account for this, adults and children in income-based Employment and Support Allowance families were included in the domain in addition to adults and children in Income Support families.
4.3.5 The Lower-layer Super Output Area level count was constructed by selecting relevant claimants from the Department for Work and Pensions’ Unified Publication Database, matching in information on dependent partners (conducted within the Department for Work and Pensions) and dependent children (conducted within HM Revenue & Customs), then aggregating to Lower-layer Super Output Area level. The administrative records used to construct the indicators are the same as those used to produce published National Statistics. Adults and children in Working Tax Credit and Child Tax Credit families
Child Tax Credit component
4.3.6 The Child Tax Credit component of this indicator was constructed as the number of adults and children in a Lower-layer Super Output Area living in Child Tax Credit families, who are not claiming Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee), and whose equivalised income(^{27}) (excluding housing benefits) is below 60 per cent of the national median before housing costs(^{28}). Data for August 2012 was sourced from a database held by HM Revenue & Customs.
4.3.7 Child Tax Credit is payable to families with children who are either:
- Claiming out-of-work benefits
- In work and claiming Working Tax Credit
- Claiming neither out-of-work benefits nor Working Tax Credit but whose household income does not exceed the Child Tax Credit income threshold.
Working Tax Credit component
4.3.8 The Working Tax Credit component of this indicator was constructed as the number of adults in a Lower-layer Super Output Area in receipt of Working Tax Credit (who are not claiming Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee) and are not counted already under the Child Tax Credit component above) and whose equivalised income (excluding housing benefits) is below 60 per cent of the national median before housing costs. Data for August 2012 was sourced from a database held by HM Revenue & Customs.
4.3.9 Working Tax Credit is payable to people who:
- are aged from 16 to 24 and have a child or a qualifying disability, or are aged 25 or over (with or without children); and
- work at least the specified number of hours; and
- have an income below the means tested level.
Asylum seekers in England in receipt of subsistence support, accommodation support, or both
4.3.10 The indicator is the number of asylum seekers (adults and children) in a Lower-layer Super Output Area who were in receipt of subsistence support, accommodation support or both. Data for August 2012 was supplied by the Home Office.
(^{27}) Income equilvalisation is a way of taking into account variations in household size and/or composition when making income comparisons between households. The Organisation for Economic Co-operation and Development’s modified equivalence scale is used to equilvalise household income in this indicator.
(^{28}) The official low income threshold is 60 per cent of median household equivalised income. The Department for Work and Pensions’ Households Below Average Income team provided a special version of the 60 per cent of median threshold which is at assessment unit level (claimant, partner and dependent children) and which takes into account only income that is required for the Working Tax Credit/Child Tax Credit calculation. This methodology is also used for the annual estimate of child poverty undertaken by the Child Poverty Unit in accordance with its mandate contained in the Child Poverty Act 2010. 4.3.11 Asylum is protection given to someone fleeing persecution in their own country under the 1951 United Nations Convention Relating to the Status of Refugees. In the UK, asylum seekers who are homeless or without money to buy food and other essentials (‘destitute’) can apply for subsistence and accommodation support while their application is being considered(^{29}).
Combining the indicators to create the domain
4.3.12 The counts for each of these indicators at Lower-layer Super Output Area level were summed to produce a non-overlapping overall count of income deprived individuals. This overall count was then expressed as a proportion of the total population of the Lower-layer Super Output Area for mid-2012 (from the Office for National Statistics) less the prison population (from the Ministry of Justice). Shrinkage was applied to construct the overall domain score(^{30}).
Changes since the Indices of Deprivation 2010
4.3.13 The indicators in the domain remain the same as in the Indices of Deprivation 2010, except for an enhancement to the Working Tax Credit and Child Tax Credit indicator, to include all people receiving tax credits who are below the income threshold. Where benefits have been replaced or there have been eligibility changes since the Indices of Deprivation 2010, this has been described above. Further details of all these changes are given in Appendix C.
4.3.14 New sanctions regulations were introduced in 2012 for claimants of certain benefits. As explained in Appendix M, those affected by sanctions could not be included in the domain due to a lack of suitable data.
4.3.15 The data on claimants of income-based Employment Support Allowance (which replaced Incapacity Benefit and Income Support paid because of an illness or disability for new claimants from 2008) has now been incorporated into this indicator. Work Capability Assessments for Employment Support Allowance were introduced in 2008, reducing the number of people eligible for income related support because of an illness or disability.
Supplementary indices
4.3.16 In addition, two supplementary indices were created, which are subsets of the Income Deprivation Domain. These are the Income Deprivation Affecting Children Index and the Income Deprivation Affecting Older People Index:
The Income Deprivation Affecting Children Index is the proportion of all children aged 0 to 15 living in income deprived families. Income deprived families are defined as families that either receive Income Support or income-based Jobseekers Allowance or income-based Employment and Support Allowance or Pension Credit (Guarantee) or families not in receipt of these benefits but in receipt of Working Tax Credit or Child Tax Credit with an equivalised income (excluding
(^{29}) See [www.gov.uk/browse/visas-immigration/asylum](http://www.gov.uk/browse/visas-immigration/asylum) for further details on asylum support in the UK.
(^{30}) Shrinkage is a statistical method used to ‘borrow strength’ from larger areas (the local authority district) to reduce the impact of unreliable small area data. This is described in Section 3.4 and Appendix D. housing benefit) below 60 per cent of the national median before housing costs. Shrinkage was applied to construct the Income Deprivation Affecting Children Index score.
The Income Deprivation Affecting Older People Index is the proportion of all those aged 60 or over who experience income deprivation. This includes adults aged 60 or over receiving Income Support or income-based Jobseekers Allowance or income-based Employment and Support Allowance or Pension Credit (Guarantee). Shrinkage was applied to construct the Income Deprivation Affecting Older People Index score.
4.4 Employment Deprivation Domain
4.4.1 The Employment Deprivation Domain measures the proportion of the working-age population in an area involuntarily excluded from the labour market. This includes people who would like to work but are unable to do so due to unemployment, sickness or disability, or caring responsibilities.
The indicators
- Claimants of Jobseeker’s Allowance (both contribution-based and income-based), women aged 18 to 59 and men aged 18 to 64
- Claimants of Employment and Support Allowance (both contribution-based and income-based), women aged 18 to 59 and men aged 18 to 64
- Claimants of Incapacity Benefit, women aged 18 to 59 and men aged 18 to 64
- Claimants of Severe Disablement Allowance, women aged 18 to 59 and men aged 18 to 64
- Claimants of Carer’s Allowance, women aged 18 to 59 and men aged 18 to 64.
Indicator details
4.4.2 Data for the five indicators was provided by the Department for Work and Pensions, constructed from administrative records of benefit claimants in such a way to create a non-overlapping count of claimants. To account for seasonal variations in employment deprivation, four quarterly cuts were taken for each indicator and the average number of claimants across the four quarterly cuts calculated for each of the five indicators.
Claimants of Jobseeker’s Allowance
4.4.3 Jobseeker’s Allowance is paid to individuals who are out of work, available for work and actively seeking work. It is the primary measure of unemployment levels for small areas.
4.4.4 New Deal and Flexible New Deal have been replaced by the Work Programme, so the three New Deal indicators included in the Indices of Deprivation 2010 have been removed from the domain. Participants in the Work Programme are still in receipt of Jobseeker’s Allowance, so are included in the domain through this indicator.
4.4.5 From May 2012, any lone parents whose youngest child is aged 5 or over are no longer eligible for Income Support and are now eligible for Jobseeker’s Allowance. Accordingly this group were counted in this domain if they received Jobseeker’s Allowance.
Claimants of Employment and Support Allowance
Claimants of Incapacity Benefit
Claimants of Severe Disablement Allowance
4.4.6 Employment and Support Allowance, Incapacity Benefit and Severe Disablement Allowance are paid to individuals who are unable to work due to limiting illness or disability. Incapacity Benefit and Severe Disablement Allowance are no longer available for new claimants: Incapacity Benefit replaced Severe Disablement Allowance for new claimants in April 2001 and Employment and Support Allowance replaced Incapacity Benefit and Income Support paid because of an illness or disability for new claimants from October 2008. However, there still are a number of long-term sickness benefit claimants receiving Severe Disablement Allowance and Incapacity Benefit31.
Claimants of Carer’s Allowance
4.4.7 The new Carers Allowance indicator measures those adults who are involuntarily excluded from the labour market due to caring responsibilities. Carer’s Allowance is payable to people aged 16 or over who provide unpaid care for at least 35 hours a week to someone who is in receipt of disability or social care benefits, who are not in full-time education or studying, and earn less than £102 a week32.
Combining the indicators to create the domain
4.4.8 A non-overlapping count of claimants of each of the benefits was created for the following four time points to account for seasonal variations in employment deprivation: May 2012, August 2012, November 2012 and February 201333. The counts of Jobseeker’s Allowance, Employment and Support Allowance, Incapacity Benefit and Severe Disablement Allowance are non-overlapping because the benefits system does not permit an individual to claim more than one of these benefits at the same time. To account for the new Claimants of Carer’s Allowance indicator, a count of such claimants not receiving Jobseeker’s Allowance, Employment and Support Allowance, Incapacity Benefit and Severe Disablement Allowance was added to the domain numerator to provide a non-overlapping count.
31 As of February 2013 there were approximately 170,000 Severe Disablement Allowance claimants across England as a whole (an average of just over 5 claimants per Lower-layer Super Output Area) and 582,000 Incapacity Benefit claimants (just under 18 claimants per Lower-layer Super Output Area).
32 The eligible disability or social care benefits are: Personal Independence Payment daily living component, Disability Living Allowance middle or highest care rate, Attendance Allowance, Constant Attendance Allowance at or above the normal maximum rate with an Industrial Injuries Disablement Benefit, or basic (full day) rate with a War Disablement Pension or Armed Forces Independence Payment. Full-time studying is more than 21 hours per week. The earnings threshold is after the deduction of taxes, care costs while at work and 50 per cent of pension contributions.
33 These time points are consistent with the Income Deprivation Domain. Also, using later time points would mean that a subset of claimants would have migrated on to Universal Credit, which has different eligibility criteria to the existing Employment Deprivation Domain benefits. This was achieved by the Department for Work and Pensions through the use of a unique person identifier.
4.4.9 A quarterly averaged count of claimants/participants was calculated for each of the indicators to create the Employment Deprivation Domain numerator, calculated as the seasonally-adjusted count of employment deprived people per Lower-layer Super Output Area.
4.4.10 The denominator was the working-age population (women aged 18 to 59 and men aged 18 to 64), derived from mid-year population estimates (from the Office for National Statistics), with the prison population (from the Ministry of Justice) subtracted. In order to provide a time point which closely matches the numerator, 2012 and 2013 mid-year population estimates were used, with a weight of 0.75 applied to the 2012 count and a weight of 0.25 applied to the 2013 count.
4.4.11 The Employment Deprivation Domain numerator was expressed as a proportion of the Employment Deprivation Domain denominator to form the Employment Deprivation Domain score. The score represents the proportion of the working-age population experiencing employment deprivation. Shrinkage was applied to construct the final domain score.
Changes since the Indices of Deprivation 2010
4.4.12 The indicators in the domain remain the same as in the Indices of Deprivation 2010, except for the new indicator on claimants of Carer’s Allowance. As the New Deal ceased after the Indices of Deprivation 2010, the indicators based on New Deal claimants were removed.
4.4.13 Where benefits have been replaced or there have been eligibility changes since the Indices of Deprivation 2010, this has been described above. Further details on all these changes are given in Appendix C.
4.4.14 New sanctions regulations were introduced in 2012 for claimants of certain benefits. As explained in Appendix M, those affected by sanctions could not be included in the domain due to a lack of suitable data.
4.4.15 The data on claimants of contribution-based Employment Support Allowance (which replaced Incapacity Benefit and Income Support paid because of an illness or disability for new claimants from 2008) was incorporated into this indicator in the Indices of Deprivation 2010. Claimants of income-based Employment and Support Allowance are now also included together with the contribution-based claimants. Work Capability Assessments for Employment Support Allowance were introduced in 2008, affecting the number of people eligible for these benefits.
4.5 Education, Skills and Training Deprivation Domain
4.5.1 The Education, Skills and Training Domain measures the lack of attainment and skills in the local population. The indicators fall into two sub-domains: one relating to children and young people and one relating to adult skills. These two sub-domains are designed to reflect the ‘flow’ and ‘stock’ of educational disadvantage.
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34 A ratio of 3:1 between 2012 and 2013 has been adopted for the denominator to match the numerator which uses three time points from 2012 and one from 2013. within an area respectively. That is, the ‘children and young people’ sub-domain measures the attainment of qualifications and associated measures (‘flow’), while the ‘skills’ sub-domain measures the lack of qualifications in the resident working-age adult population (‘stock’).
The indicators
Children and Young People sub-domain
- Key Stage 2 attainment: The average points score of pupils taking reading, writing and mathematics Key Stage 2 exams
- Key Stage 4 attainment: The average capped points score of pupils taking Key Stage 4
- Secondary school absence: The proportion of authorised and unauthorised absences from secondary school
- Staying on in education post 16: The proportion of young people not staying on in school or non-advanced education above age 16
- Entry to higher education: A measure of young people aged under 21 not entering higher education
Adult Skills sub-domain
- Adult skills: The proportion of working-age adults with no or low qualifications, women aged 25 to 59 and men aged 25 to 64
- English language proficiency: The proportion of working-age adults who cannot speak English or cannot speak English well, women aged 25 to 59 and men aged 25 to 64
Indicator details
Key Stage 2 attainment 4.5.2 The indicator is the average points score for pupils at Key Stage 2. The numerator is the total score of pupils taking English and mathematics in 2010/11 and 2011/12, and reading, writing and mathematics in 2012/13, in a Lower-layer Super Output Area. The denominator is the total number of subjects (exams) taken by pupils for the same years as the numerator.
4.5.3 The data is for pupils in state-funded schools and was supplied by the Department for Education from the National Pupil Database, based on the Lower-layer Super Output Area of pupil residence. Three years of data were used to reduce issues due to fluctuations between year-groups.
4.5.4 During the 2010/11 to 2012/13 period for which data was used, changes to the grading scheme and teacher assessments resulted in changes to the way that the
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35 In 2012/13 the reading and writing components of English were assessed separately. Previously, the reading and writing components were assessed jointly. 36 The state-funded schools comprise: academies, free schools and City Technology Colleges, and schools maintained by a local authority (Community, Foundation, Voluntary Aided, Voluntary Controlled, Community Special and Foundation Special). average points scores are constructed\\textsuperscript{37}. Therefore, standardisation and shrinkage were applied separately to each year of data before combining into a single indicator using factor analysis.
**Key Stage 4 attainment**
4.5.5 The indicator is the average capped points score for pupils at Key Stage 4 (GCSE or equivalent)\\textsuperscript{38}. The numerator is the total capped score of pupils taking Key Stage 4 in 2010/11, 2011/12 and 2012/13 in a Lower-layer Super Output Area. The denominator is the total number of pupils in the area who took Key Stage 4 exams, for the same years as the numerator.
4.5.6 The data is for pupils in state-funded schools and was supplied by the Department for Education from the National Pupil Database, based on the Lower-layer Super Output Area of pupil residence. Three years of data were used to reduce issues due to fluctuations between year-groups. As each year’s results are separately moderated (and thus score thresholds change), standardisation and shrinkage were applied separately to each year of data before combining into a single indicator using factor analysis.
**Secondary school absence**
4.5.7 The indicator is the proportion of authorised and unauthorised absences from secondary school. The numerator is the number of half days missed by pupils living in a Lower-layer Super Output Area due to authorised and unauthorised absences for 2010/11, 2011/12 and 2012/13. The denominator is the total number of possible half-day sessions for 2010/11, 2011/12 and 2012/13.
4.5.8 The data is for pupils in state-funded schools and was supplied by the Department for Education from the National Pupil Database, based on the Lower-layer Super Output Area of pupil residence. Three years of data were used to reduce issues due to fluctuations between year-groups. Shrinkage was applied to the indicator.
**Staying on in education post 16**
4.5.9 The indicator measures the proportion of young people not staying on in school or non-advanced education above age 16, based on receipt of Child Benefit. Child Benefit is a tax-free payment that most parents can claim for their child(ren).
\\textsuperscript{37} In 2010/11, students sat separate English and maths National Curriculum Tests, with the average points score calculated from these two tests and with level 5 (point score 33) being the maximum achievable grade. In 2011/12, the writing element of the English exam was changed to be based on teacher assessment of a mixture of tests and coursework, with only partial external moderation. The reading element was still assessed externally with a National Curriculum Test, and in addition, a new level 6 test was introduced with a point score of 39 (the previous maximum point score was 33). In 2012/13, there were separate point scores for reading and writing, rather than a combined score. The writing element was entirely based on the teacher’s internal assessment of work for the year. See http://www.education.gov.uk/schools/performance/2011/primary_11/PointsScoreAllocation2011.pdf p1, http://dera.ioe.ac.uk/12366/1/assessment%20and%20reporting%20arrangements%20-%20key%20stage%202.pdf p.5 and 6, http://www.naldic.org.uk/Resources/NALDIC/Teaching%20and%20Learning/ARA2013.pdf p.6.
\\textsuperscript{38} The average capped points score caps the total number of courses that can be included at the equivalent of eight full GCSEs. This places higher weight on the grades within the core of eight subjects than on the quantity of courses taken. Children aged under 16 are eligible. Those aged between 16 and 19 are only eligible if they are in relevant education or training, or registered for work, education or training with an approved body.
4.5.10 The numerator for the indicator is the number of people aged 17 receiving Child Benefit (who are only eligible if they are in relevant education or training), at Lower-layer Super Output Area level for the period 2010 to 2012. The denominator is the number of people in the area aged 15 receiving Child Benefit in the period 2008 to 2010.
4.5.11 The indicator definition is based on the assumption that the group of young people aged 17 in a Lower-layer Super Output Area in a given year is comparable to the group aged 15 two years previously. For indicator reliability, the value of deriving the numerator and the denominator from the same (Child Benefit) source is seen to outweigh the impact of in-migration and out-migration of young people in this age cohort between the two time points.
4.5.12 The data was supplied by HM Revenue & Customs. The indicator was calculated in a positive form as the proportion of children staying on in school or non-advanced education. This figure was subtracted from 1 to produce the proportion not staying on in education after the age of 16. Shrinkage was applied to the indicator.
**Entry to higher education**
4.5.13 The indicator is a measure of young people aged under 21 not entering higher education. The numerator is the number of successful entrants aged under 21 to higher education in a Lower-layer Super Output Area. Data from the Higher Education Statistics Agency was used for the numerator, with four years of data – 2009/10 to 2012/13 – used to reduce the problems of small numbers and year-on-year fluctuation. The denominator was the population aged 14-17 in the Lower-layer Super Output Area for the four years, 2009 to 2012 less the prison population.
4.5.14 The indicator includes those aged under 21 who successfully applied from a domestic postcode in England to a higher education institution anywhere in the UK(^{39}). The data was restricted to first degree, first year, full-time students, and age was as at 31 August each year.
4.5.15 As detailed above, the numerator and denominator for this indicator were constructed from four years of data, now possible due to the availability of annually updated data. The indicator was calculated in a positive form as a measure of those aged 21 entering higher education. This figure was subtracted from 1 to produce the measure of young people not entering higher education. Shrinkage was applied to the indicator.
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(^{39}) For the purpose of the Higher Education Statistics Agency’s data collection, ‘higher education’ refers to courses for which the level of instruction is above that of level 3 of the Qualifications and Curriculum Authority National Qualifications Framework (for example courses at the level of Certificate of Higher Education and above). Adult skills
English language proficiency
4.5.16 The adult skills indicator is the proportion of working-age adults (women aged 25 to 59 and men aged 25 to 64) with no or low qualifications.
4.5.17 The English language proficiency indicator is the proportion of the working-age population (women aged 25 to 59 and men aged 25 to 64) who cannot speak English or cannot speak English ‘well’. This new indicator was included in the Adult Skills sub-domain to include those adults who experience barriers to learning and disadvantage in the labour market as a result of lack of proficiency in English.
4.5.18 A non-overlapping count of those adults with no or low qualifications, and/ or who cannot speak English or cannot speak English ‘well’ was provided by the Office for National Statistics from Census 2011 data. The denominator was the number of working-age adults (women aged 25 to 59 and men aged 25 to 64) in the same area, again taken from the 2011 Census. Shrinkage was applied to the indicator.
Combining the indicators to create the domain
4.5.19 The indicators within the Children and Young People sub-domain were standardised by ranking and transforming to a normal distribution. The maximum likelihood factor analysis technique was used to generate the weights to combine the indicators into the sub-domain score see Table 4.1.
| Indicator | Indicator weight | |------------------------------------------------|------------------| | Key Stage 2 attainment | 0.210 | | Key Stage 4 attainment | 0.232 | | Secondary school absence | 0.224 | | Staying on in education post 16 | 0.130 | | Entry to higher education | 0.204 |
4.5.20 The indicators within the Adult Skills sub-domain were the proportion of adults with no or low qualifications and/ or lack of English language proficiency. As these were already combined into a non-overlapping indicator, no further combination was needed within the sub-domain.
4.5.21 The two sub-domains were standardised by ranking and transforming to an exponential distribution and combined with equal weights to create the overall domain score.
Changes since the Indices of Deprivation 2010
4.5.22 The indicators in the domain remain the same as in the Indices of Deprivation 2010, except for the removal of the Key Stage 3 attainment indicator (Key Stage 3 assessments became teacher assessment only from 2008/9), the addition of the indicator on English language proficiency, and the change in the upper age band of the adult skills indicator from 54 in the Indices of Deprivation 2010 to 59 for women and 64 for men. Appendix C gives more details and describes other minor changes. to indicators in this domain, for example due to changes in available data, and changes to definitions.
4.6 Health Deprivation and Disability Domain
4.6.1 The Health Deprivation and Disability Domain measures the risk of premature death and the impairment of quality of life through poor physical or mental health. The domain measures morbidity, disability and premature mortality but not aspects of behaviour or environment that may be predictive of future health deprivation.
The indicators
- Years of potential life lost: An age and sex standardised measure of premature death
- Comparative illness and disability ratio: An age and sex standardised morbidity/disability ratio
- Acute morbidity: An age and sex standardised rate of emergency admission to hospital
- Mood and anxiety disorders: A composite based on the rate of adults suffering from mood and anxiety disorders, hospital episodes data, suicide mortality data and health benefits data.
Indicator details
Years of potential life lost
4.6.2 The years of potential life lost indicator measures ‘premature death’, defined as death before the age of 75 from any cause (the commonly used measure of premature death). This includes death due to disease as well as external causes such as accidents, unlawful killing and deaths in combat.
4.6.3 The indicator was based on mortality data covering the period 2008 to 2012, provided by the Office for National Statistics. The denominator was the 2008 to 2012 mid-year population estimates (minus the prison population) in five-year age-sex bands. The level of unexpected mortality was weighted by the age of the individual who has died. The unexpected death of a younger person therefore has a greater impact on the overall score than someone who is older, even if their death is also unexpected.
4.6.4 The indicator was directly age and sex standardised in five-year age-sex bands: comparing the actual number of deaths in an area to what would be expected given the area’s age and sex structure. Shrinkage was applied to the indicator.
Comparative illness and disability ratio
4.6.5 The comparative illness and disability ratio is an indicator of work limiting morbidity and disability, based on those receiving benefits due to inability to work through ill health.
4.6.6 The benefits paid to people who are unable to work due to ill health are Disability Living Allowance, Employment and Support Allowance, Attendance Allowance, the disability premium of Income Support, Incapacity Benefit, and Severe Disablement Allowance (these last two benefits are not available for new claimants, but there are groups still receiving them). Individuals cannot receive more than one of these benefits at the same time, so the numbers of people receiving them can be straightforwardly summed to produce an indicator.
4.6.7 The indicator was based on data from 2013 provided by the Department of Work and Pensions. The denominator was the 2013 mid-year population estimate (minus the prison population) in five-year age-sex bands. The indicator was directly age and sex standardised in five-year age-sex bands; comparing the actual number of benefit recipients in an area to what would be expected given the area’s age and sex structure. Shrinkage was applied to the indicator.
**Acute morbidity**
4.6.8 The acute morbidity indicator measures the level of emergency admissions to hospital, based on administrative records of inpatient admissions.
4.6.9 Emergency admissions are defined as cases where ‘admission is unpredictable and at short notice because of clinical need’. This includes admission via the Accident and Emergency department, admission directly onto a ward or into theatre and the emergency transfer of patients between hospitals. All emergency admissions greater than one day in length (where discharge is not on the same date as admission) are included as an indication of acute health problems. Only admissions to NHS hospitals are included in the data.
4.6.10 The numerator used the number of hospital spells starting with admission in an emergency and lasting more than one calendar day, and was based on data from the period 2011/12 to 2012/13 provided by the Health and Social Care Information Centre from the Hospital Episode Statistics database. The denominator was the 2011 and 2012 mid-year population estimates (minus the prison population) in five-year age-sex bands.
4.6.11 Two years of data were used to reduce the problems of small numbers. The indicator was directly age and sex standardised in five-year age-sex bands, and shrinkage applied.
**Mood and anxiety disorders**
4.6.12 The mood and anxiety disorders indicator is a broad measure of levels of mental ill health in the local population. The definition used for this indicator includes mood (affective), neurotic, stress-related and somatoform disorders.
4.6.13 The indicator is a modelled estimate based on four separate sources outlined in the sections below: prescribing data; hospital episodes data; suicide mortality data; and health benefits data. Although none of the four sources on their own provide a comprehensive measure of mood and anxiety disorders, used in combination they represent a large proportion of all those suffering mental ill health.
*Prescribing data*
4.6.14 The number of patients within a particular GP practice with mental health problems was estimated using information on the conditions for which particular drugs are prescribed and their typical dosages\\textsuperscript{40}. Prescription data is published at GP practice level\\textsuperscript{41}, and a two-stage process used to estimate area rates.
1. The number of people was estimated based on the assumption that those with mental ill health take the national ‘average daily quantity’ of a specific drug on every day of the year\\textsuperscript{42}. Two years of prescription data (for 2012 and 2013) were used to reduce problems of small numbers.
2. The estimate for each GP practice was then distributed indirectly to Lower-layer Super Output Area level using data on GP practice patients place of residence by Lower-layer Super Output Area level\\textsuperscript{43}.
4.6.15 The denominator for the indicator was based on the same practice population distribution used to distribute the GP Practice estimates to local areas.
\\textit{Hospital episode data}
4.6.16 Hospital episode data made available by the Health and Social Care Information Centre was used to estimate the proportion of the population suffering severe mental health problems relating to depression and anxiety, based on all those who have had an inpatient spell for reason of mental ill health.
4.6.17 The indicator is an annual count of those suffering at least one severe mental health inpatient spell during the year, an ‘annual incidence of hospitalisation’. A count was made of all those who have had at least one inpatient spell in any one year coded within International Classification of Diseases 10 chapter ‘F’ (the coding for mental ill health)\\textsuperscript{44}. Two years of data (for 2012 and 2013) were used to reduce problems of small numbers.
4.6.18 The denominator was the 2012 and 2013 mid-year population estimates (minus the prison population). A simple (not standardised) rate was calculated, and shrinkage applied.
\\textsuperscript{40} Based on prescription medication use for anxiolytics (British National Formulary Section 4.1.2) and anti-depressants (British National Formulary Section 4.3). \\url{http://www.hscic.gov.uk/catalogue/PUB06624/nat-dem-e-anti-pres-audi-summ-rep-apx4.pdf}.
\\textsuperscript{41} GP practice level prescription data was sourced from the Health and Social Care Information Centre (HSCIC) at \\url{http://www.hscic.gov.uk/gpprescribingdata} and \\url{http://www.hscic.gov.uk/searchcatalogue?q=title%3A%22presentation+level+data%22&area=&size=10&sort=Relevance}.
\\textsuperscript{42} While this assumption may not fit very well in individual cases, it is more likely to hold across the ‘average’ for the practice population. For information on average daily quantities, see the Prescribing Support Unit information at \\url{www.hscic.gov.uk/prescribing}. The average daily quantities were used to produce an estimate of the numbers of patients required to account for the GP Practice level prescription volumes for the different prescription drugs based on ‘typical’ dosages.
\\textsuperscript{43} The GP Attribution Dataset contains information about populations registered with GP practices, and is maintained by the Health and Social Care Information Centre. From 2013, data is published for individual GP practice patients at Lower layer Super Output Area level, for example \\url{http://www.hscic.gov.uk/article/2021/Website-Search?productid=16172}. For earlier time points, data was made available by the Health and Social Care Information Centre.
\\textsuperscript{44} The International Classification of Diseases 10 mental health codes used were: F30-F39 (Mood (affective) disorders) and F40-F48 (Neurotic, stress-related and somatoform disorders). Suicide mortality data
4.6.19 Although suicide is not a direct measure of mental ill health, it is highly associated with depression where it is implicated in a majority of cases(^{45}). The actual measure used was deaths that occurred between 2008 and 2012 which had International Classification of Diseases 10 codes X60-X84 and Y10-Y34 excluding Y33.9 where the coroner’s verdict was pending. Five years of data were used to reduce problems of small numbers.
4.6.20 The denominator was the 2008 to 2012 mid-year population estimates (minus the prison population). A simple (not standardised) rate was calculated, and shrinkage applied.
Health benefits data
4.6.21 The rate of long-term sickness and disability in an area, including for mental health reasons, can be measured using information on receipt of particular benefits. Incapacity Benefit, Severe Disablement Allowance and Employment and Support Allowance benefits are paid to individuals of working-age who are unable to work because of ill health. These datasets are coded for medical conditions, and the codes were converted to an International Classification of Diseases 10 coding. A count of individuals with a condition within chapter ‘F’ was used as the numerator for the indicator(^{46}).
4.6.22 The numerator was based on data from 2013 provided by the Department of Work and Pensions. The denominator was the 2013 mid-year population estimate (minus the prison population). A simple (not standardised) rate was calculated, and shrinkage applied.
Combining the components to create a composite indicator
4.6.23 The four independent administrative data sources were combined to reduce the influence of under- or over-recording on any one source using weights generated by factor analysis, see Table 4.1.
| Indicator | Indicator weight | |-----------------------------------|------------------| | Prescribing data | 0.224 | | Hospital episode data | 0.419 | | Suicide mortality data | 0.086 | | Health benefits data | 0.270 |
4.6.24 Using the four components minimises the impact of any variation in the organisation and practice of local services, where individuals with identical mental health needs may receive different types of treatment; the combined indicator
(^{45}) See for example Inskip, H., Harris, E. and Barracough, B. (1998), Lifetime risk of suicide for affective disorder, alcoholism and schizophrenia, The British Journal of Psychiatry, 172, p.35-37. [http://bip.rcpsych.org/content/172/1/35.abstract](http://bip.rcpsych.org/content/172/1/35.abstract)
(^{46}) The precise International Classification of Diseases 10 codes were as for the hospital data used in the acute morbidity indicator above: F30-F39 (Mood (affective) disorders) and F40-F48 (Neurotic, stress-related and somatoform disorders). should therefore be a more precise measure of the underlying ‘true’ rate of mental health than any single indicator on its own.
4.6.25 Unlike the other indicators in this domain, the mood and anxiety disorders indicator is not age and sex standardised. Although there are particular ages when a person is at higher risk of suffering from these mental health disorders, and females are at greater risk than males, the distribution of mood and anxiety disorders does not follow a clear distribution over the lifespan so age and sex have not been controlled for.
Combining the indicators to create the domain
4.6.26 The indicators within the domain were standardised by ranking and transforming to a normal distribution. Factor analysis was used to generate the weights to combine the indicators into the final domain score, see Table 4.3.
| Indicator | Indicator weight | |----------------------------------------|------------------| | Years of potential life lost | 0.244 | | Comparative illness and disability ratio | 0.287 | | Acute morbidity | 0.254 | | Mood and anxiety disorders | 0.216 |
Changes since the Indices of Deprivation 2010
4.6.27 The indicators in the domain remain the same as in the Indices of Deprivation 2010. Where benefits have been replaced or there have been eligibility changes since the Indices of Deprivation 2010, this has been described above. Further details of these changes are given in Appendix C.
4.6.28 The data on claimants of Employment Support Allowance (which replaced Incapacity Benefit and Income Support paid because of an illness or disability for new claimants from 2008) was incorporated into this indicator since Indices of Deprivation 2010. Work Capability Assessments for incapacity benefits were also introduced in 2008, further affecting the number of people eligible for these benefits.
4.7 Crime Domain
4.7.1 Crime is an important feature of deprivation that has major effects on individuals and communities. The Crime Domain measures the risk of personal and material victimisation at local level.
The indicators
- Violence: The rate of violence per 1,000 at-risk population
- Burglary: The rate of burglary per 1,000 at-risk properties
- Theft: The rate of theft per 1,000 at-risk population
- Criminal Damage: The rate of criminal damage per 1,000 at-risk population. Indicator details
Violence: The rate of violence per 1,000 at-risk population
Burglary: The rate of burglary per 1,000 at-risk properties
Theft: The rate of theft per 1,000 at-risk population
Criminal Damage: The rate of criminal damage per 1,000 at-risk population
4.7.2 Recorded crime data for 2013/14 was made available via the Association of Chief Police Officers and the Home Office. The Appendix on quality assurance outlines the work done to check the input data and data processing involved (Appendix J).
4.7.3 The methodology used in the Indices of Deprivation 2015 is identical to that developed for and used in the Indices of Deprivation 2010, 2007 and 2004:
1. A list of notifiable offence codes that were active during the 2013/14 year was identified, which best replicated the definitions of the four Crime Domain indicators ‘violence’, ‘burglary’, ‘theft’ and ‘criminal damage’. See Appendix H for this list of offences by indicator.
2. Individual level geocoded crime records for this list of notifiable offences were extracted from the recorded crime data made available, and assigned to one of the four indicators.
3. Lower-layer Super Output Area level counts were constructed for each indicator by aggregating the individual event-level geocoded crime data using a bespoke mapping application. Where an incident occurred within 100 metres of a Lower-layer Super Output Area boundary, the incident was apportioned equally to the areas either side of the boundary. A series of rules were imposed to maximise data quality, such as ensuring that crimes that were geocoded to locations well outside of the respective force boundary were not mapped at this stage.
4.7.4 The Lower-layer Super Output Area level counts for each indicator were constrained to aggregate counts of crime (for an equivalent set of notifiable offence categories) published at Community Safety Partnership level which are available as open data. All recorded crimes are allocated a Community Safety Partnership identifier code, whilst a minority of recorded crimes are not allocated a detailed geocode. Any discrepancies between the Community Safety Partnership level data and the aggregated geocoded data are therefore dealt with in this constraining step, so that the constrained Lower-layer Super Output Area level aggregations from geocoded data sum up to match the Community Safety Partnership level open data exactly.
4.7.5 For the violence, theft and criminal damage indicators, the constrained Lower-layer Super Output Area counts for 2013/14 were expressed as crime rates per 1,000 ‘at-risk’ population, using a special population-based denominator. This denominator consisted of the total Lower-layer Super Output Area mid-year 2013
47 Although the Community Safety Partnership level open data statistics do relate to the same underlying occurrence of crime, they are semi-independent of the geocoded crime data because the Community Safety Partnership identifier in the crime record is not dependent upon the detailed geocode variable(s) (i.e. the grid reference or postcode). population estimate (minus the prison population) plus the non-resident workplace population from the 2011 Census.
4.7.6 For the burglary indicator, counts for Lower-layer Super Output Areas for 2013/14 were expressed as a crime rate per 1,000 ‘at-risk’ properties, using a special property-based denominator. This denominator consisted of residential dwellings at Lower-layer Super Output Area level from the 2011 Census plus non-domestic properties at the same level from Ordnance Survey’s Address Base.
4.7.7 Finally, shrinkage was applied to the Lower-layer Super Output Area level rates for each indicator, to produce the four indicator scores.
Combining the indicators to create the domain
4.7.8 The four composite shrunk indicators were standardised by ranking and transforming to a normal distribution. Factor analysis was used to generate the weights to combine the indicators into the domain score, see Table 4.4.
| Indicator | Indicator weight | |--------------------|------------------| | Violence | 0.324 | | Burglary | 0.189 | | Theft | 0.222 | | Criminal Damage | 0.265 |
Changes since the Indices of Deprivation 2010
4.7.9 The indicators in the domain remain the same as in the Indices of Deprivation 2010. Minor changes made to accommodate updated Home Office counting rules are described in Appendix C.
4.8 Barriers to Housing and Services Domain
4.8.1 The Barriers to Housing and Services Domain measures the physical and financial accessibility of housing and local services. The indicators fall into two sub-domains: ‘geographical barriers’, which relate to the physical proximity of local services, and ‘wider barriers’ which includes issues relating to access to housing such as affordability.
The indicators
Geographical Barriers sub-domain
- Road distance to a post office: A measure of the mean distance to the closest post office for people living in the Lower-layer Super Output Area
- Road distance to a primary school: A measure of the mean distance to the closest primary school for people living in the Lower-layer Super Output Area
- Road distance to a general store or supermarket: A measure of the mean distance to the closest supermarket or general store for people living in the Lower-layer Super Output Area
- Road distance to a GP surgery: A measure of the mean distance to the closest GP surgery for people living in the Lower-layer Super Output Area Wider Barriers sub-domain
- Household overcrowding: The proportion of all households in a Lower-layer Super Output Area which are judged to have insufficient space to meet the household’s needs
- Homelessness: Local authority district level rate of acceptances for housing assistance under the homelessness provisions of the 1996 Housing Act, assigned to the constituent Lower-layer Super Output Areas
- Housing affordability: Difficulty of access to owner-occupation or the private rental market, expressed as the inability to afford to enter owner-occupation or the private rental market.
Indicator details
Road distance to a post office
Road distance to a primary school
Road distance to a general stores or supermarket
Road distance to a GP surgery
4.8.2 The four road distance indicators were chosen for the Indices of Deprivation 2000 and retained in each subsequent update as they relate to key services that are important for people’s day-to-day life and to which people need to have good geographical access. All road distance indicators are constructed in the same way.
4.8.3 The indicators are defined as an average road distance measured in kilometres and calculated initially at Output Area level(^{48}).
4.8.4 The grid referenced locations of Post Offices were supplied by Post Office Ltd (for March 2014). All Post Office branches were included.
4.8.5 The postcoded locations of primary schools were obtained from the Department for Education’s Edubase system (July 2014). These postcodes were then geocoded using Code-Point Open (May 2014 version) and the ONS Postcode Directory (May 2014 version). All schools classified as ‘open’ or ‘open but proposed to close’ that are also ‘primary’ or ‘all through’ were included. In terms of the type of establishment, schools were included that are classified as local authority maintained schools, academies or free schools.
4.8.6 The grid referenced locations of food shops were obtained from the Ordnance Survey Points of Interest dataset (for March 2014). The definition of food shop includes supermarket chains, convenience stores and independent supermarkets. This includes concessions such as food shops within petrol stations, but administrative offices are removed.
4.8.7 The postcodes of GP premises were obtained from the Health and Social Care Information Centre (May 2014 release). These postcodes were geocoded using
(^{48}) For more information about Output Areas see: www.neighbourhood.statistics.gov.uk/dissemination/Info.do?page=nessgeography/neighbourhoodstatisticsgeographyglossary/neighbourhood-statistics-geography-glossary.htm#O Code-Point Open (May 2014 version), the ONS Postcode Directory (May 2014 version) and a small number of manual assignments. The dataset of GPs used to construct the indicator is a list of all active medical practices and prescribing cost centres (numbering approximately 8,200). It does not capture the size of a practice, which varies from that of a single practitioner to a large surgery with many GPs and additional health care professionals.
4.8.8 Because healthcare and education are a responsibility for the devolved administrations, only GPs and primary schools located in England have been taken into account when constructing the English Indices of Deprivation. However, food shops and post offices in mainland UK were included, so that account can be taken of services just within the Scottish or Welsh borders.
4.8.9 A bespoke geographic information system application was used to calculate the road distance to the closest service from the population weighted centroid of each Output Area. To create an average road distance for the Lower-layer Super Output Area, a population-weighted mean of the Output Area road distances was used. Each Output Area score was weighted according to the proportion of the Lower-layer Super Output Area population that is within the Output Area, and the weighted scores summed. The Output Area level population estimates used for population-weighting were obtained from the 2011 Census(^49).
**Household overcrowding**
4.8.10 The indicator is the proportion of households in a Lower-layer Super Output Area that are classed as overcrowded according to the definition below. The numerator is the number of overcrowded households in the Lower-layer Super Output Area, while the denominator is the number of households in the same area. Both were taken from the 2011 Census. Shrinkage was applied to the indicator.
4.8.11 The Census 2011 ‘occupancy rating’ provides a measure of whether a household’s accommodation is overcrowded or under-occupied. There are two measures of occupancy rating, one based on the total number of rooms in a household’s accommodation, and one based only on the number of bedrooms. As for the Indices of Deprivation 2010, the household overcrowding indicator uses the occupancy rating based on rooms. This relates the actual number of rooms in a dwelling to the number of rooms required by the household, taking account of the ages of, and relationships between, household members.
4.8.12 The room requirement(^50) used in the occupancy rating states that every household needs a minimum of two common rooms, excluding bathrooms, with bedroom requirements that reflect the composition of the household. The occupancy rating of a dwelling is expressed as a positive or negative figure, reflecting the number of rooms in a dwelling that exceed the household’s requirements, or by which the home falls short of its occupants’ needs.
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(^{49}) Each road distance indicator uses the total population for population-weighting, with the exception of the road distance to a primary school where the population of children aged 4 to 11 was used.
(^{50}) For worked examples of how the room requirement is calculated, see: [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-notes-and-clarifications/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-notes-and-clarifications/index.html) 4.8.13 All statistics derived from the 2011 Census and published by the Office for National Statistics are classified as National Statistics and comply fully with the National Statistics Code of Practice.
**Homelessness**
4.8.14 This local authority district level indicator is expressed as the rate of acceptances for housing assistance under the homelessness provisions of housing legislation (as defined below). Although the Indices of Deprivation 2010 indicator used data for a single year, the updated indicator was constructed from the average of data for three years (2011/12, 2012/13 and 2013/14) in order to increase the robustness of the indicator. The homelessness data used in the numerator is published by the Department for Communities and Local Government. The denominator is the local authority district count of households from the 2011 Census, which is the latest date for which this data is available.
4.8.15 Homelessness is defined as applications made to local housing authorities under the homelessness provisions of housing legislation where a decision was made and the applicant was found to be eligible for assistance (acceptances). It therefore excludes any households found to be ineligible.
4.8.16 The raw data used to construct the indicator was the same as those used to produce published National Statistics. Local authority district rates were assigned to the constituent Lower-layer Super Output Areas, with each such area in a district given the same rate. As this data is available at local authority district level, shrinkage was not applied to this indicator.
**Housing affordability**
4.8.1 The housing affordability indicator is a measure of the inability to afford to enter owner-occupation or the private rental market. The indicator is made up of two components relating to housing affordability: one component which measures difficulty of access to owner-occupation, and one component which measures difficulty of access to the private rental market. The private rental component considers whether people can afford to rent in the market without assistance from Housing Benefit. The two components were constructed separately.
4.8.2 The indicator is a modelled estimate based on house prices and rents in the relevant Housing Market Area and modelled incomes at Lower-layer Super Output Area level with a 2012 time point. The main data sources are the Family Resources Survey for household incomes and composition, the Regulated Mortgage Survey (Council for Mortgage Lenders) and Land Registry for house prices, and the Valuation Office Agency for market rents. Other sources include a range of Census and other published data at Lower-layer Super Output Area level, and indicators at local authority district level including the Annual Population Survey and the Annual Survey of Hours and Earnings.
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51 Jones, Coombes and Wong (2010) The Geography of Housing Market Areas in England, undertaken for the former National Housing and Planning Advice Unit and published by the Department for Local Government and Communities [www.gov.uk/government/publications/housing-market-areas](http://www.gov.uk/government/publications/housing-market-areas). For further details see [www.ncl.ac.uk/curds/research/defining/NHPAU.htm](http://www.ncl.ac.uk/curds/research/defining/NHPAU.htm). The geography of HMAs is described in Appendix I. 4.8.3 The target group is households where the head is aged under 40. This aims to capture the cohort of households entering the housing market based on the recognition that most first time buyers and renters are in the younger adult age group. To increase the robustness of the indicator, the age cut-off has changed since the Indices of Deprivation 2010, from 35 to 40, resulting in a larger number of cases in the relevant surveys with which to produce modelled estimates.
4.8.4 Households (that is the first benefit units in the household) are assigned to dwelling size groups based on their bedroom requirements as under the standard UK ‘bedroom standard’. Affordability criteria are broadly the same as for the Indices of Deprivation 2010. The threshold house prices and rents were based on the lower quartile of all sale prices/rents within size groups (0, 1, 2, 3 and 4 or more bedrooms) at Housing Market Area level. The lower tier of Housing Market Areas was used, with Lower-layer Super Output Area level price and local authority level rent data apportioned to Housing Market Areas (lower-tier Housing Market Areas are described in Jones et al (2010), see footnote 51, and Appendix I).
4.8.5 Income is defined as the income of the ‘first benefit unit’ in the household, excluding income from means-tested benefits. Income levels were estimated in stages, following similar lines to a study by Bramley and Watkins for the Improvement Service for Scottish local government, which estimated income and poverty measures for Scottish Datazones. Individual-level predictive regression models were developed based on income levels for individuals and households in the Family Resources Survey, applied to small areas using equivalent variables from Census and other sources at Lower-layer Super Output Area level; and constrained using the Office for National Statistics’ ‘groups’ of similar Lower-layer Super Output Areas in stronger or weaker housing markets.
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52 Technically, the head of household is known as the “Household Reference Person”, defined as the highest income householder without regard to gender. 53 The standard is defined in the Housing (Overcrowding) Bill 2003 and in summary allocates a bedroom for each couple and for each additional adult, and for each child or pair of children, provided that children over 10 do not have to share with the opposite sex. For the renting component, a single person household aged under 35 is deemed to need only a bedroom in a shared dwelling (using threshold rents available for a ‘0-bedroom’ unit). 54 The primary criterion for buying is based on lending multipliers, assuming a 95% mortgage and ignoring deposit constraints. For renting, the primary criterion is a ratio of rent to gross income of 25%. The secondary criterion for both buying and renting is that net income after housing cost should exceed 1.2 times the Housing Benefit Applicable Amount (HBAA) for the relevant household unit (DWP Housing Benefit and Council Tax Benefit Circular HB/CTB A1/2012, Appendix A, Annexe 2). 55 The first benefit unit is defined as the main householder and any partner and dependent children, where the household reference person is aged under 40. Other adults present in any ‘complex’ households are separate benefit units, and their income is not included because these would not be considered reckonable income for the purposes of obtaining a mortgage and because it is assumed that it is the core benefit unit that would be seeking to buy or rent an appropriate housing unit. For the same reason, the room requirements of other adults in a ‘complex’ household are not included when constructing the indicator. 56 Bramley, G. and Watkins, D. (2013) Local Incomes and Poverty in Scotland: developing local and small area estimates and exploring patterns of income distribution, poverty and deprivation, Report of Research for the Improvement Service on behalf of four Local Authorities (Edinburgh, Falkirk, Fife and Highland) and the Scottish Government. http://www.improvementservice.org.uk/library/download-document/3838-local-incomes-and-poverty-in-scotland/. 57 Lower-layer Super Output Areas were classified according to whether the Housing Market Area to which they belong has relatively lower or higher house prices. This classification was then combined with the Office 4.8.6 In order to combine the two components into a single indicator of housing affordability, each component was standardised by ranking and transforming to a normal distribution. The two components were then combined with equal weights to create the housing affordability indicator.
Combining the indicators to create the domain
4.8.7 The relevant indicators within each of the sub-domains were then standardised by ranking and transforming to a normal distribution, and combined using equal weights. The sub-domains were then standardised by ranking and transforming to an exponential distribution and combined with equal weights to create the overall domain score.
Changes since the Indices of Deprivation 2010
4.8.8 The indicators in the domain remain the same as in the Indices of Deprivation 2010, apart from changes to the housing affordability indicator including:
- broadening the measure to include affordability of the private rental market;
- improving the income estimation methodology, and producing the indicator at Lower-layer Super Output Area level, rather than local authority districts; and
- using local Housing Market Areas as the reference area.
4.8.9 Other minor changes to this domain, for example due to changes in available data, have been explained above. Further details of all these changes are given in Appendix C.
4.9 Living Environment Deprivation Domain
4.9.1 The Living Environment Deprivation Domain measures the quality of the local environment. The indicators fall into two sub-domains. The ‘indoors’ living environment measures the quality of housing; while the ‘outdoors’ living environment contains measures of air quality and road traffic accidents.
The indicators
*Indoors sub-domain*
- Houses without central heating: The proportion of houses that do not have central heating
- Housing in poor condition: The proportion of social and private homes that fail to meet the Decent Homes standard.
*Outdoors sub-domain*
- Air quality: A measure of air quality based on emissions rates for four pollutants
- Road traffic accidents involving injury to pedestrians and cyclists.
for National Statistics Census 2001-based classification of Lower-layer Super Output Areas at ‘Group’ level to produce the groups of similar Lower-layer Super Output Areas in stronger or weaker markets. Indicator details
**Houses without central heating**
4.9.2 The houses without central heating indicator is used as a measure of housing which is expensive to heat. The numerator is the number of houses without central heating in the Lower-layer Super Output Area while the denominator is the number of households in the area.
4.9.3 Data was taken from the Census 2011 (the previous indicator was based on Census 2001 data), and identifies the proportion of houses in each Lower-layer Super Output Area that do not have central heating in any room. Shrinkage was applied to the indicator.
**Housing in poor condition**
4.9.4 The housing in poor condition indicator is a modelled estimate of the proportion of social and private homes that fail to meet the Decent Homes standard.
4.9.5 A property fails the Decent Homes Standard if it fails to meet any one of the four separate components shown in the table below. Each of these components was modelled separately, using data from the 2011 English Housing Survey at national level, in combination with a commercial dataset that provides information on the age, type, tenure and occupant characteristics of the housing stock at individual dwelling level. Failure likelihood factors for individual dwellings were generated by segmentation analysis and logistic regression models, and aggregated to Lower-layer Super Output Area.
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58 The Census 2011 definition of central heating used includes gas, oil or solid fuel central heating, night storage heaters, warm air heating and underfloor heating.
59 See ‘A Decent Home: Definition and guidance for implementation’ published in June 2006 for details of the Decent Homes standard. [https://www.gov.uk/government/publications/a-decent-home-definition-and-guidance](https://www.gov.uk/government/publications/a-decent-home-definition-and-guidance) Table 4.5. The four components of the Decent Homes Standard
| Component | Description | |------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------| | Housing Health and Safety Rating System | Dwellings which fail to meet this criterion are those containing one or more hazards assessed as serious (‘Category 1’). The system includes 29 hazards in the home categorised into Category 1 (serious) or Category 2 (other). | | Disrepair | A dwelling is said to be in disrepair if: at least one of the key building components is old and needs replacing or major repair due to its condition; or more than one of the other building components are old and need replacing or major repair due to their condition. | | Modernisation | A dwelling is said to fail this criterion if it lacks three or more of the following: a reasonably modern kitchen (20 years old or less); a kitchen with adequate space and layout; a reasonably modern bathroom (30 years old or less); an appropriately located bathroom and WC; adequate insulation against external noise (where such noise is a problem); or adequate size and layout of common areas for blocks of flats. | | Thermal comfort | A dwelling fails this criterion if it does not have effective insulation and efficient heating. |
Air quality
4.9.6 The indicator is an estimate of the concentration of the four pollutants nitrogen dioxide, benzene, sulphur dioxide and particulates. Indicators for each of the pollutants were based on 2012 air quality data published by the UK Air Information Resource for 1km grid-squares(^60), which was modelled to Lower-layer Super Output Area level using the point-in-polygon method. For Lower-layer Super Output Areas that did not have grid points falling within them, data from the nearest point of the air quality grid was assigned.
4.9.7 For each pollutant the atmospheric concentration was compared to a national standard value(^61), with the concentrations in each Lower-layer Super Output Area divided by the appropriate national standard, before summing to produce a single indicator.
4.9.8 In theory, values for the combined indicator range from zero to infinity. However in practice values are unlikely to exceed 4, the equivalent of a site where concentrations of all four pollutants are at their respective thresholds.
4.9.9 Due to changes in the national targets(^62), the particulate matter component of the air quality indicator were based on particles less than 2.5 micrometres in diameter, rather than the 10 micrometres previously used. Additional pollutants (arsenic, cadmium, nickel and benzoapyrene) are also the subject of a new air quality
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(^60) UK-AIR: Air Information Resource [http://uk-air.defra.gov.uk/](http://uk-air.defra.gov.uk/)
(^61) The annual mean standards of nitrogen dioxide, benzene and particulates are defined by the UK’s National Air Quality Strategy while the safe guideline for sulphur dioxide is set by the World Health Organisation.
(^62) UK and EU Air Quality Policy Context [http://uk-air.defra.gov.uk/air-pollution/uk-eu-policy-context](http://uk-air.defra.gov.uk/air-pollution/uk-eu-policy-context) directive\\textsuperscript{63}. However the overwhelming majority of areas in the country have better-than-target values for these pollutants so they have not been included in the measure.
**Road traffic accidents involving injury to pedestrians and cyclists**
4.9.10 The indicator is based on reported accidents that involve death or personal injury to a pedestrian or cyclist\\textsuperscript{64}. The indicator uses data for 2011 to 2013 published by the Department for Transport, with three years of data used to reduce the problem of small numbers.
4.9.11 The numerator for this indicator is the number of reported accidents (weighted for severity) in a Lower-layer Super Output Area that involve death or personal injury to a pedestrian or cyclist, averaged across the three years 2011 to 2013. To take into account the number of people in the local area during the day, the denominator uses the non-resident workplace population (from Census 2011) as well as the average of the mid-year population estimates for 2011 to 2013 (from the Office for National Statistics) with the prison population (from the Ministry of Justice) subtracted.
4.9.12 Weights were applied to the total counts of the three severity types: a weight of 1 was applied for slight severity, 2 for serious and 3 for fatal. Each incident was plotted according to its grid reference, which gives its location accurate to 10 metres. Where an incident occurred within 100 metres of a Lower-layer Super Output Area boundary, the incident was apportioned equally to the areas either side of the boundary. Shrinkage was applied to the indicator.
**Combining the indicators to create the domain**
4.9.13 The indicators within each of the sub-domains was standardised by ranking and transforming to a normal distribution, and combined using equal weights to create the sub-domains. The sub-domains were standardised by ranking and transforming to an exponential distribution.
4.9.14 The domain was created by summing the two sub-domains, weighted according to patterns of ‘indoors’ and ‘outdoors’ time use\\textsuperscript{65}. As done in the Indices of Deprivation 2010, the Indoors Living Environment sub-domain was given two thirds of the domain’s weight, and the Outdoors Living Environment sub-domain, one-third.
\\textsuperscript{63} See Air Quality Standards Regulations 2010, http://www.legislation.gov.uk/uksi/2010/1001/pdfs/uksi_20101001_en.pdf
\\textsuperscript{64} Only accidents that involve at least one ‘mechanically propelled’ vehicle are included in the dataset. Accidents involving personal injury are counted, including deliberate acts of violence but not confirmed cases of suicide. Accidents involving pedal cycles are included. Where many casualties were associated with one accident, all pedestrian and cyclist casualties were counted. Injuries sustained on private roads and in car parks are not included. See www.gov.uk/government/collections/road-accidents-and-safety-statistics for details.
\\textsuperscript{65} UK 2000 Time Use Survey, http://discover.ukdataservice.ac.uk/catalogue?sn=4504 Changes since the Indices of Deprivation 2010
The indicators in the domain remain the same as in the Indices of Deprivation 2010, apart from changes to the housing in poor condition indicator which include an improved modelling methodology. Other minor changes to this domain, for example due to changes in available data, are described above. Further details of all these changes are given in Appendix C. Chapter 5. Ensuring reliability of the Indices of Deprivation
5.1 Overview of quality assurance
5.1.1 The Indices of Deprivation 2015 have been carefully designed and developed to ensure the robustness and reliability of the output datasets and reports. The quality assurance process for the methods, input data sources, data processing steps and outputs builds on the research team’s experience of previous developments of the Indices of Deprivation since 2000, and involves a number of different processes outlined in this section.
5.1.2 The quality assurance process also draws on the quality assurance and audit arrangements practice models developed by the UK Statistics Authority to ensure that the assessment of data sources and methodology carried out is proportionate to both the level of public interest in the Indices, and the scale of risk over the quality of the data.
5.1.3 Further detail on the quality assurance is provided in Appendices J, K and L, including our assessment against the UK Statistics Authority criteria for National Statistics status and additional validation carried out for the Crime domains and modelled indicators (Appendix J), an overview of the quality assurance process provided to data suppliers (Appendix K), and quality assurance documents for the input data sources (Appendix L).
Our assessment of the quality of the Indices of Deprivation
5.1.4 Based on the design and development of the Indices of Deprivation, and the quality assurance processes and actions, we have assessed that the Indices of Deprivation outputs are fit for purpose. This is based on our assessment of the level of risk of quality concerns and public interest in the Indices, which use the risk and profile matrix set out in the UK Statistics Authority toolkit.
5.1.5 In the following sections we outline how our quality management meets the criteria required for the basic and enhanced levels of assurance. Our quality assurance draws on the four practice areas associated with data quality set out by the UK Statistics Authority toolkit: operational context and data collection; communication with data suppliers; quality assurance principles, standards and checks; and quality assurance investigations carried out for enhanced assurance.
5.2 Designing the Indices to ensure quality
5.2.1 The starting point for the quality assurance work is that the Indices themselves have been designed to ensure the high quality of the output data. The design of the Indices of Deprivation 2015 is based on a set of principles and practices that help
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66 UK Statistics Authority (2015) Administrative Data Quality Assurance Toolkit. [http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-toolkit.pdf](http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-toolkit.pdf) to ensure data quality (more detail on the methods, domains and indicators is given in Chapters 3 and 4):
- The domains and Index of Multiple Deprivation bring together 37 indicators of deprivation, from a wide range of data sources. This sheer diversity of inputs also leads to more reliable overall data outputs; to be highly deprived on the Index of Multiple Deprivation, an area is likely to be highly deprived on many of the domains(^{67}). Due to the variety of data inputs, there is little chance that an area is identified as highly deprived due to a bias in one of the component indicators; the use of multiple independent indicators increases robustness of the final outputs.
- Shrinkage estimation is used to improve reliability of the small area data, by 'borrowing strength' from larger local authority districts. This tends to result in unreliable values (those having larger standard errors) being shifted or 'shrunk' towards the average of the larger area. During the development of the Indices (see below), all indicators were compared before- and after-shrinking, to examine the extent of movement of unreliable scores.
- The different domain scores are standardised (in order to combine them into the overall Index of Multiple Deprivation) by ranking across all areas. This has the effect of pulling-in any extreme area scores that lie at the top or bottom of the distribution. Exponential transformation is then used to ensure that deprivation on one domain is not completely cancelled out by lack of deprivation on another domain.
- The domains are weighted before combining into the overall Index of Multiple Deprivation. The smallest weights are given to the two domains containing modelled indicators (Barriers to Housing and Services, and Living Environment), which therefore have a relatively small impact on the overall Index of Multiple Deprivation.
5.3 How we have ensured quality of the Indices
**Appropriate and robust indicators, based on well understood data sources**
5.3.1 As outlined in Chapter 3, the development of the Indices of Deprivation 2015 identified a set of 37 indicators that can be used to measure relative deprivation within each of the domains. These indicators are based on data sources that can be used to derive appropriate measures covering England at small area level. Chapter 4 sets out the sources used for each of the indicators. The data sources used as inputs to the Indices of Deprivation 2015 can be grouped into three types as shown in the table below.
5.3.2 For each of the input data sources used, the research team assessed and documented its quality. Appendix L lists the quality documents for each data source. Close communication with the data suppliers ensured that the strengths and weaknesses of the underlying sources and indicators were well understood. In
(^{67}) To a lesser extent, this also applies to individual domains of deprivation; to be highly deprived on a domain, an area is likely to be highly deprived on the individual indicators from which the domain is constructed. some cases, this led to potential indicators being rejected as not sufficiently robust to use in the Indices of Deprivation 2015 (see Appendix M).
| Table 5.1. Types of data sources used as inputs to the Indices of Deprivation 2015 | |---------------------------------|---------------------------------|---------------------------------| | Data source | Notes | Documentation assessed | | Published i.e. open data | The preference was to directly use, wherever possible, existing high quality open data sources that have themselves been validated as being of National Statistics quality. In some cases, small variations on open data sources were obtained from the same source through special request; for example Census 2011 data on qualifications and English language proficiency was obtained from the Office for National Statistics. | Quality assurance report(s) supplied with the open data | | Administrative data sources made available to the research team | In the absence of appropriate published open data sources, the second preference was for the Indices of Deprivation 2015 to derive indicators from established and well-understood administrative data sources. These data sources, or indicators derived from them, were made available to the research team by data suppliers. In many cases, these data sources are also used by data suppliers to derive published statistical data outputs; for example the Income Deprivation and Employment Deprivation domains are in-part derived from the DWP Unified Publication Database, which is a source for DWP Official Statistics (many of which have themselves been assessed as being of National Statistics quality). In practice, the majority of indicators in the Indices were built directly from well-understood administrative sources in this way. | Quality assurance report(s) on the underlying administrative data sources | | Modelled estimates derived for the Indices of Deprivation 2015 | In the small number of cases where there was an absence of appropriate open data or established and well-understood administrative data sources, the Indices of Deprivation 2015 used specially modelled estimates for the deprivation indicator at hand. In practice, this was the case for only three indicators: housing affordability, housing in poor condition and air quality. These were developed and quality assured by leading experts in the appropriate fields (see Chapter 4 for further details on these indicators). | Quality assurance report(s) on any underlying data sources, and technical summaries of the methodology used to construct the indicator |
5.3.3 In practice, the majority of the datasets used in the Indices of Deprivation 2015 were derived from administrative records, which have close to 100 per cent coverage and are not subject to sampling error. In many instances the raw administrative records are the same as those used to produce published National Statistics. 5.3.4 The research team conducted additional exploration of issues that could affect the quality of the sources, such as the impact of any changes since the Indices of Deprivation 2010, and considered actions to minimise risks to quality. These are set out in Appendices J and M. As an example, the team explored the impact on benefits data of people affected by sanctions, and the potential to adjust the relevant indicators in the Income Deprivation and Employment Deprivation domains. Because data is only available on sanctions decisions taken during a particular month, and not on the total number of people subject to sanctions at a particular time point, the team were not able make adjustment for those subject to sanctions.
5.3.5 The following sections outline the quality assurance steps undertaken during the development of the data outputs. Appendix J provides further detail of the quality assurance process, under the framework outlined by the UK Statistics Authority.
Minimise the impact of potential bias and error in the input data sources
5.3.6 As set out in Section 5.2, the Indices of Deprivation have been carefully designed to minimise the impact of possible bias and error in the input data sources. The different processing stages, and range of different indicators used, mean that the resulting output datasets provide a robust identification of deprived areas.
5.3.7 An example of this comes from the Mood and anxiety disorders indicator of the Health and Disability Deprivation Domain. This indicator is constructed from four independent administrative data sources (see Section 4.6). Although none of the four sources on their own provide a comprehensive measure of mood and anxiety disorders, used in combination they represent a large proportion of all those suffering mental ill health. In addition, using the four component indicators in this way reduces the influence of under- or over-recording from any one source, and minimises the impact of any variation in the organisation and practice of local services, where individuals with identical mental health needs may receive different types of treatment. The combined indicator should therefore be a more precise measure of the underlying ‘true’ rate of mental health than any single indicator on its own.
Views of data users
5.3.8 This update of the Indices of Deprivation has involved close engagement with users to gather views on potential indicators and data sources, and to ensure that the outputs are of high quality and meet user needs. Their views were sought in the survey carried out in July 2014, the consultation in November 2014, and workshops in November and December 2014. There was considerable support for the methodology, including the new and enhanced indicators.
5.3.9 The Department for Communities and Local Government Project Board and its Advisory Group have also provided feedback on the methodology, data sources and quality assurance process. Audited, replicable and validated processing steps are used to construct the indicators, domains and Index of Multiple Deprivation 2015
5.3.10 All processing of the data was carried out using syntax, providing a complete audit of the processing steps from input data sources through to data outputs. Using syntax avoids the risks associated with carrying out calculations and processing using spreadsheets.
5.3.11 The syntax also enabled clearer validation and audit of the work done, both internally within the teams responsible for the domains and other members of the research team, and externally by the independent assessor (see paragraph 5.3.19). The checks included external replication and validation of the complete set of processing steps. The syntax was checked to confirm the processing steps were being implemented accurately, and produced data outputs as expected.
Real world validation of the data inputs and outputs
5.3.12 An important part of the checking process was to compare the Indices of Deprivation 2015 data against the data used to construct the previous Indices (the Indices of Deprivation 2010) at all stages in the process. A range of methods were used, including plotting histograms and box plots to examine the range and distribution of data, and scatter plots and correlations to determine the overall association of data between years. The final domains and Index of Multiple Deprivation were tabulated for the 2015 and 2010 versions, and areas that had changed significantly between the versions were examined.
5.3.13 The administrative datasets used in the Indices of Deprivation are liable to change between years as eligibility criteria, definitions and methodology are modified over time. To ensure that reliable data was used, the input data sources were compared thoroughly with the sources used in producing the previous Indices where available. This quality check was carried out before any data processing, in order to check for large differences that might indicate a methodological change in the administrative datasets being used.
5.3.14 Examining the input data sources also helped contextualise differences seen at a later stage of data processing. For example, trends in benefit claimant numbers, or road traffic accidents, were used in the quality checks once data processing had been carried out, helping judge whether any change between years identified by the Indices data is realistic.
5.3.15 Where possible, the Indices of Deprivation 2015 data was compared to equivalent published data to check that they were broadly similar. Small differences between the Indices of Deprivation 2015 data and published data are inevitable due to methodological differences, but significant differences could indicate a processing error. Published data was not always available at Lower-layer Super Output Area level so comparisons were made at a spatial scale that was possible, most commonly at local authority district level. Ideally this validation would have used data from independent sources to those used in constructing the Indices, however in practice this was not always possible as no such separate source existed.
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68 All processing was carried out using Stata 13 statistical software. 5.3.16 The deprivation deciles of each indicator, sub-domain and domain were mapped and the geographical pattern of deprivation examined. Checks of the overall distribution of deprivation across England were accompanied by more detailed checks of small areas known to the research team.
5.3.17 In addition, ‘reality checks’ were undertaken to consider whether the Indices of Deprivation 2015 data corresponded with the expected pattern of deprivation. For example, overcrowding is expected to be more severe in urban areas than rural locations because cities are more densely populated. Reality checking provides an additional check that the data processing has been correctly carried out, and that the indicators, domains and overall Index of Multiple Deprivation have been correctly ranked.
**Internal and external quality assurance checks**
5.3.18 *Internal audit.* The data processing steps and data outputs were subject to a series of internal quality assurance checks by the project team. Indicators and domains were reviewed by the team responsible for constructing the domain, and internally audited by a team member who was not involved in constructing the domain. The Index of Multiple Deprivation and higher-level summaries were reviewed and audited by three team members.
5.3.19 *External scrutiny of the complete process.* On completion of the Indices, an external independent assessor carried out external validation and assurance of the data processing steps for construction of the indicators, domains and Index of Multiple Deprivation from start to finish. This external scrutiny included assessment of the data processing methods and syntax, and real-world analysis of the Indices of Deprivation 2015 output datasets against the Indices 2010 data outputs and comparable open data sources.
**Additional enhanced assurance of specific data sources**
5.3.20 A small number of data sources were identified as requiring additional quality assurance. These were related to indicators in the Crime Domain, the acute morbidity indicator in the Health Deprivation and Disability Domain, and the modelled indicators of housing affordability and housing condition. The additional assurance work for these indicators is outlined in Appendix J.
**Roles and responsibilities of the research team and data suppliers**
5.3.21 The development and construction of the Indices of Deprivation was a complex project, involving multiple data suppliers and processing steps carried out by the research team. The composition of the research team carrying out the update of the Indices of Deprivation has been carefully considered to ensure quality of the data outputs.
5.3.22 In addition, clear communication and coordination between the different teams involved was an important part of ensuring the quality of the final outputs. Regular contact with each of the data suppliers helped understand the strengths and weaknesses of the different input data sources and modelling techniques used. Appendix A. Indicator details and data sources
A.1.1. This Appendix provides numerator and denominator details for each of the 37 indicators included in the Indices of Deprivation 2015.
A.1.2. As far as is possible, each indicator has been based on data from the most recent time point available. Using the latest available data in this way means that there is not a single consistent time point for all indicators, however in practice most indicators in the Indices of Deprivation 2015 relate to the tax year 2012/13.
A.1.3. Where the denominator is detailed as residential population, this includes the communal establishment population, but excludes any prison population.
A.2. Income Deprivation Domain
- **Adults and children in Income Support families** Numerator: As described, 2012 (Department for Work and Pensions) Denominator (for summed Income Domain indicators): Total resident population mid-2012 (Office for National Statistics) less the prison population (Ministry of Justice).
- **Adults and children in income-based Jobseeker’s Allowance families** Numerator: As described, 2012 (Department for Work and Pensions) Denominator (for summed Income Domain indicators): Total resident population mid-2012 (Office for National Statistics) less the prison population (Ministry of Justice).
- **Adults and children in income-based Employment and Support Allowance families** Numerator: As described, 2012 (Department for Work and Pensions) Denominator (for summed Income Domain indicators): Total resident population mid-2012 (Office for National Statistics) less the prison population (Ministry of Justice).
- **Adults and children in Pension Credit (Guarantee) families** Numerator: As described, 2012 (Department for Work and Pensions) Denominator (for summed Income Domain indicators): Total resident population mid-2012 (Office for National Statistics) less the prison population (Ministry of Justice).
- **Adults and children in Working Tax Credit and Child Tax Credit families not already counted, that is those who are not in receipt of Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee) and whose equivalised income (excluding housing benefit) is below 60 per cent of the median before housing costs** Numerator: As described, 2012 (HM Revenue and Customs) Denominator (for summed Income Domain indicators): Total resident population mid-2012 (Office for National Statistics) less the prison population (Ministry of Justice).
- **Asylum seekers in England in receipt of subsistence support, accommodation support, or both** A.3. Employment Deprivation Domain
- **Claimants of Jobseeker’s Allowance (both contribution-based and income-based), women aged 18-59 and men aged 18-64** Numerator: As described, four quarters from May 2012 to February 2013 (Department for Work and Pensions) Denominator (for summed Employment Domain indicators): Working-age population, women aged 18 to 59 and men aged 18 to 64 (Office for National Statistics population estimates 2012 and 2013) less the prison population (Ministry of Justice).
- **Claimants of Employment and Support Allowance (both contribution-based and income-based), women aged 18-59 and men aged 18-64** Numerator: As described, four quarters from May 2012 to February 2013 (Department for Work and Pensions) Denominator (for summed Employment Domain indicators): Working-age population, women aged 18 to 59 and men aged 18 to 64 (Office for National Statistics population estimates 2012 and 2013) less the prison population (Ministry of Justice).
- **Claimants of Incapacity Benefit, women aged 18-59 and men aged 18-64** Numerator: As described, four quarters from May 2012 to February 2013 (Department for Work and Pensions) Denominator (for summed Employment Domain indicators): Working-age population, women aged 18 to 59 and men aged 18 to 64 (Office for National Statistics population estimates 2012 and 2013) less the prison population (Ministry of Justice).
- **Claimants of Severe Disablement Allowance, women aged 18-59 and men aged 18-64** Numerator: As described, four quarters from May 2012 to February 2013 (Department for Work and Pensions) Denominator (for summed Employment Domain indicators): Working-age population, women aged 18 to 59 and men aged 18 to 64 (Office for National Statistics population estimates 2012 and 2013) less the prison population (Ministry of Justice).
- **Claimants of Carer’s Allowance, women aged 18-59 and men aged 18-64** Numerator: As described, four quarters from May 2012 to February 2013 (Department for Work and Pensions) Denominator (for summed Employment Domain indicators): Working-age population, women aged 18 to 59 and men aged 18 to 64 (Office for National Statistics population estimates 2012 and 2013) less the prison population (Ministry of Justice).
A.4. Education Skills and Training Deprivation Domain
- **Key Stage 2 attainment** Numerator: Total score of pupils taking reading, writing and mathematics Key Stage 2 exams in maintained schools, 2010/11, 2011/12 and 2012/13 (Department for Education) Denominator: Total number of Key Stage 2 subjects taken by pupils in maintained schools, 2010/11, 2011/12 and 2012/13 (Department for Education).
- **Key Stage 4 attainment** Numerator: Total capped (best 8) score of pupils taking Key Stage 4 in maintained schools, 2010/11, 2011/12 and 2012/13 (Department for Education) Denominator: All pupils in maintained schools who took Key Stage 4 exams, 2010/11, 2011/12 and 2012/13 (Department for Education).
- **Secondary school absence** Numerator: Number of authorised and unauthorised absences from secondary school, 2010/11, 2011/12 and 2012/13 (Department for Education) Denominator: Total number of possible sessions for 2010/11, 2011/12 and 2012/13 (Department for Education).
- **Staying on in education post 16** Numerator: Young people not staying on in school or non-advanced education above age 16, 2010, 2011 and 2012 (HM Revenue and Customs) Denominator: Young people aged 15 receiving Child Benefit in 2008, 2009 and 2010 (HM Revenue and Customs).
- **Entry to higher education** Numerator: Young people aged under 21 not entering higher education, 2009/10, 2010/11, 2011/12 and 2012/13 (Higher Education Statistics Agency) Denominator: Population aged 14-17, 2009, 2010, 2011 and 2012 (Office for National Statistics population estimates) less the prison population (Ministry of Justice).
- **Adult skills** Numerator: Working-age adults with no or low qualifications, non-overlapping count with English language proficiency indicator, women aged 25 to 59 and men aged 25 to 64, 2011 (Office for National Statistics, from Census 2011) Denominator: Working-age adults, women aged 25 to 59 and men aged 25 to 64, 2011 (Census).
- **English language proficiency** Numerator: Working-age adults who cannot speak English or cannot speak English well, non-overlapping count with Adult skills indicator, women aged 25 to 59 and men aged 25 to 64, 2011 (Office for National Statistics, from Census 2011) Denominator: Working-age adults, women aged 25 to 59 and men aged 25 to 64, 2011 (Census).
### A.5. Health Deprivation and Disability Domain
- **Years of potential life lost** Numerator: Mortality data in five-year age-sex bands, for 2008, 2009, 2010, 2011 and 2012 (Office for National Statistics) Denominator: Total resident population in five-year age-sex bands, for 2008, 2009, 2010, 2011 and 2012 (Office for National Statistics population estimates) less the prison population (Ministry of Justice).
- **Comparative illness and disability ratio** Numerator: Non-overlapping counts of people in receipt of Income Support, Disability Premium, Attendance Allowance, Disability Living Allowance, Severe Disablement Allowance, Incapacity Benefit in five-year age-sex bands, 2013 (Department for Work and Pensions) Denominator: Total resident population in five-year age-sex bands, 2013 (Office for National Statistics population estimates) less the prison population (Ministry of Justice).
- **Acute morbidity** Numerator: Hospital spells starting with admission in an emergency in five-year age-sex bands, 2011/12 and 2012/13 (Health and Social Care Information Centre, Hospital Episode Statistics) Denominator: Total resident population in five-year age-sex bands, 2011/12 and 2012/13 (Office for National Statistics population estimates) less the prison population (Ministry of Justice).
- **Mood and anxiety disorders** A composite based on the rate of adults suffering from mood and anxiety disorders (source: Health and Social Care Information Centre, 2013), hospital episodes data (source: Health and Social Care Information Centre, Hospital Episode Statistics, 2011/12 and 2012/13), suicide mortality data (source: Office of National Statistics, 2008, 2009, 2010, 2011 and 2012) and health benefits data (source: Department for Work and Pensions, 2013).
### A.6. Crime Domain
- **Violence** Numerator: 18 recorded crime offence types, 2013/14 (Association of Chief Police Officers, provided by the Home Office) Denominator: Total resident population, 2013 (Office for National Statistics) less the prison population (Ministry of Justice) plus the non-resident workplace population, 2011 (Census).
- **Burglary** Numerator: 4 recorded crime offence types, 2013/14 (Association of Chief Police Officers, provided by the Home Office) Denominator: Total residential dwellings, 2011 (Census), plus non-domestic addresses (Ordnance Survey’s Address Base).
- **Theft** Numerator: 5 recorded crime offence types, 2013/14 (Association of Chief Police Officers, provided by the Home Office) Denominator: Total resident population, 2013 (Office for National Statistics) less the prison population (Ministry of Justice) plus the non-resident workplace population, 2011 (Census).
- **Criminal damage** Numerator: 8 recorded crime offence types, 2013/14 (Association of Chief Police Officers, provided by the Home Office) Denominator: Total resident population, 2013 (Office for National Statistics) less the prison population (Ministry of Justice) plus the non-resident workplace population, 2011 (Census).
### A.7. Barriers to Housing and Services Domain
- **Road distance to a post office** Population weighted mean of Output Area road distance distance score (the road distance from the populated weighted Output Area centroid to nearest Post Office), 2014 (Post Office Ltd).
- **Road distance to a primary school** Population weighted mean of Output Area road distance distance score (the road distance from the populated weighted Output Area centroid to nearest primary school), 2014 (Department for Education Edubase).
- **Road distance to general store or supermarket** Population weighted mean of Output Area road distance distance score (the road distance from the populated weighted Output Area centroid to general store or supermarket), 2014 (Ordnance Survey).
- **Road distance to a GP surgery** Population weighted mean of Output Area road distance distance score (the road distance from the populated weighted Output Area centroid to nearest GP premises), 2014 (Health and Social Care Information Centre).
- **Household overcrowding** Numerator: Overcrowded households, 2011 (Census) Denominator: Total number of households, 2011 (Census).
- **Homelessness** Numerator: Number of accepted decisions for assistance under the homelessness provisions of housing legislation, average of 2011/12, 2012/13 and 2013/14 (Department for Communities and Local Government) Denominator: Total number of households, 2011 (Census).
- **Housing affordability** Modelled estimate of households unable to afford to enter owner-occupation or the private rental market on the basis of their income, estimated primarily from the Family Resources Survey, Regulated Mortgage Survey, Land Registry house prices, and Valuation Office Agency market rents, 2012.
### A.8. Living Environment Deprivation Domain
- **Housing in poor condition** Modelled estimate of the probability that any given dwelling in the Output Area (aggregated to Lower-layer Super Output Area level) fails to meet the Decent Homes standard, estimated from the English Housing Survey, 2011.
- **Houses without central heating** Numerator: As described, 2011 (Census) Denominator: Total number of households, 2011 (Census).
- **Air quality** Modelled estimates of air quality based on the concentration of four pollutants (nitrogen dioxide, benzene, sulphur dioxide and particulates), estimated from UK Air Information Resource air quality, 2012.
- **Road traffic accidents** Numerator: Injuries to pedestrians and cyclists caused by road traffic accidents, 2011, 2012 and 2013 (Department for Transport) Denominator: Total resident population, averaged over 2011 to 2013 (Office for National Statistics) less the prison population (Ministry of Justice) plus non-resident workplace population, 2011 (Census) Appendix B. Denominators
B.1.1. The majority of the 37 indicators used in the Indices of Deprivation 2015 are expressed as rates or proportions, and thus require a numerator (for example the number of people experiencing a particular form of deprivation in an area) and a suitable denominator (for example the total number of people ‘at-risk’ of the deprivation in the same area). This Appendix details the issues involved and the data and methodology employed in the construction of estimates of the at-risk population for the various indicators.
B.2. Choosing suitable denominators
B.2.1. A denominator should represent the population at-risk of experiencing a given type of deprivation and therefore it is important to choose a denominator that relates to the numerator with which it will be combined. Certain indicators use numerators and denominators derived from the same data source, while other indicators require their numerators and denominators to be constructed from different sources. Whichever is required, it is important to try to ensure that each denominator includes only those individuals (or households, properties etc.) that are at-risk of experiencing the particular form of deprivation being measured by that indicator.
B.2.2. So, for example, in the Education, Skills and Training Deprivation Domain, the Key Stage 2 attainment indicator is constructed by deriving both the numerator (the sum of points achieved in reading, writing and mathematics by pupils living in a Lower-layer Super Output Area) and the denominator (the sum of the number of subjects taken by pupils living in a Lower-layer Super Output Area) from the National Pupil Database dataset. Similarly, for the indicators where numerators were derived from the 2011 Census, the denominators were also drawn from the Census. Deriving both numerator and denominator using a single data source rules out any systematic error that arises from datasets of different coverage or representativeness.
B.2.3. For a considerable number of indicators, however, estimates of the at-risk population need to be constructed using external data sources. This is discussed below.
B.3. Data for the denominators
B.3.1. ‘Mid-year’ population estimates at Lower-layer Super Output Area level are published by the Office for National Statistics’ Population Estimation Unit. These are a single year of age and sex mid-year estimates that are published in the years between censuses. These estimates are derived by ‘aging’ the previous Census estimates by adding in births, subtracting deaths and adjusting for migration. The most recent mid-year estimates were published in October 2014\\textsuperscript{69}, and relate to the mid-point of 2013.
B.3.2. Output Area level population denominators were used to create the four road distance indicators in the Barriers to Housing and Services Domain. These denominators use Census 2011 data, the latest year for which Output Area level data is available.
B.3.3. Data was also obtained from the Home Office on the number of prisoners per single year of age and sex for each Lower-layer Super Output Area containing a prison.
B.4. Defining the at-risk population
B.4.1. The population estimates used as denominators for many of the indicators included resident population and communal establishment population, but excluded prison population. Prisoners were not included as they are not at-risk of many forms of deprivation captured in the Indices of Deprivation. Other types of communal establishment population (for example students; persons in care establishments; children in local authority homes) are at-risk of experiencing these forms of deprivation (age/sex restrictions allowing), and so were included in the denominator. This is the same definition of at-risk populations that was adopted for previous Indices.
B.5. Age and sex profile
B.5.1. Some indicators required estimates of the total population for the denominator while others required estimates of the population of a specific age and sex. Population estimates by five-year age band and sex, and by non-standard age/sex groupings as required by particular indicators, were created by the research team from the population estimates published by the Office for National Statistics. For example, the Employment Deprivation Domain required a denominator of males aged 18 to 64 and females aged 18 to 59, while the standardised health indicators required a population denominator for each five-year age-band and sex group.
\\textsuperscript{69} This update takes account of a correction to these estimates, published in January 2015, to correctly treat foreign armed forces, see http://www.ons.gov.uk/ons/about-ons/get-involved/consultations-and-user-surveys/satisfaction-surveys/population-estimates-for-uk--england-wales-correction/index.html. Appendix C. Changes since the Indices of Deprivation 2010
C.1. Changes to the Lower-layer Super Output Area geography
C.1.1. The Indices of Deprivation 2010, 2007 and 2004 used the 2001 Lower-layer Super Output Area geography, developed for the 2001 Census.
C.1.2. The Office for National Statistics has since updated Lower-layer Super Output Area geography using population data from the 2011 Census. Only a small number of changes were made between the 2001 and 2011 versions, with modifications to the boundaries of approximately 2.5 per cent of the 2001 Lower-layer Super Output Areas.
C.1.3. The Indices of Deprivation 2015 have been produced using this 2011 version of the Lower-layer Super Output Area geography.
C.2. Domains and indicators
C.2.1. It has been possible to update almost all of the indicators in the Indices of Deprivation 2010 with little or, at most, minor changes. Figure C.1 summarises the updated, new and modified indicators for each of the domains:
- two new indicators are proposed, based on improved availability of robust data
- four modifications to indicators, due to improved data or estimation methods
- four indicators will be dropped, as these are no longer available or appropriate to include.
C.2.2. Minor changes to indicators, for example due to changes in available data, and changes to definitions are described in the text in the following sections. **Figure C.1.** Domains and indicators for the Indices of Deprivation 2015, showing changes since the Indices of Deprivation 2010
| Domain | Indicators | |---------------------------------------------|-----------------------------------------------------------------------------| | **Income Deprivation 22.5%** | Adults and children in Income Support families | | | Adults and children in income-based Jobseeker’s Allowance families | | | Adults and children in income-based Employment and Support Allowance families| | | Adults and children in Pension Credit (Guarantee) families | | | Adults and children in Child Tax Credit and Working Tax Credit families, | | | below 60% median income not already counted\*\* | | | Asylum seekers in England in receipt of subsistence support, accommodation | | | support, or both | | **Employment Deprivation 22.5%** | Claimants of Jobseeker’s Allowance, aged 18-59/64 | | | Claimants of Employment and Support Allowance, aged 18-59/64 | | | Claimants of Incapacity Benefit, aged 18-59/64 | | | Claimants of Severe Disablement Allowance, aged 18-59/64 | | | Claimants of Carer’s Allowance, aged 18-59/64 ++ | | | Participants in New Deal for under 25s | | | Participants in New Deal for 25s | | | Participants in New Deal for Lone Parents | | **Health Deprivation & Disability 13.5%** | Years of potential life lost | | | Comparative illness and disability ratio | | | Acute morbidity | | | Mood and anxiety disorders | | **Education, Skills & Training Deprivation 13.5%** | Key stage 2 attainment: average points score | | | Key stage 4 attainment: average points score | | | Secondary school absence | | | Staying on in education post 16 | | | Entry to higher education | | | **Key Stage 3 attainment** | | | Adults with no or low qualifications, aged 25-59/64 \*\* | | | English language proficiency, aged 25-59/64 ++ | | **Crime 9.3%** | Recorded crime rates for: | | | - Violence | | | - Burglary | | | - Theft | | | - Criminal damage | | **Barriers to Housing & Services 9.3%** | Road distance to: post office; primary school; general store or supermarket; GP surgery | | | Household overcrowding | | | Homelessness | | | Housing affordability\*\* | | **Living Environment Deprivation 9.3%** | Housing in poor condition \*\* | | | Houses without central heating | | | Air quality | | | Road traffic accidents |
**Key**
++ New indicators
\*\* Modified indicators
Indicators that are no longer advisable/viable
(% illustrates the weight of each domain in the Index of Multiple Deprivation)
### Changes to the Income Deprivation Domain
| Modified indicator | Adults and children in Working Tax Credit and Child Tax Credit families not already counted | |--------------------|------------------------------------------------------------------------------------------| | | Cases of Working Tax Credit where no Child Tax Credit is in payment (for single people and childless couples) are included, in addition to cases where there is also Child Tax Credit in payment. As with Child Tax Credit, ‘Working Tax Credit only’ cases are included up to the income threshold - that is those whose equivalised income (excluding housing benefits) is below 60 per cent of the median before housing costs. The change to this indicator means that the Income Deprivation Domain now includes all people receiving tax credits who are below the income threshold. |
| Changes to data and definitions(^{70}) | Income-based Employment and Support Allowance replaced Income Support paid because of an illness or disability for new claims (from October 2008). To account for this, adults and children in income-based Employment and Support Allowance families have been included in the domain in addition to adults and children in Income Support families. |
### Changes to the Employment Deprivation Domain
| New indicator | Claimants of Carer’s Allowance | |---------------|--------------------------------| | | This indicator captures adults who are involuntarily excluded from the labour market due to caring responsibilities. The indicator is a non-overlapping count of Carers Allowance claimants of working-age excluding those who receive Jobseeker’s Allowance, Employment and Support Allowance, Incapacity Benefit or Severe Disablement Allowance(^{71}). Carers Allowance is payable to people aged 16 or over who provide unpaid care for at least 35 hours a week to someone who is in receipt of disability or social care benefits(^{72}) and who are a) not in full-time education or studying for more than 21 hours a week and b) earn less than £102 a week(^{73}). |
| Changes to data and definitions | New Deal and Flexible New Deal have been replaced by the Work Programme, so the three New Deal indicators included in the Indices of Deprivation 2010(^{74}) have been removed from the domain. Participants in the Work Programme are still in receipt of |
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(^{70}) Universal Credit is replacing certain income related benefits. This will not affect the updated Indices since this change was introduced after the time point of the data used.
(^{71}) Note, not all claimants of Incapacity Benefit, Severe Disablement Allowance, contribution-based Employment and Support Allowance and contribution-based Jobseeker’s Allowance are eligible for Carer’s Allowance but it is payable to claimants of income-based Jobseeker’s Allowance and income-based Employment and Support Allowance.
(^{72}) The social care benefits comprise: Personal Independence Payment daily living component, Disability Living Allowance - the middle or highest care rate, Attendance Allowance, Constant Attendance Allowance at or above the normal maximum rate with an Industrial Injuries Disablement Benefit, or basic (full day) rate with a War Disablement Pension or Armed Forces Independence Payment.
(^{73}) These are earnings after the deduction of taxes, care costs while at work and 50 per cent of pension contributions.
(^{74}) As shown in Figure C.1. Jobseeker’s Allowance so do not need to be included separately in the domain.
There has been progressive replacement of Incapacity Benefit and Severe Disablement Allowance by contribution-based Employment and Support Allowance and income-based Employment and Support Allowance. This change has been reflected by including claimants of income-based Employment and Support Allowance as well as the contributory claimants. In addition, four quarters of data have been used rather than the previous single quarter, to be consistent with the other indicators in the domain.
From May 2012, any lone parents whose youngest child is aged 5 or over are no longer eligible for Income Support and are now eligible for Jobseeker’s Allowance. Accordingly this group is now counted in this domain if they receive Jobseeker’s Allowance.
Changes to the Education, Skills and Training Deprivation Domain
| New indicator | English language proficiency | |---------------|-----------------------------| | | This indicator captures those adults who experience barriers to learning and disadvantage in the labour market because of lack of proficiency in English. Based on Census 2011 data, this indicator measures the proportion of the working-age population who cannot speak English, or cannot speak English ‘well’, and has been combined with the adults skills indicator to provide a non-overlapping count of adults with no or low qualifications and/or lack of English language proficiency. |
| Modified indicator | Adult skills | |--------------------|--------------| | | The upper age threshold has been increased, from 54 in the Indices of Deprivation 2010, to 59 for women and 64 for men. This reflects that the majority of people aged 55 to retirement age are economically active. The upper age limit is now consistent with indicators in the Employment Deprivation Domain. |
| Changes to data and definitions | The Key Stage 3 attainment indicator included in the Indices of Deprivation 2010 has been removed from the Children and Young People sub-domain. This is because statutory tests were abolished and Key Stage 3 assessments became teacher assessment only from 2008/9. | |---------------------------------| In order to strengthen the indicators on Key Stage 2 attainment, Key Stage 4 attainment, secondary school absence and staying on in education post 16, the average of three years’ worth of data has been used (rather than the two years used previously). | | | The numerator for the entry to higher education indicator is based on four years of data. The denominator for this indicator has also been constructed from four years of data, now possible due to the availability of annually updated data (a single year was used previously). | The average points score for the Key Stage 2 attainment indicator no longer contains a science element, and there have been changes to the way the English element of Key Stage 2 has been assessed and graded.
### Changes to the Health Deprivation and Disability Domain
| Changes to data and definitions | Data on claimants of Employment Support Allowance (which replaced Incapacity Benefit and Income Support paid because of an illness or disability for new claimants from 2008) has been incorporated into the comparative illness and disability ratio indicator and the health benefits component of the mood and anxiety disorders indicator. Work Capability Assessments for Employment Support Allowance were introduced in 2008, reducing the number of people eligible for incapacity benefits. |
### Changes to the Crime Domain
| Changes to data and definitions | The Home Office periodically updates the counting rules that define what constitutes crime and the specific type of crime. Some minor updates have been made to the rules since the Indices of Deprivation 2010, but it has still been possible to replicate the indicators using the same definitions for ‘violence’, ‘burglary’, ‘theft’ and ‘criminal damage’. The number of offence categories used for each crime indicator were revised for the Indices of Deprivation 2015, in order to maximise comparability with the Indices of Deprivation 2010:
- Violence - 18 notifiable offence categories (previously 21)
- Burglary – 4 notifiable offence categories.
- Theft – 5 notifiable offence categories
- Criminal damage – 8 notifiable offence categories (previously 11)\
See Appendix H for details of the notifiable offence categories used in the Indices of Deprivation 2015. |
### Changes to the Barriers to Housing and Services Domain
| Modified indicator | **Housing affordability**\
The following changes were made to this indicator:
- broadening the measure to include inability to afford to enter the private rental market, in addition to the owner-occupied sector;
- producing the indicator at Lower-layer Super Output Area level, rather than at local authority level as was produced for the Indices of Deprivation 2010;
- using local Housing Market Areas as the reference areas (see | Appendix I for information on Housing Market Areas), to reflect commuting and migration patterns, rather than the local authorities which were the reference areas for the Indices of Deprivation 2010;
- improving the income estimation methodology
- improving the indicator reliability, by increasing the upper age cut-off from age 35 to age 40 to increase the sample size available for the statistical modelling.
The resulting indicator combines with equal weight the two underlying components: affordability of owner-occupation and affordability of private rented accommodation.
| Change to data and definitions | In order to strengthen the homelessness indicator, the average of three years' worth of data is used (instead of one year used previously). |
### Changes to the Living Environment Domain
| Modified indicator | **Housing in poor condition** |--------------------|--------------------------------------------------| | | The following changes were made to this indicator: | | | • the four components of the Decent Homes standard were modelled separately to improve accuracy; | | | • the statistical model was created at dwelling-level, rather than the Output Area level measure created previously; | | | • to reflect policy changes since the indicator was last produced, the Housing Health and Safety Rating System was used instead of the previous fitness standard. |
| Change to data and definitions | Changes to national targets on air quality mean that the particulate matter component of the air quality indicator will now be based on particles less than 2.5 micrometres in diameter (10 micrometres was used previously) | Appendix D. The shrinkage technique
D.1. Improving the reliability of small area data values using shrinkage estimation
D.1.1. The shrinkage technique is designed to deal with the problems associated with small numbers in a Lower-layer Super Output Area. In some areas – particularly where the at-risk population is small – data may be ‘unreliable’, that is more likely to be affected by sampling and other sources of error.
D.1.2. The technique of shrinkage estimation (in other words empirical Bayesian estimation) is used to ‘borrow strength’ from larger areas to avoid creating unreliable small area data. Shrinkage estimation involves moving Lower-layer Super Output Area scores towards another more robust score, often relating to a higher geographical level. All Lower-layer Super Output Area scores will move somewhat through shrinkage, but those with large standard errors (in other words the most ‘unreliable’ scores) will tend to move the most. The Lower-layer Super Output Area score may be moved towards a ‘more deprived’ or ‘less deprived’ score through shrinkage estimation. Without shrinkage, some Lower-layer Super Output Areas would have scores which do not reliably describe the deprivation in the area due to chance fluctuations from year to year.
D.1.3. It could be argued that shrinkage estimation is inappropriate for administrative data which are, in effect, a census. This is not correct. The problem exists not only where data are derived from samples but also where scans of administrative data effectively mean that an entire census of a particular group is being considered. This is because such censuses can be regarded as samples from ‘super-populations’, which one could consider to be samples in time. All the data from administrative sources and the 2011 Census are treated as samples from a super-population in this way, and the shrinkage technique was applied to indicators which use this data. The exceptions are the modelled indicators, road distance indicators and indicators supplied at local authority district level.
Selecting the larger areas from which unreliable small area data can borrow strength
D.1.4. The principle for selecting the larger area should be that the Lower-layer Super Output Areas within them share characteristics. In the current shrinkage methodology, local authority districts are used. The Lower-layer Super Output Areas within a single district share issues relating to local governance and possibly to economic sub-climates. To a certain extent, they may also share issues relating to labour market sub-climates.
D.1.5. There are various other contenders for larger areas from which unreliable small area data can borrow strength. The Government Statistical Service Methodology Advisory Committee suggested alternatives to the current local authority district geography that could be explored. Following discussion with the project Advisory Group, the Office for National Statistics Super Output Area Classification was investigated as a potential ‘larger area’ from which small area data could ‘borrow strength’. D.1.6. The impact of using clusters defined by the Super Output Area Classification as the larger areas to which Lower-layer Super Output Areas are 'shrunk' was investigated and compared with the impact of shrinkage to local authority districts. The analysis was undertaken using the Indices of Deprivation 2010, examining the impact of shrinkage using different larger areas on Lower-layer Super Output Area ranks in the Income Deprivation Domain, the Employment Deprivation Domain, and on the Key Stage 4 indicator in the Education, Skills and Training Deprivation Domain.
D.1.7. It was found that when estimates for Lower-layer Super Output Areas were shrunk to the mean score of their cluster (as defined by the Super Output Area Classification), a greater number of Lower-layer Super Output Areas changed rank than if they were shrunk to the mean score of the local authority district. Shrinkage to the mean score for their cluster also results in more Lower-layer Super Output Areas moving from 'more deprived' to 'less deprived' than in the other direction (in comparison with shrinkage to local authority districts).
D.1.8. Whichever larger area was selected, the overwhelming majority of Lower-layer Super Output Areas remained within the same decile of deprivation after shrinkage. So, for example, taking the most deprived decile of the Income Deprivation Domain, out of 3,248 Lower-layer Super Output Areas, 3,243 of them remained in the same decile after shrinkage to the district mean and 5 moved to the adjacent, less deprived decile. If shrinkage was applied to the mean of the Super Output Area Classification cluster, then 3,236 remained in the most deprived decile while 12 moved to the adjacent decile. More Lower-layer Super Output Areas moved out of the most deprived decile into a less deprived decile when shrinkage was to the mean for the Super Output Area Classification cluster than when it was to the district mean.
D.1.9. Other factors were considered in addition to the above assessment of the two options for shrinkage. The main consideration was whether Lower-layer Super Output Areas have more in common (in terms of the underlying drivers of deprivation) with other such areas in the same cluster elsewhere in England than they do with those in their own local authority district. Other considerations were that the approach used should be transparent, and whether there is a perceived advantage to containing the impact of shrinkage within a local authority district, as occurs when shrinking to the district mean.
D.1.10. Having considered the results of the investigation there was no clear evidence that shrinkage to Super Output Area Classification clusters would be preferable, and the conclusion was to continue with the approach of shrinking to local authority districts.
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75 In the Super Output Area Classification in use at the time of the 2010 Indices (based on 2001 Lower-Layer Super Output Areas), there is a hierarchy of 52 cluster subgroups nested within 20 groups and 7 supergroups. For this exploration, the clusters used for shrinkage were the 52 subgroups. The descriptions of Super Output Area Classification groups and supergroups did not sufficiently differentiate between Layer Super Output Areas according to shared characteristics to be an appropriate higher level geography to which to shrink.
76 There were fewer Lower-layer Super Output Areas at the time of the construction of the Indices of Deprivation 2010 than is the case since the 2011 Census. D.2. The shrinkage calculation
D.2.1. The actual mechanism of the shrinkage procedure is to estimate deprivation in a particular Lower-layer Super Output Area using a weighted combination of (a) data from the Lower-layer Super Output Area, and (b) data from another more robust score (in the case of the Indices, this is the local authority district score). The weight attempts to increase the efficiency of the estimation, while not increasing its bias. For example, if the Lower-layer Super Output Area score has a large standard error and the score is out of line with other Lower-layer Super Output Area scores in the local authority then the Lower-layer Super Output Area score moves towards the district score. The amount of movement depends on both the size of the standard error and the amount of heterogeneity amongst the Lower-layer Super Output Areas in a local authority district.
D.2.2. The ‘shrunk’ estimate of a Lower-layer Super Output Area level proportion (or ratio) is a weighted average of the two ‘raw’ proportions for the Lower-layer Super Output Area and for the corresponding District. The weights used are determined by the relative magnitudes of within-Lower-layer Super Output Area and between-Lower-layer Super Output Area variability.
If the rate for a particular indicator in Lower-layer Super Output Area j is ( r_j ) events out of a population of ( n_j ), the empirical logit for each Lower-layer Super Output Area is:
\[ m_j = \\log \\left[ \\frac{(r_j + 0.5)}{(n_j - r_j + 0.5)} \\right] \]
whose estimated standard error ( s_j ) is the square root of:
[ s_j^2 = \\frac{(n_j + 1)(n_j + 2)}{n_j(r_j + 1)(n_j - r_j + 1)} ]
The corresponding counts ( r ) out of ( n ) for the district in which Lower-layer Super Output Area j lies gives the district-level logit:
\[ M = \\log \\left[ \\frac{(r + 0.5)}{(n - r + 0.5)} \\right] \]
The ‘shrunk’ Lower-layer Super Output Area level logit is then the weighted average:
[ m_j^\* = w_j m_j + (1 - w_j) M ]
where ( w_j ) is the weight given to the ‘raw’ Lower-layer Super Output Area-j data and ((1-w_j)) the weight given to the overall rate for the district. The formula used to determine ( w_j ) is:
[ w_j = \\frac{1/s_j^2}{1/s_j^2 + 1/t^2} ] where $t^2$ is the inter-Lower-layer Super Output Area variance for the $k$ Lower-layer Super Output Areas in the district, calculated as:
$$t^2 = \\frac{1}{k-1} \\sum\_{j=1}^{k} (m_j - M)^2$$
D.2.3. Thus large Lower-layer Super Output Areas, where precision $1/s^2_j$ is relatively large, have weight $w_j$ close to 1 and so shrinkage has little effect. The shrinkage effect is greatest for small Lower-layer Super Output Areas in relatively homogeneous districts.
The final step is to back-transform the shrunk logit $m_j^\*$ using the ‘anti-logit’, to obtain the shrunk Lower-layer Super Output Area level proportion for each Lower-layer Super Output Area:
$$z_j = \\frac{\\exp(m_j^*)}{1 + \\exp(m_j^*)}$$ Appendix E. Factor analysis
E.1. Combining different types of indicator using factor analysis
E.1.1. In a number of the domains, factor analysis is used as a method for combining indicators, by finding appropriate weights for combining indicators into a single score based on the inter-correlations between all the indicators.(^{77})
E.1.2. Factor analysis is only used in domains where ‘latent variables’ are hypothesised to exist and where the indicator variables are ‘effect indicators’, i.e. indicators that are influenced by the latent variable. In practice, the technique is applied to three domains: the Children and Young People sub-domain of the Education, Skills and Training Deprivation Domain, the Health Deprivation and Disability Domain, and the Crime Domain.
E.1.3. There are many candidates in terms of types of factor analysis. Two of the main contenders are maximum likelihood factor analysis (as used in the current and previous versions of the Indices of Deprivation) and Principal Components Analysis. The distinction between maximum likelihood factor analysis and Principal Components Analysis is a technical one. In brief, the assumptions underpinning Principal Components Analysis are that the indicators going into the analysis are perfectly reliable and measured without error. Maximum likelihood factor analysis requires no such assumption.
E.1.4. It is not the aim of this analysis to reduce a large number of variables into a number of theoretically significant factors as is usual in much social science use of factor analysis. The indicators within a domain have been chosen because they are held to measure a single area-deprivation factor. The analysis therefore involves exploring a one-common factor model against the possibility of there being more than one meaningful factor. If a meaningful second common factor is found it would suggest the need for a new domain or the removal of variables. This possibility can be examined through standard tests and criteria, such as examination of Eigen values. No meaningful second factors (in other words second factors that measured deprivation) emerged in any of the domains.
E.2. The process for combining indicators using factor analysis
E.2.1. The process of combining indicators using factor analysis comprised three stages:
1. All indicators were converted to the standard normal distribution (following shrinkage, where appropriate).
2. The standardised scores were factor analysed (using the Maximum Likelihood method), deriving a set of weights.
3. The indicators were then combined using these weights.
(^{77}) See Noble et al. 2004 Annex F for a full account of the Factor Analysis technique applied. Appendix F. Exponential transformation
F.1. Using exponential transformation to prepare the domains for combination
F.1.1. In order to combine the domains into an overall Index of Multiple Deprivation, the domain scores first need to be standardised. Any standardisation and transformation should meet the following criteria:
- **Standard distribution.** It must ensure that each domain has a common distribution, so that domains can be combined, without one domain dominating due to a much larger distribution.
- **Cancellation.** It must have an appropriate degree of ‘cancellation’ built into it (discussed below)
- **Identify deprived areas.** It must facilitate the easy identification of the most deprived Lower-layer Super Output Areas.
- **Scale independent.** It must not be scale dependent (in other words confuse population size with level of deprivation).
F.1.2. The standardisation and transformation used in the Indices of Deprivation 2015 involves each of the domain scores being ranked, and then the ranks are transformed to an exponential distribution. The exponential distribution has a number of properties that satisfy the criteria above, most importantly that it enables control over cancellation and it helps identify the most deprived Lower-layer Super Output Areas.
**Standard distribution**
F.1.3. The exponential distribution transforms each domain so that they each have a common distribution, the same range and identical maximum / minimum values. The process starts by ranking the scores in each domain to standardise the domain scores (from 1 for the least deprived, to 32,844 for the most deprived), before applying the exponential transformation procedure to create a standardised domain score ranging from 0 (least deprived) to 100 (most deprived).
**Cancellation**
F.1.4. The exponential transformation procedure gives control over the extent to which lack of deprivation in one domain cancels or compensates for deprivation in another domain. It allows precise regulation, although not elimination, of these cancellation effects. The scaling constant (23) used produces roughly 10 per cent cancellation. This means that in the extreme case, a Lower-layer Super Output Area which was ranked most deprived on one domain but least deprived on another would overall be ranked at the 90th percentile in terms of deprivation (if the two domains were equally weighted). This compares to the 50th percentile if the untransformed ranks or a normal distribution had been used instead. For example a Lower-layer Super Output Area that ranked most deprived in terms of the Income Deprivation Domain but was ranked least deprived on the Barriers to Services Domain would still be at the 90th percentile (top 10 per cent) if these two domains were combined with equal weights. Identify deprived areas
F.1.5. The exponential transformation effectively spreads out that part of the distribution in which there is most interest - that is the 'tail' which contains the most deprived Lower-layer Super Output Areas in each domain. The scaling constant ensures that the most deprived 10 per cent of Lower-layer Super Output Areas cover 50 per cent of the distribution of scores (in other words, scores between 50 and 100 after exponential transformation).
Scale independent
F.1.6. The transformation is not affected by the size of the Lower-layer Super Output Area’s population.
F.2. The exponential transformation calculation
F.2.1. The transformation used is as follows:
For any Lower-layer Super Output Area, denote its rank on the domain R, scaled to the range [0,1]. R=1/N for the least deprived and R=N/N (in other words R=1) for the most deprived, where N=the number of Lower-layer Super Output Areas in England.
The transformed domain score X is given by:
[ X = -23 \\ln \\left( 1 - R \\left( 1 - \\exp^{-100/23} \\right) \\right) ]
where 'ln' denotes natural logarithm and 'exp' the exponential or antilog transformation
F.2.2. Figure F.1 illustrates the effect of the exponential distribution using the Income Deprivation Domain as an example. The first figure shows the distribution of the Income Deprivation scores, in other words the percentage of income-deprived people in each area. The second figure shows the exponentially transformed domain scores, which range from 0 to 100. The 10 per cent most deprived Lower-layer Super Output Areas (numbering 3,248) have an exponentially transformed score between 50 and 100. The remaining 90 per cent have an exponentially transformed domain score between 0 and 50. Figure F.1. Distribution of Indices of Deprivation 2015 Income deprivation domain, before and after exponential transformation has been applied. Appendix G. Weighting the domains
G.1. Weighting the domains to create an overall Index of Multiple Deprivation
G.1.1. Combining the different domains into an overall index always involves weighting the domains, whether the weights are set explicitly or not. Greater weight on a specific domain gives greater importance to that domain in the overall index. Weights may be set explicitly, as they were in the Indices of Deprivation 2000 and subsequent updates. If domain scores were simply added together (after standardisation), this explicitly gives each domain an equal weight. Conversely, if domains are not standardised to lie on the same scale or distribution, then weights are set implicitly by the domain distributions.
G.1.2. In the final analysis there is no ultimate method by which to measure multiple deprivation, as it is a combination of individual deprivations measured in the component domains. However, the choice of weights is not arbitrary; for the Indices of Deprivation 2000 and subsequent updates, the aim was that the weights should be explicit and based on clear criteria:
- Income and Employment Domains should carry more weight than the other domains. This is supported by research and the wider academic literature, for example the work of Townsend. Accordingly, the Income and Employment Domains have been given the highest weights, accounting for 45 per cent between them of the final domain weights in Indices of Deprivation 2015.
- Domains with the most robust indicators should be given the greater weights. Only those indicators which are sufficiently robust are included within the Indices. In addition, all the indicators meet specific criteria for being included: they are ‘domain specific’ and measure major features of deprivation in that domain, are up-to-date, are capable of being updated on a regular basis, and are available across England at a small area level. The relative robustness of the indicators was gauged by extensive and detailed quality assurance testing of the data which also drew on extensive experience of working with such data.
G.1.3. During the consultation for the Indices of Deprivation 2000 and each of the subsequent English Indices of Deprivation, there has been a great deal of support for the weights chosen. Subsequent assessment of potential weights based on empirical methodologies (see below) also supports the weights used for Indices of Deprivation 2010.
G.1.4. Assessment of potential weights based on empirical methods showed consistent results. Analysis commissioned from Dibben et al.(^7) explored three alternative empirical methods for setting domain weights, rather than the theoretical basis outlined above:
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(^7) Dibben, C., Atherton, I., Cox, M., Watson, V., Ryan, M. and Sutton, M. (2007) Investigating the Impact of Changing the Weights that Underpin the Index of Multiple Deprivation 2004, London: Communities and Local Government. • Survey approach – How does living in the conditions measured by each domain affect an individual’s chance of being socially excluded? This used data from the Millennium Poverty and Social Exclusion Survey to examine the contributions of different domains to a social well-being measure closely related to social exclusion.
• Revealed preference approach – How does the state divide up the ‘public purse’ between different policies aimed at reducing the proportion of the population affected by each of the domains of deprivation? This analysis allocated departmental and local government spend between each of the domains.
• Discrete Choice Experiment – Given a choice between individuals living in these different conditions, who is felt to be most in need of support from the government? The experiment surveyed 1,000 households, asking respondents to choose between supporting individuals with different types of deprivation; these responses were used to derive empirical weights for the domains.
G.1.5. There was close overall agreement between the three empirical methods for deriving domain weights, and the actual domain weights, with the research recommending a single change to the weights – switching the weights of the Employment Domain (from 22.5 per cent to 13.5 per cent) and Health and Disability Deprivation Domain (from 13.5 per cent to 22.5 per cent) domains. This change makes little difference to the overall Index distribution, with a very high correlation between the original and revised indices.
G.1.6. With reference to these research findings, the use of these weights was revisited in the most recent consultations preceding the release of the Indices of Deprivation 200779 and Indices of Deprivation 201080. Both consultations found 89 per cent of respondents were in favour of keeping the weights the same. Furthermore, the survey of users in July 2014 did not reveal significant support for moving to new weights. In light of the very high level of user support, the weights used in the Indices of Deprivation 2015 remain as used in the Indices of Deprivation 2010.
79 Department for Communities and Local Government (2007) Updating the English Indices of Deprivation 2004: Stage Two ‘Blueprint’ Consultation Report – Summary of Responses. http://webarchive.nationalarchives.gov.uk/20120919132719/http://www.communities.gov.uk/publications/communities/indicesdeprivationresponses
80 Department for Communities and Local Government (2011) English Indices of Deprivation consultation: summary of responses. https://www.gov.uk/government/consultations/english-indices-of-deprivation. Appendix H. Categories of recorded crime
H.1.1. This Appendix sets out the categories of recorded crime used for the Crime Domain indicators. See Chapter 4 for details of the domain and indicators.
Violence
| Offence code | Offence name | |--------------|-----------------------------------------------------------------------------| | 1 | Murder | | 4.1 | Manslaughter | | 4.2 | Infanticide | | 2 | Attempted murder | | 37/1 | Causing Death by Aggravated Vehicle Taking | | 5D | Assault with intent to cause serious harm | | 5E | Endangering Life | | 8N | Assault with injury | | 8P | Racially or Religiously Aggravated Assault with Injury | | 8L | Harassment | | 8M | Racially or Religiously Aggravated Harassment | | 9A | Public Fear Alarm or Distress | | 9B | Racially or Religiously Aggravated Public Fear, Alarm or Distress | | 105A | Assault without Injury | | 105B | Racially or religiously Aggravated Assault without Injury | | 34A | Robbery of Business Property | | 34B | Robbery of Personal Property | | 62A | Violent disorder |
Burglary
| Offence code | Offence name | |--------------|-----------------------------------------------------------------------------| | 28A/B/C/D | Burglary in a dwelling | | 29 | Aggravated Burglary in a dwelling | | 30A/B | Burglary in a building other than a dwelling | | 31 | Aggravated Burglary in a building other than a dwelling | Theft
| Offence code | Offence name | |--------------|--------------------------------------------------| | 37/2 | Aggravated Vehicle Taking | | 39 | Theft from the Person | | 45 | Theft from a Motor Vehicle | | 48 | Theft or Unauthorised Taking of Motor Vehicle | | 126 | Interfering with a motor vehicle |
Criminal damage
| Offence code | Offence name | |--------------|--------------------------------------------------| | 56A | Arson endangering life | | 56B | Arson not endangering life | | 58A | Criminal Damage to a dwelling | | 58B | Criminal Damage to a building other than a dwelling| | 58C | Criminal Damage to a vehicle | | 58D | Other Criminal Damage | | 58J | Racially or Religiously Aggravated Criminal Damage| | 59 | Threat or possession with intent to commit Criminal Damage | Appendix I. Housing Market Area geography
I.1.1. Figure I.1 shows the Housing Market Area geography across Great Britain. Lower-tier Housing Market Areas, shown with black boundaries, have been used in producing the indicator of housing affordability. The resulting indicator is produced at Lower-layer Super Output Area level.
I.1.2. Work to determine a geography for Housing Market Areas was carried out by Heriot-Watt University and the Universities of Manchester, Newcastle and Sheffield. The research was published by the Department of Communities and Local Government in November 2010(^81). The research sought to identify the optimal areas within which planning for housing should be carried out, since housing market dynamics and population changes do not respect administrative boundaries such as for local authorities.
I.1.3. The resulting Housing Market Area geography took into account commuting and migration patterns using 2001 Census data, and the extent to which areas were ‘self-contained’(^82):
- Upper-tier Housing Market Areas, defined by a high level of commuting self-containment.
- Lower-tier Housing Market Areas (277 areas in England). The upper-tier Housing Market Areas were further subdivided, with larger and more urban upper-tier areas with more localised housing market conditions divided according to migration patterns.
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(^81) Department for Communities and Local Government research and analysis on housing market areas [www.gov.uk/government/publications/housing-market-areas](http://www.gov.uk/government/publications/housing-market-areas) with additional details from the Centre for Urban and Regional Development Studies (CURDS) at [www.ncl.ac.uk/curds/research/defining/NHPAU.htm](http://www.ncl.ac.uk/curds/research/defining/NHPAU.htm).
(^82) That is, the extent to which people live and work in the same area, or the extent to which people move house within the same area. Figure I.1. The upper and lower-tier Housing Market Area geography
Upper-tier - purple boundaries Lower-tier - black boundaries nested within purple boundaries
Reproduced from the Geography of housing market areas: Executive summary, Department for Communities and Local Government, November 2010, p9 www.gov.uk/government/publications/housingmarket-areas Appendix J. Quality assurance of the Indices of Deprivation 2015
J.1. Level of assurance
J.1.1. The quality assurance of the Indices of Deprivation 2015 used the risk and profile matrix set out in the UK Statistics Authority Administrative Data Quality Assurance Toolkit(^{83}), summarised in the table below.
| Level of risk of quality concerns | Public interest profile | |----------------------------------|-------------------------| | | Lower | Medium | Higher | | Low | Statistics of lower quality concern and lower public interest [A1] | Statistics of low quality concern and medium public interest [A1/A2] | Statistics of low quality concern and higher public interest [A1/A2] | | Medium | Statistics of medium quality concern and lower public interest [A1/A2] | Statistics of medium quality concern and medium public interest [A2] | Statistics of medium quality concern and higher public interest [A2/A3] | | High | Statistics of higher quality concern and lower public interest [A1/A2/A3] | Statistics of higher quality concern and medium public interest [A3] | Statistics of higher quality concern and higher public interest [A3] |
**Level of risk of quality concerns**
J.1.2. Our assessment for each indicator, domain and the overall Index of Multiple Deprivation is based on the criteria set out in the table below.
| Summary | • What weight does this indicator contribute to the overall Index of Multiple Deprivation?\
• Our assessment of level of risk of quality concerns: Low; Medium; High. | |---------|----------------------------------------------------------------------------------------------------------------------------------| | Operational context and data collection | • Is the indicator published (i.e. open data), in a form that could be used to create the indicator relatively straightforwardly?\
• If published as open data, is the indicator National Statistics? (i.e. of recognised quality, and with appropriate quality assurance documentation)\
• If the indicator is not published as open data, is it based on underlying datasets that are themselves used to generate National Statistics? |
(^{83}) UK Statistics Authority (2015) Administrative Data Quality Assurance Toolkit.\
http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-toolkit.pdf. | Communication with data suppliers | • Is there a single point of contact with the data supplier?\
• Have the data supplier and project team established appropriate contact points to discuss data supply and quality assurance?\
• Has sufficient quality assurance documentation been provided by the data supplier? | | Quality assurance principles, standards and checks | • Have concerns been raised by suppliers, users or reviewers over the quality of the indicator or underlying data sources?\
• If any such concerns have been raised, have these been responded to in the Indices methodology and/or documentation?\
• Do good proxy datasets exist for validating the indicator against real-world data sources? E.g. if the underlying datasets are not published, are any derivatives from the datasets available for our quality assurance validation such as data at local authority district level? |
J.1.3. Based on our assessment of the Indices inputs and outputs, we have identified:
- The domains and overall Indices of Multiple Deprivation have a low Level of risk of quality concerns. These datasets might be seen to have a high risk of quality concerns due to the number of different data collection bodies, and complex data collection processes. However these risks are mitigated by the design, data processing, and multiple independent indicators used, in developing the domains and the Index of Multiple Deprivation.
- The input indicators have a mixture of low and medium concerns over data quality. For each of the data sources used for the indicators, Appendix L sets out the main quality assurance documents available.
Public interest profile
J.1.4. Based on our assessment of the Indices inputs and outputs, we have identified the public interest in the Indices:
- Medium public interest in the overall Index of Multiple Deprivation and higher level summary measures;
- Lower / medium public interest for the domains;
- Lower public interest for the underlying indicators used in the Indices.
Overall level of assurance
J.1.5. Based on our assessment of the Indices inputs and outputs, we have determined the level of assurance required to be as follows:
- Enhanced assurance is appropriate for the overall Index of Multiple Deprivation and higher level summary measures, and a small number of specific datasets: the Crime Domain indicators, the acute morbidity indicator in the Health Deprivation and Disability Domain, and the housing affordability and housing condition modelled indicators. Additional assurance work for these indicators is outlined in Appendix J.3 below.
- Basic assurance is appropriate for the remaining indicators and domains.
J.2. Quality management actions
J.2.1. The work to produce the Indices of Deprivation has incorporated a number of actions to ensure quality, which are set out in Chapter 5. The table below lists the primary actions against the quality management actions framework set out in the UK Statistics Authority toolkit(^8^4).
| Quality management area | Actions | |-------------------------|---------| | Manage | • Design of the Indices, including quality of the input data sources; statistical techniques to improve the reliability of small area data; and communication with data suppliers and users.\
• Clear roles and responsibilities across the research team and data suppliers, and separate internal and external quality assurance checks. | | Communicate | • Review of potential data sources with data suppliers, to identify strengths and weaknesses of the data sources and data processing considered for inclusion in the Indices.\
• Regular dialogue with data suppliers and the research team.\
• Documenting quality guidelines and quality assurance for all input data sources used in the Indices (see Appendix L)\
• Description of the indicators used in the Indices, including biases and assumptions.\
• Engagement with users of the Indices of Deprivation outputs, including 250 responses to the survey on the draft proposals, 100 responses to the final consultation and over 125 attendees at workshops. | | Investigate | • Quality assurance of all data sources used as inputs in the Indices, including review of quality processes for administrative and survey data, and modelling methodologies used to develop specific indicators.\
• Quality assurance of the processing steps used to construct all indicators, sub-domains, domains, the overall Index of Multiple Deprivation, and the higher area level summaries.\
• Real world validation of the outputs against data from the previous Indices of Deprivation 2010, as well as appropriate open data sources. This included sense checking of geographic... |
(^8^4) UK Statistics Authority (2015) Administrative Data Quality Assurance Toolkit.\
[http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-toolkit.pdf](http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-toolkit.pdf). Table J.3. Quality management actions undertaken for quality assurance of the Indices of Deprivation
| Quality management area | Actions | |-------------------------|---------| | | patterns and time series trends. Ideally this validation would have used data from independent sources to those used in constructing the Indices; however in practice this was not always possible as no such separate source existed. | | | • In addition to the quality assurance carried out when constructing the domains, internal audit and external scrutiny are carried out on the complete process. These include scrutiny of the methods, processing syntax, and the constructed datasets. The internal audit was carried out on a domain-by-domain basis by a team member not involved in the construction of the domain. The external scrutiny was carried out by an external academic, to provide independent verification. |
J.3. Enhanced assurance
J.3.1. A small number of specific datasets were identified as requiring additional quality assurance: the Crime Domain indicators, the acute morbidity indicator in the Health Deprivation and Disability Domain, and the housing affordability and housing condition modelled indicators. The additional assurance work for these indicators is outlined below.
Crime Domain
J.3.2. The Crime Domain has been included since the 2004 Indices, based on indicators that use police recorded crime datasets. These datasets are currently under scrutiny in efforts to improve their quality. The Public Administration Select Committee(^{85}) and Her Majesty’s Inspectorate of Constabulary(^{86}) have identified concerns with crimes being under-recorded and/or miscategorised. The UK Statistics Authority removed the National Statistics designation from statistics based on recorded crime data in January 2014(^{87}).
J.3.3. In its final report(^{88}), Her Majesty’s Inspectorate of Constabulary concluded that up to 20 percent of crimes may be going unrecorded. The report acknowledges that there appears to be some variation in the level of under-recording between police forces, but it is not possible to give a reliable statistical measure of this variation between forces. Neither is it possible to infer how this variation applies at lower geographical levels or between more or less deprived neighbourhoods. Therefore
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(^{85}) Commons Select Committee, Crime statistics inquiry [http://www.parliament.uk/business/committees/committees-a-z/commons-select/public-administration-select-committee/inquiries/parliament-2010/crime-statistics/](http://www.parliament.uk/business/committees/committees-a-z/commons-select/public-administration-select-committee/inquiries/parliament-2010/crime-statistics/)
(^{86}) Her Majesty’s Inspectorate of Constabulary (HMIC) crime data integrity information [https://www.justiceinspectorates.gov.uk/hmic/our-work/crime-data-integrity/](https://www.justiceinspectorates.gov.uk/hmic/our-work/crime-data-integrity/)
(^{87}) UK Statistics Authority register of de-designations [http://www.statisticsauthority.gov.uk/assessment/assessment/register-of-de-designations/index.html](http://www.statisticsauthority.gov.uk/assessment/assessment/register-of-de-designations/index.html)
(^{88}) Her Majesty’s Inspectorate of Constabulary (2014), Crime-recording: making the victim count, [https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-making-the-victim-count/](https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-making-the-victim-count/) geographical adjustments cannot be made to the police recorded crime data used in the Indices to take under-recording into account.
J.3.4. However, the Indices themselves are designed to help ensure the quality of the output datasets by minimising the impact of bias and error in the input data sources:
- The Crime Domain is based on a combination of multiple crime types, which have different geographical distributions, and potentially different under-recording distributions, and which are then used to rank areas. The distribution of the Crime Domain ranks is therefore likely to be more reliable than the distribution of any one of the underlying offences.
- As the Crime Domain uses a large set of crime categories (see Appendix H), miscategorisation of crimes will often not affect the Domain. For example, ‘Assault with intent to cause serious harm’, ‘Assault with injury’ and ‘Assault without Injury’ are each included under the violence indicator; a miscategorisation between these offences will therefore have no impact on the indicator.
- The overall Index of Multiple Deprivation 2015 brings together 37 indicators of deprivation, from a wide range of data sources. As discussed in Chapter 5, due to the variety of data inputs there is little chance that an area is identified as highly deprived due to a bias in one of the component indicators; the use of multiple independent indicators increases robustness of the final outputs.
- In addition, the team has carried out enhanced quality assurance checks and processes to ensure the quality of the crime data outputs, which are described in the section below.
J.3.5. Taking into account the findings of the final report from Her Majesty’s Inspectorate of Constabulary, the data exploration undertaken by the research team, and the support from users, the Indices of Deprivation 2015 continues to use police recorded crime data for the Crime Domain as the best available source of information on crime levels at small area level.
**Additional quality checks and processes carried out on the police recorded crime datasets**
J.3.6. The individual-level geocoded recorded crime data used to construct the Crime Domain of the Indices of Deprivation 2015 was drawn primarily from the routine monthly data extracts provided by the 39 regional police forces in England to the Home Office for the purpose of administering the police.uk website. The Association of Chief Police Officers granted members of the Indices of Deprivation 2015 research team access to the raw (i.e. non-anonymised) police data within a secure police setting for the purposes of updating the Indices.
J.3.7. In addition to the quality assurance checks already performed by the Association of Chief Police Officers and the Home Office in producing the police.uk open data source, the research team performed an extensive series of checks on the geocoded police data to ensure the appropriate levels of accuracy and completeness prior to incorporation into the Crime Domain. As well as the quality checks carried out, various techniques were used to maximise the quality of the aggregate crime counts constructed from the raw geocoded crime data. J.3.8. The most important checking process carried out was to compare the Indices of Deprivation 2015 crime counts generated from the raw individual-level geocoded data, against aggregate crime counts at the Police Force-level and Community Safety Partnership-level that are supplied separately by each police force to the Home Office and which are available as open data. These checks of geocoded data against the open data, aggregate statistics were performed at the end of each major data processing phase of the Crime Domain. Primarily, these checks enabled assessment of:
- the degree to which the raw geocoded data contained the correct number of crime records (per crime type, time period and Police Force) prior to any mapping being undertaken; and
- the degree to which the geocoded data could be successfully mapped to appropriate Lower-layer Super Output Areas using the grid reference and/or postcode of offence location.
J.3.9. Where checks revealed discrepancies between the geocoded data and the open data, an enquiry was submitted to the relevant police force. Where necessary, a follow-up data request was submitted to the police force for a bespoke extract of geocoded data for the purpose of the Crime Domain. These bespoke data extracts were then incorporated into the processing phases of the Crime Domain, and the checks against open data performed again.
J.3.10. The extensive checks performed on the final geocoded data demonstrated a high level of correspondence with the publicly available open data at Police Force-level and Community Safety Partnership-level.
J.3.11. We have concluded that this data provides the best measure of crime levels at Lower-layer Super Output Area level, and is fit for purpose to use as an input data source for the Indices of Deprivation 2015.
Acute morbidity indicator in the Health Deprivation and Disability Domain
J.3.12. The acute morbidity indicator in the Health Deprivation and Disability Domain is an age and sex standardised rate of emergency admission to hospital, based on Hospital Episode Statistics provided by the Health and Social Care Information Centre. Emergency admissions are defined as cases where ‘admission is unpredictable and at short notice because of clinical need’, and all emergency admissions greater than one day in length (where discharge is not on the same date as admission) are included.
J.3.13. Some concerns by users and researchers have been raised over the possibility of practices by particular hospital trusts affecting the robustness of this indicator. As stated earlier, the use of multiple independent indicators is one means of minimising the impact of bias and error in input data sources on the Indices of Deprivation. But to further explore the possibility of bias in this input data source, we have carried out additional validation of the indicator as outlined below:
- Quality assurance material from the supplier was reviewed to identify whether there was specific coverage of this issue.
- Correlation and funnel-plot analysis at Lower-layer Super Output Area level showed that the distribution of short stay emergency admissions (of 1 day or less) is consistent with stays of all lengths. This suggests that there are no large-scale systematic differences between hospital trusts in the way that short-stay and longer-stay emergency admissions are treated.
- Strong correlations were found between the indicator and the overall Health Deprivation and Disability Domain, and between the indicator and the corresponding indicator in the Indices of Deprivation 2010. In addition, analysis of local authority data showed no surprising patterns of change between data from the Indices of Deprivation 2015 and Indices 2010.
J.3.14. Without reviewing the underlying primary data sources used to create the Hospital Episodes Statistics data, it is not possible to categorically conclude that the data accurately records the underlying level of acute morbidity need. However, based on our additional checks set out above, we have concluded that the indicator is the best available measure of acute morbidity, and is fit for purpose as an input indicator into the Indices of Deprivation 2015.
Housing affordability and housing condition modelled indicators
J.3.15. Where possible the Indices of Deprivation uses indicators based on data that provides a direct measure of the particular form of deprivation relevant to the indicator. In a small number of cases, no robust data is available to provide a direct measure, and in these cases a modelled estimate is used.
J.3.16. For two indicators, housing affordability and housing condition, synthetic estimation techniques are used to model the indicator to Lower-layer Super Output Area level. For these indicators, the data suppliers have carried out and documented additional work to quality assure the indicators:
- Each of the data sources used in the models was reviewed;
- The predictive strengths of the models were checked;
- The modelled datasets were verified at higher level against independently published sources where available;
- The predicted values were matched to larger area survey values, to ensure consistency of the modelled indicators against other available data.
J.3.17. Additional quality assurance was carried out for the housing affordability indicator:
- The methodology was based on peer reviewed methodology used to develop small area income estimates and poverty measures in Scotland.
- Two versions of the modelling were carried out and compared. A version of the indicator was constructed using the Understanding Society survey, and compared with the actual indicator which uses the Family Resources Survey.
J.3.18. Additional quality assurance was carried out for the housing condition indicator:
- Assessment of the input data sources, including measures of accuracy.
- Description and checks on the processing steps, including process maps / flow-charts showing the development of the indicator.
______________________________________________________________________
89 This approach has been taken by Her Majesty’s Inspectorate of Constabulary in their review of crime statistics discussed earlier in this section.
90 Bramley and Watkins (2013). Local Incomes and Poverty in Scotland: Developing Local and Small Area Estimates and Exploring Patterns of Income Distribution, Poverty and Deprivation http://www.improvementservice.org.uk/assets/local-incomes-poverty-scotland.pdf • Accuracies of the statistical models were estimated. • Comparison of the Indices of Deprivation 2015 housing condition indicator methodology against the methodology used in previous versions of the indicator. • Comparison against related data sources, including local stock condition surveys carried out by local authorities. • Validations and peer reviews carried out by the data supplier and other users of the data.
J.3.19. Based on this additional quality assurance, we have concluded that these indicators provide the best measures of housing affordability and housing condition at Lower-layer Super Output Area level, and are fit for purpose to use as indicators in the Indices of Deprivation 2015. Appendix K. Quality Assurance overview for data suppliers
K.1.1. This appendix sets out the overview presentation for data suppliers, used to explain the quality assurance model used for the Indices of Deprivation 2015. The overview also describes the information required from data suppliers.
Quality Assurance for the Indices of Deprivation
Overview for data suppliers
Version 1.0
Oxford Consultants for Social Inclusion (OCSI) [email protected] +44 1273 810 270 www.ocsi.co.uk @ocsi_uk
Background
- OCSI have been commissioned by DCLG to update the Indices of Deprivation, for publication in 2015
- Alongside the OCSI work, the UK Statistics Authority are assessing whether the Indices should be badged as ‘National Statistics’
- UKSA assessment will look at the datasets going into the Indices, and the QA work that has been carried out and documented on these underpinning datasets
- As part of our quality assurance, we need to work with all suppliers providing data that goes into the indices
- This slide deck forms part of our quality assurance. It outlines the process we will go through to assure ourselves and our users of the robustness of the data for use in statistical purposes Additional administrative data context
- The Indices of Deprivation use many different data sources, including administrative sources.
- Administrative data provides a readily available, rich source of information but, like other data types, is susceptible to quality issues.
- The concern is that the data has not usually been collected with statistical purposes in mind. With all administrative data there is a risk of variation in recording practices between suppliers, cases of incomplete data, incorrect data format and mis-typed data. There have even been cases of intentional misreporting, a particular concern where data is used to monitor performance.
- Principle 4 of the Code of Good Practice requires that we "adopt quality assurance procedures, including the consideration of each statistical product against users’ requirements, and of their coherence with other statistical products."
Public interest and data quality concerns
- The Indices use ~40 different data indicators sourced from multiple suppliers.
- Depending on the nature of the data & source, different levels of assurance will be appropriate.
- We have assessed the ‘maturity level’ (A1 - A3) for each data indicator and, where necessary, each practice area.
- Our assessment is that the ID2015 inputs and outputs are a mix of A1 and A2.
- Our reasoning behind each maturity classification will be set out in our final report(s).
What we need to do – high level
- Make a critical judgement about the robustness of the data for use in producing statistics.
- Inform users about the quality of our statistical outputs, including estimates of the main sources of bias and other errors.
To meet requirements, provide assurance under 4 practice areas
- Understand and report the operational context.
- Understand why and how the data is recorded and collected.
- Identify the scope for error or misreporting in the collection and recording of the data.
- Establish a common understanding about the origin of the data, its suitability for use within the statistics and the quality standards and data format expected for the statistics.
- Quality assurance the data with validation checks and by calibrating it against other sources. Review external audits and regulations.
Our assessment of the underlying data sources
Based on the UKSA exposure draft, we apply this checklist to each indicator:
- Is the indicator published (is open data)?
- If published as open data, is the indicator National Statistics?
- If not published data, are we using underlying datasets that are used to generate National Statistics?
- Is the underlying data used for payments (eg benefit systems) – i.e. likely to be higher quality?
- Is the underlying data used for performance targets (eg crime data) – i.e. risk of performance pressure?
- Is the underlying source data collated from separate sources, or single source? (ie risk of inconsistent processes across suppliers)
- If not published, are the underlying datasets (or derivatives of them eg LAD aggregates of LSOA data) available for our QA process?
- Have concerns been raised by users or reviewers over the quality of the indicator or underlying data sources? Have these been responded to in our QA? What we need from you the data supplier
- Details of the indicator development, including
- input data sources
- technical methodology
- processing steps (ideally process map).
- Details of your QA, including (as appropriate)
- assessment of data inputs
- models goodness-of-fit
- comparison against related data sources
- validation and/or peer review
- any known data quality concerns identified by you or users.
- Input datasets and syntax (as appropriate)
- for our internal review & validation processes.
Key reading
- UKSA Quality Assurance of Administrative Data Toolkit http://www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics
- Types of official statistics www.statisticsauthority.gov.uk/national-statistician/types-of-official-statistics
- Code of Practice for Official Statistics www.statisticsauthority.gov.uk/assessment/code-of-practice
- Exposure draft of UKSA Admin data assurance www.statisticsauthority.gov.uk/assessment/monitoring/administrative-data-and-official-statistics/quality-assurance-and-audit-arrangements-for-administrative-data.html
Quality Assurance for the Indices of Deprivation
Overview for data suppliers
Version 1.0
Oxford Consultants for Social Inclusion (OCSI) [email protected] +44 1273 810 270 www.ocsi.co.uk @ocsi.uk Appendix L. Quality assurance documents for input data sources
L.1.1. This Appendix lists the main quality assurance documents available for the input data sources used in the Indices of Deprivation, with web links where available. Table L.2 provides a look-up between the indicator identification code used in the table, and the proper name of the indicator.
Table L.1. Quality assurance documents available for the input data sources
| Indicator codes(s) | Document / resource name | Web link (if available) | |--------------------|--------------------------|-------------------------| | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | DWP Statistics Quality Guidelines Statement | https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/203643/dwp-statistics-Quality_Guidelines_statement_final.pdf | | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | Statement of the administrative sources of DWP statistics | https://www.gov.uk/government/statistics/statement-of-the-administrative-sources-of-dwp-statistics | | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | Confidentiality and access policy for DWP statistics | https://www.gov.uk/government/statistics/confidentiality-and-access-policy-for-dwp-statistics | | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | Policies and statements related to DWP statistical summaries (including Quality statement and Methodology statement) | https://www.gov.uk/government/statistics/dwp-statistical-summary-policies-and-statements | | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | Policies and statements related to DWP abstract of statistics | https://www.gov.uk/government/statistics/dwp-abstract-of-statistics-policies-and-statements | | ID1, ID2, ID3, ID4, ID5, ID7, ID8, ID9, ID10, ID11, ID19, ID24 | Fraud and error in benefits recent guidelines/QA/Tech annexe | https://www.gov.uk/government/publications/fraud-and-error-in-the-benefit-system-supporting-documents-for-statistical-reports | | ID 6 | Home Office statistics statement of compliance with code of practice for official | https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/341674/ho-compliance-state-aug14.pdf |
91 All web references were downloaded 18th August 2015. | Indicator codes(s) | Document / resource name | Web link (if available) | |--------------------|--------------------------|-------------------------| | ID 6 | Home Office statement of compliance – release practices | \[https://www.gov.uk/government/uploads/system/uploads/attachment_d data/file/309011/ho-release-comp-state-14.pdf\](https://www.gov.uk/government/uploads/system/uploads/attachment_d data/file/309011/ho-release-comp-state-14.pdf) | | ID 6 | Home Office use of administrative sources for statistical purposes | [https://www.gov.uk/government/publications/home-office-use-of-administrative-sources-for-statistical-purposes](https://www.gov.uk/government/publications/home-office-use-of-administrative-sources-for-statistical-purposes) | | ID1, ID2, ID3, ID4, ID5, ID15 | Quality reports for HMRC statistics | [https://www.gov.uk/government/collections/hmrc-quality-reports-statistics](https://www.gov.uk/government/collections/hmrc-quality-reports-statistics) | | ID1, ID2, ID3, ID4, ID5, ID15 | HMRC statement of administrative sources | [https://www.gov.uk/government/statistics/hmrc-statistics-statement-of-administrative-sources](https://www.gov.uk/government/statistics/hmrc-statistics-statement-of-administrative-sources) | | ID1, ID2, ID3, ID4, ID5, ID15 | HMRC policy on revisions | \[https://www.gov.uk/government/uploads/system/uploads/attachment_d ata/file/251990/cop-revisions.pdf\](https://www.gov.uk/government/uploads/system/uploads/attachment_d ata/file/251990/cop-revisions.pdf) | | Denominators | Census quality assurance of 2011 population estimates | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-assurance/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-assurance/index.html) | | ID16 | Higher Education Statistics Agency (HESA) statement of administrative sources and quality assurance | [https://www.hesa.ac.uk/sads](https://www.hesa.ac.uk/sads) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census quality assurance by Local Authority | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-assurance/local-authority-quality-assurance/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-assurance/local-authority-quality-assurance/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census response and imputation rates | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/response-and-imputation-rates/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/response-and-imputation-rates/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census assessing accuracy of responses | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/assessing-accuracy-of-answers/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/assessing-accuracy-of-answers/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census data capture and cleaning | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/data-capture-coding-and-cleaning/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-measures/data-capture-coding-and-cleaning/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census confidence intervals | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-] | Indicator codes(s) | Document / resource name | Web link (if available) | |-------------------|--------------------------|-------------------------| | ID17, ID18, ID23, ID25, ID34, ID37 | Census quality notes and clarifications | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-notes-and-clarifications/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/2011-census-user-guide/quality-and-methods/quality/quality-notes-and-clarifications/index.html) | | Denominators | Quality and methodology information for population indicators | [http://www.ons.gov.uk/ons/guide-method/method-quality/quality/quality-information/population/index.html](http://www.ons.gov.uk/ons/guide-method/method-quality/quality/quality-information/population/index.html) | | Denominators | Quality measures for population estimates and uncertainty project for Local Authority Mid-year Population Estimates | [http://www.ons.gov.uk/ons/guide-method/method-quality/imps/latest-news/uncertainty-in-la-mypes/index.html](http://www.ons.gov.uk/ons/guide-method/method-quality/imps/latest-news/uncertainty-in-la-mypes/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | 2011 census issues and corrections | [http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/census-products--issues-and-corrections/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/census-data/census-products--issues-and-corrections/index.html) | | ID17, ID18, ID23, ID25, ID34, ID37 | Census independent review of coverage assessment and quality assurance | [http://www.ons.gov.uk/ons/guide-method/census/2011/how-our-census-works/how-we-planned-the-2011-census/independent-assessments/independent-review-of-coverage-assessment--adjustment-and-quality-assurance/index.html](http://www.ons.gov.uk/ons/guide-method/census/2011/how-our-census-works/how-we-planned-the-2011-census/independent-assessments/independent-review-of-coverage-assessment--adjustment-and-quality-assurance/index.html) | | ID20, ID21, ID22, ID33 | The HES processing cycle and data quality | [http://www.hscic.gov.uk/media/1366/The-HES-processing-cycle-and-HES-data-quality/pdf/](http://www.hscic.gov.uk/media/1366/The-HES-processing-cycle-and-HES-data-quality/pdf/) | | ID20, ID21, ID22, ID33 | Data quality and checks performed on SUS and HES data | [http://www.hscic.gov.uk/media/13655/Data-quality-checks-performed-on-SUS-and-HES-data/pdf/Data_quality_checks_performed_on_SUS_and_HES_data.pdf](http://www.hscic.gov.uk/media/13655/Data-quality-checks-performed-on-SUS-and-HES-data/pdf/Data_quality_checks_performed_on_SUS_and_HES_data.pdf) | | ID20, ID21, ID22, ID33 | HSCIC data quality | [http://www.hscic.gov.uk/dq](http://www.hscic.gov.uk/dq) | | ID20, ID21, ID22, ID33 | HSCIC 2014 data quality report | [http://www.hscic.gov.uk/catalogue/PUB15783](http://www.hscic.gov.uk/catalogue/PUB15783) | | ID20, ID21, ID22, ID33 | HSCIC 2013 second annual data quality report | [http://www.hscic.gov.uk/catalogue/PUB11530](http://www.hscic.gov.uk/catalogue/PUB11530) | | ID20, ID21, ID22, ID33 | HSCIC 2012 first annual data quality report | [http://www.hscic.gov.uk/catalogue/PUB08687](http://www.hscic.gov.uk/catalogue/PUB08687) | | ID20, ID21, ID22, ID33 | HSCIC Secondary Use Services (SUS) data quality dashboards | [http://www.hscic.gov.uk/article/1923/SUS-Data-Quality-Dashboards](http://www.hscic.gov.uk/article/1923/SUS-Data-Quality-Dashboards) | | Indicator codes(s) | Document / resource name | Web link (if available) | |-------------------|--------------------------|-------------------------| | ID21 | 2011 GP attribution data quality | [http://www.hscic.gov.uk/catalogue/PUB05054/attr-data-gp-reg-pop-ons-esti-2011-qual.pdf](http://www.hscic.gov.uk/catalogue/PUB05054/attr-data-gp-reg-pop-ons-esti-2011-qual.pdf) | | ID12, ID13, ID14, ID32 | Standards for official statistics published by DfE | [https://www.gov.uk/government/publications/standards-for-official-statistics-published-by-the-department-for-education](https://www.gov.uk/government/publications/standards-for-official-statistics-published-by-the-department-for-education) | | ID26, ID27, ID28, ID29 | UK Statistics Authority 2014 report on assessment of compliance to code of practice for crime statistics | [http://www.ons.gov.uk/ons/rel/crime-stats/crime-statistics/period-ending-september-2013/sty-uksa-assessment.html](http://www.ons.gov.uk/ons/rel/crime-stats/crime-statistics/period-ending-september-2013/sty-uksa-assessment.html) | | ID26, ID27, ID28, ID29 | UK Statistics Authority crime statistics assessment reports (links to 2014 and 2011 reports) | [http://www.statisticsauthority.gov.uk/assessment/assessment/assessment-reports/](http://www.statisticsauthority.gov.uk/assessment/assessment/assessment-reports/) | | ID26, ID27, ID28, ID29 | Action plans to address requirements made by UK Statistics Authority on crime statistics | [http://www.ons.gov.uk/ons/guide-method/method-quality/specific/crime-statistics-methodology/uk-statistics-authority-assessment/index.html](http://www.ons.gov.uk/ons/guide-method/method-quality/specific/crime-statistics-methodology/uk-statistics-authority-assessment/index.html) | | ID26, ID27, ID28, ID29 | HMIC crime data integrity | [https://www.justiceinspectorates.gov.uk/hmic/our-work/crime-data-integrity/](https://www.justiceinspectorates.gov.uk/hmic/our-work/crime-data-integrity/) | | ID26, ID27, ID28, ID29 | HMIC report ‘Crime recoding: making the victim count’ | [https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-making-the-victim-count/](https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-making-the-victim-count/) | | ID26, ID27, ID28, ID29 | HMIC interim report ‘Crime recording: a matter of fact’ | [https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-a-matter-of-fact-interim-report/](https://www.justiceinspectorates.gov.uk/hmic/publication/crime-recording-a-matter-of-fact-interim-report/) | | ID26, ID27, ID28, ID29 | HMIC 2009 report ‘Crime counts: A review of data quality for offences of the most serious violence’ | [https://www.justiceinspectorates.gov.uk/hmic/publication/crime-counts/](https://www.justiceinspectorates.gov.uk/hmic/publication/crime-counts/) | | ID26, ID27, ID28, ID29 | HMIC 2012 report ‘The crime scene: a review of police crime and incident reports’ - also links to specific force reports | [https://www.justiceinspectorates.gov.uk/hmic/publication/review-police-crime-incident-reports-20120125/](https://www.justiceinspectorates.gov.uk/hmic/publication/review-police-crime-incident-reports-20120125/) | | ID26, ID27, ID28, ID29 | Crime and Justice data - Quality and Methodology Information papers | [http://www.ons.gov.uk/ons/guide-method/method-quality/quality/quality-information/crime-and-justice/index.html](http://www.ons.gov.uk/ons/guide-method/method-quality/quality/quality-information/crime-and-justice/index.html) | | Indicator codes(s) | Document / resource name | Web link (if available) | |--------------------|--------------------------|-------------------------| | ID35 | DCLG - Statement of administrative sources | [https://www.gov.uk/government/publications/statement-of-administrative-sources-for-statistical-purposes](https://www.gov.uk/government/publications/statement-of-administrative-sources-for-statistical-purposes) | | ID35 | DCLG - Revisions policy | [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7616/1466387.pdf](https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/7616/1466387.pdf) | | ID35 | DCLG - quality guidelines | [https://www.gov.uk/government/publications/statistical-notice-dclg-quality-guidelines](https://www.gov.uk/government/publications/statistical-notice-dclg-quality-guidelines) | | ID35 | Homelessness statistical release - Jan to March 2014 - with note on data quality | [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/339003/Statutory_Homelessness_1st_Quarter_Jan\_-\_March_2014_England_20140729.pdf](https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/339003/Statutory_Homelessness_1st_Quarter_Jan_-_March_2014_England_20140729.pdf) | | ID35 | DCLG open data strategy 2012-2014 - includes details on data quality | [http://data.gov.uk/sites/default/files/DCLG%20Open%20Data%20Strategy_10.pdf](http://data.gov.uk/sites/default/files/DCLG%20Open%20Data%20Strategy_10.pdf) | | ID31 | Ordnance survey data positional accuracy improvement (PAI) programme | [http://www.ordnancesurvey.co.uk/business-and-government/help-and-support/navigation-technology/pai.html](http://www.ordnancesurvey.co.uk/business-and-government/help-and-support/navigation-technology/pai.html) | | ID40 | Road accident and safety statistics guidance | [https://www.gov.uk/government/publications/road-accidents-and-safety-statistics-guidance](https://www.gov.uk/government/publications/road-accidents-and-safety-statistics-guidance) | | ID40 | Guide to road traffic accident statistics and data sources (including data quality) | [https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/259012/rrcgb-quality-statement.pdf](https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/259012/rrcgb-quality-statement.pdf) | | ID40 | DfT statistics - corporate information | [https://www.gov.uk/government/organisations/department-for-transport/about/statistics#corporate-information](https://www.gov.uk/government/organisations/department-for-transport/about/statistics#corporate-information) | | ID40 | DfT - statement on data quality | [https://www.gov.uk/government/publications/standards-for-official-statistics-published-by-the-department-for-transport](https://www.gov.uk/government/publications/standards-for-official-statistics-published-by-the-department-for-transport) | | ID40 | DfT - statement of administrative sources | [https://www.gov.uk/government/publications/statement-of-administrative-sources-for-official-statistics-published-by-the-department-for-transport](https://www.gov.uk/government/publications/statement-of-administrative-sources-for-official-statistics-published-by-the-department-for-transport) | | Indicator code | Indicator name | |----------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | ID1 | Adults and children in Income Support families | | ID2 | Adults and children in income-based Jobseeker’s Allowance families | | ID3 | Adults and children in income-based Employment and Support Allowance families | | ID4 | Adults and children in Pension Credit (Guarantee) families | | ID5 | Adults and children in Working Tax Credit and Child Tax Credit families not already counted, that is those who are not in receipt of Income Support, income-based Jobseeker’s Allowance, income-based Employment and Support Allowance or Pension Credit (Guarantee) and whose equivalised income (excluding housing benefit) is below 60 per cent of the median before housing costs | | ID6 | Asylum seekers in England in receipt of subsistence support, accommodation support, or both | | ID7 | Claimants of Jobseeker’s Allowance (both contribution-based and income-based), women aged 18-59 and men aged 18-64 | | ID8 | Claimants of Employment and Support Allowance (both contribution-based and income-based), women aged 18-59 and men aged 18-64 | | ID9 | Claimants of Incapacity Benefit, women aged 18-59 and men aged 18-64 | | ID10 | Claimants of Severe Disablement Allowance, women aged 18-59 and men aged 18-64 | | ID11 | Claimants of Carer’s Allowance, women aged 18-59 and men aged 18-64 | | ID12 | Key Stage 2 attainment: average points score | | ID13 | Key Stage 4 attainment: average points score | | ID14 | Secondary school absence | | ID15 | Staying on in education post 16 | | ID16 | Entry to higher education | | ID17 | Adults with no or low qualifications, women aged 25-59 and men aged 25-64 | | ID18 | English language proficiency, women aged 25-59 and men aged 25-64 | | ID19 | Comparative Illness and Disability Ratio | | ID20 | Acute morbidity | | ID21 | Mood and anxiety disorders: Prescription data | | ID22 | Mood and anxiety disorders: Hospital episodes data | | ID23 | Mood and anxiety disorders: Suicide mortality data | | ID24 | Mood and anxiety disorders: Employment and Support Allowance and Incapacity Benefit for mental health reasons | | ID25 | Years of potential life lost | | ID26 | Recorded crime rate for Violence | | ID27 | Recorded crime rate for Criminal Damage | | ID28 | Recorded crime rate for Theft | | ID29 | Recorded crime rate for Theft | | ID30 | Road distance to a post office | | ID31 | Road distance to general store or supermarket | | ID32 | Road distance to a primary school | | ID33 | Road distance to a GP surgery | | ID34 | Household overcrowding | | ID35 | Homelessness | | ID | Description | |-----|----------------------------------| | ID36| Housing affordability | | ID37| Houses without central heating | | ID38| Housing in poor condition | | ID39| Air quality | | ID40| Road traffic accidents | Appendix M. Issues and potential indicators explored
M.1. Introduction
M.1.1. During the update of the Indices of Deprivation, a wide range of issues and indicators were explored in order to understand the potential to enhance the Indices. Where changes have been made to the Indices as a result, primarily new indicators and enhancements to existing indicators, these have been detailed in Chapter 4 and Appendix C.
M.1.2. This Appendix outlines those issues and potential indicators that were examined, but that did not result in changes to the Indices. The first section deals with issues relating to indicators that are included in the Indices of Deprivation 2015 but which did not result in changes to those indicators. The second section describes a number of indicators which were explored but were found not suitable for inclusion in this update.
M.2. Issues by domain
Income Deprivation Domain
M.2.1. Seasonal variation in benefits. Seasonal variation in benefit claims is taken into account in the Employment Deprivation Domain, but not the Income Deprivation Domain. While it may now be possible using data from the Department for Work and Pensions to capture claimants at more than one time point in the year, it was unfortunately not practicable to obtain corresponding data for this update of the Indices from HM Revenue & Customs.
M.2.2. Adjusting benefits/tax credit data for geographical variations in take-up. If benefits or tax credit take-up varies geographically, it would be desirable to adjust the administrative data in the Income Deprivation Domain to take that into account. Two recent reports on take-up have been published, one in respect of income-related benefits and published by the Department for Work and Pensions and another in respect of tax credits published by HM Revenue & Customs. Both reports have sections on geographical variation of take-up.
M.2.3. In respect of the Department for Work and Pensions’ income related benefits there is a clear injunction in the report against reliance on regional estimates of take-up: “Due to the complexities of the methodology it is not possible to produce reliable estimates at geographies below Great Britain so when using the figures it should
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92 Department for Work and Pensions (2012). Income Related Benefits: Estimates of Take-up in 2009-10. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/222915/tkup_full_report_0910.pdf
93 HM Revenue & Customs (2013). Child Benefit, Child Tax Credit and Working Tax Credit Take-up rates. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/265488/cwtcchb-take-up2011-12_fin.pdf always be considered that effects seen are an amalgamation of changes throughout the country rather than one geographical area” (paragraph 1.9.5, p 9).
M.2.4. As regards adjusting tax credit data, the take-up estimates are given by HM Revenue & Customs as a range and in almost all cases the ranges overlap between regions. There is also no indication of how take-up rates vary for deprived areas within the regions.
M.2.5. Having regard to these reports there is no adequate evidence to support geographical adjustments of the administrative data.
M.2.6. Adjusting benefits data to include people affected by sanctions. New sanctions regulations were introduced in 2012 for claimants of Jobseeker’s Allowance and Employment and Support Allowance. The effect of a sanction is that the benefit is stopped or reduced for a period of time. Those adults and their families affected by sanctions, but who otherwise would be eligible for income-based Jobseeker’s Allowance or income-based Employment and Support Allowance, will not be counted in the domain despite meeting the low income criteria.
M.2.7. Although it would enhance the Income Deprivation Domain to include those affected by sanctions, unfortunately no suitable data is available to do this. The data required would be a count of those sanctioned at any given point in time. Data on sanctions is available from the Department for Work and Pensions’ Decision Makers and Appeals System. However, data is only available on sanctions decisions taken during a particular month.
M.2.8. Unfortunately data is not available on the total number of people subject to sanctions at a particular time point, nor is it possible to derive this from the available data on sanctions decisions. There are a number of reasons for this relating to variability of the amount of time people remain sanctioned both within and between the old and new sanction regimes; the variability in the actual amount of time spent on sanctions irrespective of the period of sanction; and the review/appeal process impacting on decisions. This means that an adjustment to the Income Deprivation Domain to take into account those subject to sanctions was not possible within the timeframe of this update of the Indices.
Employment Deprivation Domain
M.2.9. Adjusting benefits/tax credit data for geographical variations in take-up. If benefits take-up varies geographically it would be desirable to adjust the administrative data in the Employment Deprivation Domain to take that into account. In the most recent report published by the Department for Work and Pensions on take-up in respect of income related benefits, there is a clear injunction in the report against reliance on regional estimates of take-up: “Due to the complexities of the methodology it is
94 See Department for Work and Pensions Jobseeker’s Allowance and Employment and Support Allowance sanctions statistics for further details: https://www.gov.uk/government/collections/jobseekers-allowance-sanctions. For an overview of the rules see https://www.gov.uk/government/publications/jobseekers-allowance-overview-of-sanctions-rules and https://www.gov.uk/government/publications/employment-and-support-allowance-sanctions-amendment-regulations-2012-2
95 Department for Work and Pensions (2012). Income Related Benefits: Estimates of Take-up in 2009-10. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/222915/tkup_full_report_0910.pdf not possible to produce reliable estimates at geographies below Great Britain so when using the figures it should always be considered that effects seen are an amalgamation of changes throughout the country rather than one geographical area” (paragraph 1.9.5, p 9). Having regard to this report there is no adequate evidence to support geographical adjustments of the administrative data.
M.2.10. **Additional weight to long-term claimants.** The possibility of providing an additional weight to those who are long-term unemployed and incapacitated would fail to pick up ‘cyclers’ (i.e. people who repeatedly move in and out of employment, for example because of seasonal work). For example, many people who are ‘seasonally’ employed might otherwise be long-term unemployed. Their brief periods of employment may not raise the likelihood of their return to more permanent employment and yet they are not counted among those who are long-term unemployed. Another reason for rejecting this adjustment is that including it would fundamentally alter the structure of the domain, which could no longer be interpreted as a straightforward proportion of people experiencing employment deprivation.
M.2.11. **Inclusion of 16 and 17 year olds.** The 16 and 17 year old age group have been excluded from the English Indices of Deprivation from 2004 onwards. The primary reason for removing the 16 and 17 year old age group from the Employment Deprivation Domain in the Indices of Deprivation 2004 was because the overwhelming majority of this age group are in either school or training, neither of which could be considered a deprivation. The recent increase in school leaving age provides further weight to the decision not to include 16 and 17 olds in this domain.
M.2.12. **Employment deprived females aged 60 to 64.** From 2010, the State Pension age has been gradually increased for females, and females aged 60 to 64 are now eligible for some of the benefits included in the Employment Deprivation Domain. However, by the mid-point of the Employment Deprivation Domain quarterly time points (September 2012) only a small cohort of females aged 60 to 64 were eligible for working-age benefits (those born between April 1950 and June 1951). As a result the number of females aged 60 to 64 receiving out-of-work benefits was significantly smaller than the number aged 55 to 59. The decision was therefore to retain the age band used in previous Indices (18 to 59 for females and 18 to 64 for males).
M.2.13. **Adjusting benefits data to include people affected by sanctions.** As indicated above in respect of the Income Deprivation Domain, new sanctions regulations were introduced in 2012 for claimants of Jobseeker’s Allowance and Employment and Support Allowance. The effect of a sanction is that the benefit is stopped or
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96 Children born on or after 1 September 1997 must stay in some form of education or training until their 18th birthday. 97 Less than 210,000 employment deprived females in England aged 60-64, compared with more than 1,840,000 aged 55-59. 98 See Department for Work and Pensions Jobseeker’s Allowance and Employment and Support Allowance sanctions statistics for further details: [https://www.gov.uk/government/collections/jobseekers-allowance-sanctions](https://www.gov.uk/government/collections/jobseekers-allowance-sanctions). For an overview of the rules see [https://www.gov.uk/government/publications/jobseekers-allowance-overview-of-sanctions-rules](https://www.gov.uk/government/publications/jobseekers-allowance-overview-of-sanctions-rules) and [https://www.gov.uk/government/publications/employment-and-support-allowance-sanctions-amendment-regulations-2012-2](https://www.gov.uk/government/publications/employment-and-support-allowance-sanctions-amendment-regulations-2012-2) reduced for a period of time. Those adults affected by sanctions, but who otherwise would be eligible for Jobseeker’s Allowance or Employment and Support Allowance, will not be counted in the domain despite meeting the criteria for inclusion in this domain. Although it would enhance the Employment Deprivation Domain to include those affected by sanctions, unfortunately no suitable data is available to do this (see sections M.2.7 and M.2.8 above).
Education, Skills and Training Deprivation Domain
M.2.14. Cross border student flows. Some English-resident students attend schools in Wales or Scotland, and vice versa. Pupils attending Welsh or Scottish schools have been excluded, as the point scoring system in schools differs between these administrations. Welsh and Scottish resident pupils who attend schools in England have also been removed from the dataset.
Health Deprivation and Disability Domain
M.2.15. Emergency admissions. The Acute Morbidity indicator is based on emergency admissions to hospital lasting more than one day. Some concerns have been raised over the possibility of practices by particular hospitals affecting the robustness of this indicator. Quality assurance analysis of the Indices of Deprivation 2015 has examined this issue, see Appendix J.3.
Crime Domain
M.2.16. Issues related to the use of police recorded crime datasets to construct the Crime Domain indicators are set out in Appendix J.3.
Barriers to Housing and Services Domain
M.2.17. Travel times to services. As part of data exploration, the possibility of switching the indicators in the Geographical Barriers to Services sub-domain from measures of road distance to services, to measures of travel time to services, was considered. The Department for Transport produces accessibility statistics at Lower-layer Super Output Area level in the form of measures of travel time to certain key services. Travel times are provided for travel by car, travel by public transport/walking, and travel by bicycle to key services. Although the release includes travel times to primary schools, GPs and food shops, travel times to post offices are not currently produced. Site locations are for England only, whereas the Indices of Deprivation 2010’s indicators for road distance to food shops and post offices take into account services beyond England’s borders.
M.2.18. Travel time by car was not pursued as a potential indicator, as most Lower-layer Super Output Areas (97-99 per cent) were assigned the minimum score of less than 5 minutes for primary schools, GPs and food shops. The Lower-layer Super Output Area scores for travel time by public transport/walking did not correlate highly with the equivalent road distance indicators of the Indices of Deprivation 2010. After careful consideration, the decision was made to retain the road distance measures as these require fewer assumptions than travel time measures, which would need to take account of issues such as the time of day.
99 Department for Transport, accessibility statistics (2012) https://www.gov.uk/government/statistics/accessibility-statistics-2012 travelled, and (in the case of public transport) frequency of service and transport connections.
M.3. Potential indicators explored that are unsuitable for inclusion in the Indices of Deprivation 2015
M.3.1. The following section describes those indicators which were explored but not found suitable for inclusion in the Indices of Deprivation 2015.
Income Domain
M.3.2. Housing Benefit and Council Tax Benefit. Housing Benefit is payable to people living on low incomes who are liable to pay rent. Council Tax Benefit was payable (until April 2013) to provide assistance to those on low incomes liable for Council Tax (local councils are now able to design their own Council Tax support schemes). Eligibility for Housing Benefit, and, before it was withdrawn, Council Tax Benefit, is assessed by reference to an applicant’s income, and also to local area rent levels and the Local Housing Allowance rental rate (and before April 2013, Council Tax). In addition, there is local variability in terms of the level of income which carries eligibility to the benefit(s). Finally, there are technical difficulties in avoiding double counting when combining this data with other benefits in the domain. For these reasons these benefits were identified as unsuitable for inclusion as indicators in the domain.
Employment Domain
M.3.3. Hidden unemployment and under-employment. The Employment Deprivation Domain aims to capture those who are involuntarily excluded from the labour market whether they are actively seeking work or not. As well as those receiving Jobseeker’s Allowance, the domain includes those out of work due to ill health. However, wider definitions of hidden unemployment also include groups such as mothers who are not working due to restrictive child care costs but would otherwise like to work, those who have given up hope of looking for work, those who are not signed on for receipt of Jobseeker’s Allowance but who are available for work, and those under-employed who want full-time work but have had to settle for part-time hours. However, despite wide ranging data exploration, it was not possible to identify suitable data sources for the construction of such an indicator.
M.3.4. Zero-hours contracts. Zero-hours contracts were considered as part of a wider definition of worklessness which includes the issue of under-employment. There are two main sources of data on zero-hours contracts: the Office for National Statistics business survey and the Labour Force Survey. Unfortunately, neither survey provides a sufficient sample size to provide robust estimates at Lower-layer Super Output Area level. In addition, there is no clear and agreed definition of ‘zero-hours contracts’, so, different groups and bodies will not only measure the number of such contracts in different ways, they will also have different perceptions of what should be included as ‘zero-hours contracts’. Significantly, the perceptions of employers and employees on what constitutes a particular type of contract will differ.
M.3.5. Lone parents receiving Income Support. Lone parents have traditionally been regarded as ‘economically inactive’, while the Employment Deprivation Domain is concerned with capturing those who are involuntarily out of employment. Recent changes have led to those lone parents whose youngest child is aged 5 or over shifting from receipt of Income Support, to receipt of Jobseeker’s Allowance. So a large proportion of lone parents will now be included in the Employment Deprivation Domain. However, there remains the question of whether lone parents with children aged under 5 should be treated as voluntarily or involuntarily out of employment. If the former, they fall outside the definition for this domain. If the latter, they should be counted. As there is no information as to whether this group is voluntarily or involuntarily out of employment, this indicator was not pursued further for this update of the Indices.
Education, Skills and Training Deprivation Domain
M.3.6. Average test score of pupils at Key Stage 1. The Key Stage 1 average test score indicator is constructed in the same way as the Key Stage 2 indicator and held in the National Pupil Database linked to each pupil’s postcode of residence. Each pupil is awarded a level for the four Key Stage exams. Values are assigned to the levels achieved in the examinations, and these values summed for each pupil. However, unlike Key Stage 2 assessments, not all Key Stage 1 results are externally moderated, with only 25 per cent of local authority schools receiving external moderation visits each year. Given there is only partial external moderation, and views expressed by users, this indicator was not pursued further for this update of the Indices.
M.3.7. Average test score of pupils at Key Stage 3. The Key Stage 3 attainment indicator included in the Indices of Deprivation 2010 was removed from the Children and Young People sub-domain, as statutory tests were abolished and Key Stage 3 assessments became teacher assessment only from 2008/9.
M.3.8. Adult literacy and numeracy. Small area level estimates of adults lacking literacy, numeracy and other skills are published based on the Skills for Life Survey. This survey is based on a sample of 7,230 respondents, across 1,516 (of 6,781) Middle layer Super Output Areas. The data is modelled to neighbourhood level using small area estimation techniques. This produces an estimate at neighbourhood level which is not sufficiently robust to use in the Indices of Deprivation and which moreover uses area effects in the modelling process which draw directly from data published from the Indices of Deprivation 2010.
M.3.9. Pupils with Special Educational Needs. Special Educational Needs levels are a good predictor of individual level pupil performance, and of variation between schools. However, there are some surprising differences between local authority areas, which may reflect policy differences rather than actual differences in educational needs.
M.3.10. Achieving a good level of development in the Early Years Foundation Stage. The Early Years Foundation Stage is a series of assessments measuring children’s
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100 Department for Business Innovation and Skills (2012), 2011 Skills for Life Survey: Small Area Estimation Technical Report. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/36077/12-1318-2011-skills-for-life-small-area-estimation-technical.pdf
101 Mooney, A., et al. (2010). Special Educational Needs and Disability: Understanding Local Variation in Prevalence, Service Provision and Support, published by Department for Children, Schools and Families. https://www.gov.uk/government/uploads/system/uploads/attachment_data/file/221970/DCSF-RB211ES.pdf progress in terms of Personal, Social and Emotional Development and Communication, Language and Literacy. This indicator was considered for inclusion because it would introduce an element of early child development (aged 5) into the domain. The data is based on practitioners’ observations over the course of the year against standard criteria, with local authorities responsible for carrying out moderation visits to ensure that assessment standards are consistent. However for the time point of mid-2012, this external moderation was only extended to 25 per cent of early years settings in the local authority area. Given the level of external moderation, and views expressed by users, this indicator was not pursued further for the update of the Indices.
M.3.11. **Exclusions from school.** Data on exclusions is collected via the School Census, with approximately 304,000 temporary and 5,000 permanent exclusions recorded in 2012. However, there is likely to be variability in how different schools apply exclusions, which could lead to differences in numbers being attributable to local policy differences as well as differences in educational deprivation levels.
**Health Deprivation and Disability Domain**
M.3.12. **Healthy lifestyle indicators.** The domain only includes direct measures of health deprivation, and does not include aspects of behaviour or environment that may be predictive of future health deprivation. Therefore healthy lifestyle indicators such as smoking, alcohol consumption and participation in sports are not appropriate to include in the domain, even where robust data is available at small area level.
M.3.13. **Obesity indicators.** Obesity is an increasing public health concern, with 23 per cent of adults, and 19 per cent of Year 6 children, classified as obese. Assessment of school pupils is now routinely carried out for Reception and Year 6 pupils, however similar data is not collected for adults.
M.3.14. **Census 2011 indicators on limiting long-term illness and general health.** The 2011 Census contained questions on limiting long-term illness and on general health status. However, the comparative illness and disability ratio indicator (derived from health benefits data made available by the Department for Work and Pensions) is highly correlated with the 2011 Census health indicators and therefore adequately captures this element of health deprivation.
M.3.15. **Cancer incidence.** Information is collected about all new cases of cancer, of which there are around 140,000 per year. To adjust for variation in the age profile of the population, age and sex standardised cancer incidence rates are needed. Lower-layer Super Output Area level age and sex standardised estimates are unlikely to be sufficiently reliable to enable meaningful comparisons between areas, even when based on aggregate data over several years.
M.3.16. **People receiving publicly-funded residential care.** People living in publicly funded residential or nursing homes are not eligible for the care components of Disability Living Allowance or Attendance Allowance but meet the same qualifying
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102 Sport England (2012), Active People Survey, [http://archive.sportengland.org/research/active_people_survey/active_people_survey_7.aspx](http://archive.sportengland.org/research/active_people_survey/active_people_survey_7.aspx)
Health and Social Care Information Centre (2012/13), National Child Measurement Programme, [http://www.hscic.gov.uk/nemp](http://www.hscic.gov.uk/nemp) conditions. This data is held by local authorities; however it is not collected nationally at individual or small area level. As sufficiently robust data is not readily available to produce this indicator, developing this indicator was outside the scope of this update.
M.3.17. **Low birth weight.** Low birth weight is linked to both increased mortality and morbidity in infancy, and an increased risk of cardio-vascular disease in later life. The indicator was considered as a potential indicator in the Indices of Deprivation 2000, and is used in the Welsh Indices of Deprivation. However, respondents to a previous consultation were concerned that certain ethnic groups have different distributions of birth weight, and that the ethnic composition of an area would therefore bias this indicator. As a result this indicator was not used in the English Indices.
M.3.18. **Infant mortality ratio.** The infant mortality ratio has previously been included in measures of deprivation such as the 1998 Index of Local Deprivation, on the basis that this represents particularly premature death, and that areas with high infant death rates would not necessarily correspond to those in which mortality levels are high at other ages. However, the numbers of infant deaths are small (nationally only around 4.7 per 1,000 live births) and, even when aggregating figures for several years, Lower-layer Super Output Area level estimates would not be sufficiently reliable to enable meaningful comparisons between areas. Also the mortality indicator (years of potential life lost) included in the domain is age standardised, giving high weightings to deaths among infants.
**Crime Domain**
M.3.19. **Police Anti-Social Behaviour incident data.** In addition to collating data on recorded crime, each police force in England is also required to collate data on reported incidents of Anti-Social Behaviour. Geocoded data is provided by each police force to the Home Office on a monthly basis in the same way as the recorded crime data is provided. This Anti-Social Behaviour data was deemed unsuitable for inclusion in the Indices of Deprivation 2015 due to known issues in relation to double counting of crimes and Anti-Social Behaviour incidents in a number of police forces.
M.3.20. **Fire Service deliberate fires data.** These are official statistics collated by the Department for Communities and Local Government (Fire Statistics Monitor). Geocoded deliberate fire data is available from 2009/10 onwards. However, many of the deliberate fires recorded by the regional fire authorities across England will also be captured as ‘arson’ in the police recorded crime data. As such, including fire service data alongside police recorded crime data would result in double counting of many events.
M.3.21. **Shoplifting.** Shoplifting was rejected because it is often concentrated in large retail centres and because its reporting is often dependent upon the offender being caught in the act.
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103 See Data Quality, Known Issues, Double counting of ASB and Crime at: [http://data.police.uk/about/#columns](http://data.police.uk/about/#columns). M.3.22. **Drug-related crime.** Drug-related crime was not deemed suitable for inclusion in the updated Indices since it could be argued that possession of an illegal drug is not in itself a form of deprivation. Certainly, drug-motivated crime (e.g. violence or burglary/theft) should be captured in a measure of deprivation, but these crimes types are already included in the Crime Domain.
M.3.23. **Sexual offences.** Sexual offence data was not previously pursued due to a number of reasons, including: sensitivity/disclosure issues; the particularly low reporting of these crimes; the way in which reporting is influenced by the relationship of the victim to the offender; and the difficulty of ascertaining the incidence.
M.3.24. **Domestic violence.** Domestic violence was not included as an indicator in its own right because violent offences against same-household members are already included in the composite violence indicator where these crimes are reported to the Police.
M.3.25. **Cycle thefts.** Cycle thefts were excluded because they are often concentrated in public areas (such as bike parks at train stations).
M.3.26. **Fraud.** Fraud was excluded because it is extremely difficult to locate geographically.
M.3.27. **Total crime.** A measure of total crime was not included because it would include the indicators described above, as well as other categories that are not relevant to deprivation.
**Barriers to Housing and Services Domain**
M.3.28. **Access to childcare.** The use of childcare is a complex issue: it depends on cost, flexibility, type and location. For example, some people prefer to use childcare nearer the workplace than close to the home. However, the number of childcare places in a district has been demonstrated to relate to the rate at which lone parents enter work in that area. For previous Indices, an option was explored to model a local authority level ratio of pre-school children to pre-school childcare places, using a combination of Child Benefit data and Ofsted childcare places. However this was seen as a complex development, with significant time needed to develop a robust indicator. As sufficiently robust data was not readily available to produce this indicator without significant extra work, developing this indicator was outside the scope of this update.
M.3.29. **Households lacking the required number of bedrooms.** Chapter 4 describes the household overcrowding indicator used in the Indices of Deprivation 2015. An alternative measure was explored, also based on Census 2011 data, which considers the number of bedrooms required by the household (rather than the number of rooms). However, this measure only counts rooms as bedrooms if they were built as such or if they have been permanently converted into a bedroom. Given that many modern houses/apartments have rooms that can be used in different ways, this alternative indicator was not used.
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104 Evans, Noble et al (2002). Growing Together or Growing Apart? Geographic Patterns of Change in IS and JSA-IB Claimants in England 1995-2000 (The Policy Press). M.3.30. **Digital services access.** Ofcom publishes data on broadband speeds, including both ‘actual broadband speed’ (based on real connections and measured speeds) and ‘availability of superfast broadband’ (download speeds of at least 30 Megabits per second)(^{105}). Actual speed is dependent on broadband packages obtained by users, so is in large part based on user choices (which may or may not be driven by questions of affordability), rather than an indicator of accessibility. The availability of superfast broadband is very high, and increasing: 77 per cent of England’s premises have superfast availability, and in 46 per cent of English Lower-layer Super Output Areas, all postcodes have superfast availability(^{106}). As indicators should measure major features of deprivation, not conditions just experienced by a small number of people or areas, this indicator was not included in this update of the Indices.
**Living Environment Deprivation Domain**
M.3.31. **Flood risk areas.** A measure of flood risk is used in the Welsh Indices of Deprivation, based on the proportion of people living in an area with a significant, moderate or low risk of flooding (risk was based on frequency rather than level of flooding damage). For England, flood risk data is available from the Environment Agency. However, the data measures risk of flooding, rather than actual flooding, and was not supported by members of the Advisory Group and Project Board as an indicator for this update of the Indices of Deprivation.
M.3.32. **Graffiti.** An indicator on graffiti was not proposed because recorded crime data for graffiti is not available separately from data on criminal damage as a whole. Moreover, some commentators have argued that graffiti may be variably reported.
M.3.33. **Households in fuel poverty.** The fuel poverty dataset published by the Department of Energy and Climate Change, which includes modelled estimates to Lower-layer Super Output Area level, is based on households with above average fuel costs that are pushed below the income poverty threshold once fuel costs are taken into account. In the survey of users in July 2014 and previous consultations there had been support from users for introducing a measure of fuel poverty into the Living Environment Deprivation Domain. However, discussion with the Fuel Poverty team at the Department of Energy and Climate Change identified that the methodology used to produce the sub-regional estimates of fuel poverty does not produce robust estimates at very low level geographies, and should not be used to compare between Lower-layer Super Output Areas(^{107}). A fuel poverty indicator was not therefore incorporated into this update of the Indices, but any improvement in methods may mean that the indicator could be further considered in future.
M.3.34. **Households lacking basic amenities.** The 2001 Census collected data on the number of households without exclusive use of a bathroom and inside toilet, but less than 1 per cent of households in England were lacking these amenities. The indicator would therefore not measure a significant aspect of deprivation at small
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(^{105}) Office of Communications, broadband coverage (2013) [http://data.gov.uk/dataset/broadband-coverage](http://data.gov.uk/dataset/broadband-coverage)
(^{106}) Ofcom (2014) Infrastructure Report 2014, [http://stakeholders.ofcom.org.uk/market-data-research/market-data/infrastructure/infrastructure-2014/](http://stakeholders.ofcom.org.uk/market-data-research/market-data/infrastructure/infrastructure-2014/)
(^{107}) 2014 review by the Department of Energy and Climate Change and Office for National Statistics statisticians, unpublished. area level. Furthermore, this indicator was not updated as part of the 2011 Census, so up-to-date data would not have been available to produce such an indicator.
M.3.35. **Households not connected to the gas network.** It is now possible in principle to construct an indicator of households not connected to the gas network, as a proxy for high costs for heating. This would be based on comparing the number of domestic gas meters in each Lower-layer Super Output Area to the number of households. However, in 13,597 Lower-layer Super Output Areas (41 per cent of all such areas in England), all households were identified as being connected to the gas network. As indicators should measure major features of deprivation, not conditions just experienced by a small number of people or areas, this indicator was not included in the updated Indices.
M.3.36. **Housing (or population) density.** The survey of users in July 2014 and a previous consultation suggested using a measure of high density housing in the Living Environment Deprivation Domain, to reflect the impact of housing on traffic congestion and pollution, and limited open space. However, housing (or population) density is only a proxy for these impacts and is not a deprivation in its own right, as high density living is not always seen as undesirable.
M.3.37. **Land use and derelict land.** The current method for measuring derelict land is the National Land Use Database, which is assembled from data collected by local authorities. However, the database is not comprehensive enough to give a sufficiently robust measure of derelict land at small area level for the whole of England, even if such an indicator was desirable.
M.3.38. **Noise pollution.** The Department for Environment, Food and Rural Affairs has estimated local environmental noise levels due to road, rail and air traffic and from industry. Although this data potentially provides an additional indicator for the Outdoors sub-domain, data is only available for major urban areas, and for major roads and railways outside the major urban areas. There was therefore not sufficient geographic coverage to include noise pollution in this update of the Indices of Deprivation.
M.3.39. **Proximity to green spaces.** There is a range of research outlining the benefits of access to green spaces including reduced pollution, improved physical and psychological wellbeing and factors which encourage healthy lifestyle behaviours. Several location datasets could be used in a composite indicator of proximity to green spaces, including local nature reserves, woodland, local open spaces, coastal beaches and Areas of Outstanding Natural Beauty. As sufficiently robust data was not readily available to produce this indicator without significant extra work, developing this indicator was outside the scope of this update. There may be value in exploring the development of such an indicator for a future update.
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108 Based on data for 2013 available at [https://www.gov.uk/government/statistics/lsoa-estimates-of-households-not-connected-to-the-gas-network](https://www.gov.uk/government/statistics/lsoa-estimates-of-households-not-connected-to-the-gas-network).
109 Online maps are available for major urban areas, with PDF maps available for major roads and railways outside the major urban areas. See [http://services.defra.gov.uk/wps/portal/noise](http://services.defra.gov.uk/wps/portal/noise) for maps and background.
110 For a summary, see Environment Agency (2008) working towards a better quality of life: Environmental Justice in South Yorkshire. [www.staffs.ac.uk/schools/sciences/geography/links/IESR/downloads/EnvJusticeinSouthYorksGENE0608BO-DZ-e-e.pdf](http://www.staffs.ac.uk/schools/sciences/geography/links/IESR/downloads/EnvJusticeinSouthYorksGENE0608BO-DZ-e-e.pdf) M.3.40. **Proximity to waste and landfill sites.** The most recent Welsh Index of Multiple Deprivation 2014 contains an indicator of proximity to waste and landfill sites, which ranks Lower-layer Super Output Areas based on the proportion of the population living within a 1km zone of each Pollution Prevention Control site and active landfill site. However, this indicator was not pursued further for the Indices of Deprivation 2015, as the impact of poor air quality resulting from proximity to waste and landfill sites is already captured as part of the air quality indicator. In addition, a systematic review of studies into the health impacts of people living in the vicinity of waste and landfill sites was unable to find sufficient evidence to establish a causal link between negative health effects and living in close proximity to waste and landfill sites.(^{111})
M.3.41. **Vacant dwellings and low demand.** The Department for Communities and Local Government publishes data on empty homes at local authority district level.(^{112}) As this data is not available at small area level, it was not considered suitable for use in a new indicator. It may be possible in future to model empty homes at small area level to provide a candidate indicator for the ‘Outdoors’ sub-domain, but this was outside the scope of this update of the Indices.
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(^{111}) For example, see information from the Environment Agency on exposure assessment of landfill sites [www.gov.uk/government/publications/exposure-assessment-of-landfill-sites](http://www.gov.uk/government/publications/exposure-assessment-of-landfill-sites)
(^{112}) Department for Communities and Local Government. Live tables on dwelling stock (including vacants) [https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock-including-vacants](https://www.gov.uk/government/statistical-data-sets/live-tables-on-dwelling-stock-including-vacants) Appendix N. History of the Indices of Deprivation
N.1.1. The Indices of Deprivation 2000 attempted to measure multiple deprivation with respect to a single overall index as well as separate domain indices. Previous indices (1981 z-scores, 1991 Index of Local Conditions and 1998 Index of Local Deprivation) that had been constructed did not attempt to measure each domain of deprivation separately before combining the indicators into an overall index; these earlier indices also comprised a smaller number of indicators, utilised proxy measures and relied heavily on Census data. The Indices of Deprivation 2000 therefore reflected an attempt to refine the conceptualisation of multiple deprivation and the methodology for constructing the indices, and included new and more up-to-date indicators.
N.1.2. In subsequent updates of the Indices of Deprivation, the number of domains and indicators has increased as more data sources become accessible, and the methodology has gradually been refined. The main focus in recent years has been to maintain a consistent methodology to allow meaningful comparisons between years.
N.1.3. The Index of Multiple Deprivation 2000 consisted of six domains: Income Deprivation; Employment Deprivation; Health Deprivation and Disability; Education, Skills and Training Deprivation; Housing Deprivation; and Geographical Access to Services Deprivation.
N.1.4. In updating these to the Indices of Deprivation 2004, the main change was the addition of the Crime Domain. Some changes were made to the Housing Deprivation Domain and the Geographical Access to Services Deprivation Domain, which became the Living Environment Deprivation Domain and the Barriers to Housing and Services Domain respectively. A small number of indicators were redistributed into these new domains. The Indices of Deprivation 2004 therefore consisted of seven domains:
- Income Deprivation
- Employment Deprivation
- Education, Skills and Training Deprivation
- Health Deprivation and Disability
- Crime
- Barriers to Housing and Services
- Living Environment Deprivation
N.1.5. There was also a change to the geography used, from wards in the Indices of Deprivation 2000 to Lower-layer Super Output Areas(^{113}) in the Indices of Deprivation 2004. The intention has always been to construct the indices at the smallest practicable spatial scale to provide a detailed measure of deprivation at a
(^{113}) For further information about Lower-layer Super Output Areas see http://neighbourhood.statistics.gov.uk/dissemination/Info.do?page=nessgeography/superoutputareasexplained/output-areas-explained.htm. small spatial unit. The 2004 Indices and all subsequent Indices have been constructed at using Lower-layer Super Output Area geography. This is a statistical geography which has more even and (on average) smaller population sizes than wards and, until it was reviewed following Census 2011, had not been subject to boundary changes (which happen regularly with wards). Lower-layer Super Output Areas are aggregations of Census Output Areas, the base unit for Census data releases.
N.1.6. The Indices of Deprivation 2007 aimed to maintain the methodology of previous Indices and no changes were made to the domains or spatial scale. The same was true of the Indices of Deprivation 2010.
N.1.7. The domains of deprivation and the methods used in developing the Indices of Deprivation 2015 update have remained consistent with those used for the 2010 Indices. This maintains comparability with previous versions of the Indices. There have been a modest number of changes to the basket of indicators used in the domains, resulting in a small number of new, modified and dropped indicators. These and changes to Lower-layer Super Output Area geography following the Census 2011 are described in Appendix C. Appendix O. What data has been published?
O.1.1. The Indices of Deprivation 2015 datasets are available to download at www.gov.uk/government/statistics/english-indices-of-deprivation-2015
Lower-layer Super Output Area data
O.1.2. Nine sets of data have been published for Lower-layer Super Output Areas:
1. Index of Multiple Deprivation: The rank and decile for each area, on the overall Index of Multiple Deprivation.
2. Domains of deprivation: The rank and decile for each area, for each of the seven domains, as well as the Index of Multiple Deprivation.
3. Supplementary Indices - Income Deprivation Affecting Children Index and Income Deprivation Affecting Older People Index: The rank and decile for each area, for the Income Deprivation Affecting Children Index and the Income Deprivation Affecting Older People Index, as well as the Index of Multiple Deprivation.
4. Sub-domains of deprivation: The rank and decile for each area, for each of the six sub-domains, as well as their respective domains.
5. Scores for the Indices of Deprivation: The scores for each area, for the overall Index of Multiple Deprivation, the seven domains, the supplementary indices, and the six sub-domains.
6. Population denominators: The primary population denominators (all people, children, working age, and older people) used in the Indices of Deprivation 2015. These can be used for aggregating the datasets, weighted by population, to other geographies such as wards (see Appendix A of Research Report).
7. All ranks, deciles and scores for the Indices of Deprivation, and population denominators (CSV file): A single text file containing all of the datasets listed above.
8. Underlying indicators. The indicators used to construct the seven domains, for those that are able to be published.
9. Transformed domain scores: The seven domain scores in this file have been standardised by ranking, and then transformed to an exponential distribution. These transformed domain scores can be used as the basis for users to combine the domains together using different weights (see Appendix B of Research Report).
Higher-level geography files
O.1.3. Four sets of data have been published for higher-level geographies:
10. Local Authority District Summaries.
11. Upper-tier Local Authority Summaries.
12. Local Enterprise Partnership Summaries.
13. Clinical Commissioning Group Summaries. O.1.4. To summarise the level of deprivation in larger areas, a range of summary measures of the Index of Multiple Deprivation 2015, the domains and the two supplementary indices (Income Deprivation Affecting Children Index and Income Deprivation Affecting Older People Index) have been created. For each of the larger areas the following measures have been published:
| Table O.1. The summary measures published for the Index of Multiple Deprivation, the domains and supplementary indices | |---------------------------------------------------------------| | Average rank | Average score | Proportion of Lower-layer Super Output Areas in most deprived 10 per cent nationally | Extent | Local concentration | Scale | | Index of Multiple Deprivation | x | x | x | x | x | | Income | x | x | x | | x | | Employment | x | x | x | | x | | Education | x | x | x | | | | Health | x | x | x | | | | Crime | x | x | x | | | | Living | x | x | x | | | | Barriers | x | x | x | | | | IDACI | x | x | x | | | | IDAOPI | x | x | x | | |
O.1.5. These measures are described in section 3.8 of the Technical Report and advice on their interpretation is provided in section 3.3 of the Research Report.
______________________________________________________________________
114 For the Indices of Deprivation 2010 and previous versions, the majority of summary measures published were for the Index of Multiple Deprivation only. In response to demand from users, additional summary measures for the domains and supplementary indices have been published here. Appendix P. Worked examples of the higher-level summary measures
Overview
P.1.1. The summary measures have been produced for the following higher-level geographies for the Index of Multiple Deprivation, domains and supplementary indices: local authority districts, upper tier local authorities, local enterprise partnerships and clinical commissioning groups. As with the Lower-layer Super Output Area data, both ranks and scores are produced, with higher scores corresponding to higher levels of deprivation, and areas ranked so that a rank of 1 identifies the most deprived high-level area on that measure.
P.1.2. In order that higher scores can consistently be interpreted as corresponding to higher levels of deprivation, those summary measures that are based on Lower-layer Super Output Area ranks (the average rank and local concentration summary measures) use a reversed ranking – where 32,844 rather than 1 corresponds to the most deprived area – in the calculation of the summary measure score.
P.1.3. To help users understand each of the summary measures, the sections below describe how to calculate the measures for hypothetical local authority districts.
Average rank
P.1.4. A user wishes to calculate the Index of Multiple Deprivation average rank for their local authority district. The average rank measure summarises the average level of deprivation across the district, based on the population-weighted ranks of the Lower-layer Super Output Areas in the area.
P.1.5. The district contains five Lower-layer Super Output Areas, with populations of 1,200, 1,800, 1,400, 1,500 and 1,700, giving a total population of 7,600, and have Index of Multiple Deprivation ranks of 3,000, 10,000, 500, 1,000 and 20,000 respectively.
P.1.6. To calculate the average rank for the local authority district, each Lower-layer Super Output Area rank is multiplied by the Lower-layer Super Output Area population. These values are then summed, before dividing by the district’s population to create the average rank for the district.
P.1.7. In order that higher scores can consistently be interpreted as corresponding to higher levels of deprivation, those summary measures that are based on Lower-layer Super Output Area ranks use a reversed ranking - where 32,844 rather than 1 corresponds to the most deprived area. The user would therefore calculate the average rank for the district as:
[ \\text{Average rank} = \\frac{32,845 - (3,000 \\times 1,200 + 10,000 \\times 1,800 + 500 \\times 1,400 + 1,000 \\times 1,500 + 20,000 \\times 1,700)}{7,600} ]
[ \\text{Average rank} = 25,240 ] When the average rank score is itself ranked then the rank of 1 (most deprived) is given to the largest average rank value.
**Average score**
P.1.8. The same user wishes to calculate the Index of Multiple Deprivation average score for their local authority district. The average score measure summarises the average level of deprivation across the district, based on the population-weighted scores of the Lower-layer Super Output Areas in the area.
P.1.9. The district contains five Lower-layer Super Output Areas, with populations of 1,200, 1,800, 1,400, 1,500 and 1,700, giving a total population of 7,600, and have Index of Multiple Deprivation scores of 45.90, 26.51, 65.67, 59.14 and 13.64 respectively.
P.1.10. In order to calculate the average score for the local district authority, each Lower-layer Super Output Area score is multiplied by the Lower-layer Super Output Area population. These values are then summed, before dividing by the district’s population to create the average score for the district. The user would calculate the average score for the district as:
[ \\text{Average score} = \\frac{(45.90 \\times 1,200 + 26.51 \\times 1,800 + 65.67 \\times 1,400 + 59.14 \\times 1,500 + 13.64 \\times 1,700)}{7,600} ]
[ \\text{Average score} = 40.35 ]
When the average score is ranked then the rank of 1 (most deprived) is given to the largest average score value.
**Proportion of Lower-layer Super Output Areas in the most deprived 10 per cent nationally**
P.1.11. A user wishes to calculate for their local authority district the proportion of Lower-layer Super Output Areas that are in the most deprived 10 per cent nationally.
P.1.12. Their local authority district contains 65 Lower-layer Super Output Areas. Of these, 18 are ranked in the most deprived decile (i.e., 10%) of all areas in England. The user would calculate the proportion of Lower-layer Super Output Areas in the most deprived 10 per cent nationally for the district as:
[ \\text{Proportion of Lower-layer Super Output Areas in the most deprived 10 per cent nationally} = \\frac{18}{65} ]
[ \\text{Proportion of Lower-layer Super Output Areas in the most deprived 10 per cent nationally} = 0.277 \\text{ (i.e. 27.7%)} ]
When the score for this summary measure is ranked then the rank of 1 (most deprived) is given to the largest proportion.
**Extent**
P.1.13. A user wishes to calculate the extent measure for their local authority district. The extent measure is a summary of the proportion of the local population that live in areas classified as among the most deprived in the country. The extent measure uses a weighted measure of the population in the most deprived 30 per cent of all areas:
- The population living in the most deprived 10 per cent of Lower-layer Super Output Areas in England receive a ‘weight’ of 1.0;
- The population living in the most deprived 11 to 30 per cent of Lower-layer Super Output Areas receive a sliding weight, ranging from 0.95 for those in the most deprived eleventh percentile, to 0.05 for those in the most deprived thirtieth percentile. In practice this means that the weight starts from 0.95 in the most deprived eleventh percentile, and then decreases by (0.95-0.05)/19 for each of the subsequent nineteen percentiles until it reaches 0.05 for the most deprived thirtieth percentile, and zero for areas outside the most deprived 30 per cent.
P.1.14. A local authority district contains 70,000 people. Of the Lower-layer Super Output Areas in the district, only four are in the most deprived 30 per cent of all Lower-layer Super Output Areas in England; the populations for only these Lower-layer Super Output Areas are included in the extent calculation. The ranks for these four Lower-layer Super Output Areas are 500, 1,000, 3,000, and 9,000 respectively, with populations of 1,400, 1,500, 1,200, and 1,800 respectively.
- The first three Lower-layer Super Output Areas are in the most deprived 10 per cent of areas (with 32,844 areas in England, the areas ranked 1 to 3,284 are in the top 10 per cent). These receive a weight of 1.0, so contribute 100 per cent of their population.
- The fourth Lower-layer Super Output Area is ranked 9,000, so is in the 28th percentile (to find out which percentile an area is in, divide the rank by the total number of ranks, in this case 32,844, multiply by 100 and round up to the nearest integer). This receives a weight of 0.1447 so contributes 14.47% of its population: the weight decreases from 0.95 for the eleventh decile by (0.95-0.05)/19, so is 0.1447 for the 28th percentile.
P.1.15. The user would therefore calculate the extent summary measure for the district as:
[ \\text{Extent} = \\frac{(1,400 + 1,500 + 1,200 + 0.1447 \\times 1,800)}{70,000} ]
[ \\text{Extent} = 0.062292 ]
When the extent score is ranked then the rank of 1 (most deprived) is given to the largest extent score.
Local concentration
P.1.16. A user wishes to calculate the local concentration measure for their local authority district. The local concentration measure is a summary of how the most deprived Lower-layer Super Output Areas in the higher-level area compare to those in other areas across the country, and measures the population-weighted average rank for the Lower-layer Super Output Areas that are ranked as most deprived in the higher-area, and that contain exactly 10 per cent of the higher-area population (in many cases, this will not be a whole number of Lower-layer Super Output Areas).
P.1.17. A local authority district contains 70,000 people; 10 per cent of this population is 7,000 people. The local concentration measure calculates the population-weighted rank of the most deprived Lower-layer Super Output Areas containing exactly 7,000 people. Having sorted the Lower-layer Super Output Areas in descending order of deprivation, the five most deprived Lower-layer Super Output Areas in the local authority district have populations of 1,400, 1,500, 1,200, 1,800, and 1,700, giving a total population of 7,600 (just higher than the 7,000 population required).
P.1.18. These Lower-layer Super Output Areas have ranks of 500, 1,000, 3,000, 10,000 and 20,000 according to the Index of Multiple Deprivation. In order that higher scores can consistently be interpreted as corresponding to higher levels of deprivation, those summary measures that are based on Lower-layer Super Output Area ranks use a reversed ranking - where 32,844 rather than 1 corresponds to the most deprived area.
P.1.19. To reach the required population of 7,000 (i.e., 10 per cent of the district’s population) the first four Lower-layer Super Output Areas are included plus 1,100 of the fifth Lower-layer Super Output Area population. The user would calculate the local concentration measure for the district as:
[ \\text{Local concentration} = 32,845 - \\left( 1,400 \\times 500 + 1,500 \\times 1,000 + 1,200 \\times 3,000 + 1,800 \\times 10,000 + 1,100 \\times 20,000 \\right) / 7,000 ]
[ \\text{Local concentration} = 26,302.14 ]
When the local concentration score is ranked then the rank of 1 (most deprived) is given to the largest local concentration score
Income scale and employment scale (two measures)
P.1.20. A user wishes to calculate the income scale and employment scale for their local authority district. The two scale measures summarise the number of people in the higher-level area who are income deprived (the income scale) or employment deprived (the employment scale).
P.1.21. A district contains five Lower-layer Super Output Areas. The number of people in low income families in each Lower-layer Super Output Area (i.e., the Income Deprivation Domain numerator) is 1,563, 1,672, 1,745, 1,499 and 1,812.
P.1.22. The user would calculate the income scale measure for the district as:
[ \\text{Income scale} = 1,563 + 1,672 + 1,745 + 1,499 + 1,812 ]
[ \\text{Income scale} = 8,291 ]
P.1.23. The employment scale measure is calculated in the same way, but using the numerator of the Employment Deprivation Domain.
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532cc3bc1732659341f577d1f37b504590a8c5b3 | Invitation to tender for provision of an online platform to deliver HR Metrics surveys and data benchmarking for local authorities across the country
Enquiries from various Bidders during week commencing 14 December 2020 and Answers to the questions at 18 December 2020 -
Enquiry 1
Objectives 11. … It is important that there is seamless transition from the current provision arrangements so that users can continue to access an application for their ongoing needs of data entry and output generation from 1 April 2021.
To ensure there is a seamless transition from the current system to our system we will plan the migration. To help us plan, please:
• provide a copy of all the surveys
Answer - London Councils is not providing copies of the surveys for this tender. A list of the surveys has been provided. The successful bidder will be provided with relevant information to enable successful migration of data from the current system to a new one. Relevant project methodology for migration can be outlined by bidders and will be sufficient for evaluation. If absolutely necessary, the implementation go live date of 1 April 2021 may be extended but subject to negotiation and mitigation of any disruption to survey timetabling.
• describe the current technical stack (i.e. infrastructure) including: o hosting arrangements (cloud or local server at London Councils)
Answer – Cloud
o database storage; which database is used Microsoft SQL Server, Oracle, MySQL, etc.
Answer – This is not deemed relevant to assessment of the bids. The successful bidder will be provided with relevant information to enable successful migration of data from the current system to a new one.
o survey software used / format surveys are stored in
Answer – This is not deemed relevant to assessment of the bids. It is anticipated that the successful bidder will have their own survey software and methods for collecting, holding and presenting the information. The key is to enable output data that can be easily read/interpreted by data users.
- provide a copy of all the Outputs results/benchmarking
- charts
- pdf reports
- scorecards
- dashboards
- Excel spreadsheet outputs
- text
Please use test input data, delete or blank out real data – we do not need to see actual data which may be confidential.
Answer – This is not deemed relevant to assessment of the bids. It is anticipated that the successful bidder will have their own approach and methods for collecting, holding and presenting the information. The key is to enable output data that can be easily accessed/ read/ interpreted by data users.
Does London Councils have a backup of the database?
Answer - No
What documentation does London Councils have?
- Database documentation; e.g., Data Dictionary and Database Diagram
Answer – No
- Systems Administration documentation
Answer - Yes (a brief summary for users)
- User documentation; e.g., how to login, fill out the surveys, raise issues, access the dashboards, etc.
Answer - Yes (a summary for users)
Please provide a copy of the documentation –
Answer – This is not deemed relevant to assessment of the bids.
14. “The full list of surveys, and their output requirements, can be found at Appendix A. Data for the surveys is collected and published on a rolling timetable throughout the year, with roughly one per month. A full data collection and publication timetable for 2020/21 is available on request”.
Please send a copy of the data collection and publication timetable for 2020/21.
Answer - The timetable is attached at appendix A. It is currently under review and likely to change. Requirements 15. London Councils’ detailed technical specification for the online application is set out in Appendix B. However, the key requirements for the online application are that it must: • be able to migrate our historic survey data into outputs that are available going forward;
Please confirm that all historic survey data is held in a database, i.e. there is no requirement to convert historic survey data into the database.
Answer - London Councils is able to download the raw data for each survey using Excel spreadsheets. This is the data that London Councils would provide for migration.
15. London Councils’ detailed technical specification for the online application is set out in Appendix B. However, the key requirements for the online application are that it must: • offer backwards compatibility to IE8;
See also Appendix B – Detailed technical specification
Row Number 22. Backwards compatibility - Some councils use older versions of IE - the application needs to be accessible/usable for users of older versions of IE (currently version IE9).
Microsoft stopped supporting IE8 in 2016 and IE9 in 2017 and there have been no security patches since this time. Older browser may not render modern websites well (and may pose a security risk if unpatched).
Please confirm the requirement for Backwards compatibility and London Councils’ acceptance of the security and display implications of using older, unsupported browsers.
Answer - London Councils is conducting a survey of users on which web browser they are using. Users have been asked to respond by 23 December 2020. This question response will be updated once the results of the survey are known.
Appendix A – Surveys likely to be required from April 2021 onwards
Bulk upload by Councils Please explain what you mean by “Bulk upload by Councils”. Does “Bulk upload” mean that Councils upload a lot of data on a customised Excel form?
Answer - Yes or Does “Bulk upload” mean that Councils upload completed multiple surveys all at the same time? Upload by online form The HR Resources Survey is not currently uploaded by an online form. Please describe what type of data is gathered on the HR Resources Survey. Is the data “transactional”, i.e., data per member of staff?
Answer – No. The data relates more to type of role e.g. recruitment, payroll, and number of staff resources assigned to the role.
Row Number 38 What do you mean by “Open and close surveys for the current survey period”? Is each survey completed across all areas at the same time?
Answer - Yes at the moment and to enable full survey return from data contributors/users the survey closure date can be extended on occasion to facilitate a fuller return.
Are there different versions of the surveys for different areas/regions?
Answer - The questionnaires are in some cases slightly different for different regions to accommodate differences in type of council (e.g. district, county) and/or client expectations of output.
Row Number 48 Survey respondents at the councils using the surveys can input/edit data directly into a secure web form or by end-user upload of customized Excel forms (in a specific, pre-determined format specified by London Councils) on the providers’ website. End-user bulk uploads as described in the sentence above are required for pay surveys and other surveys with a large volume of data to submit. (See List of Surveys for more detail.)
Please provide example files of a 'specific, pre-determined format specified by London Councils'.
Answer - An example is described in the Technical Specification. London Councils is not providing survey documents for this tender. This is not deemed relevant to assessment of the bids.
Row Number 55 Provider required to update pay survey data by the amount of annual pay award in years when the pay award is announced after the data has been partly or completely collected. Pay surveys to ascertain whether data councils upload includes that year’s pay award and where it does not, the provider is to uprate the pay data given by the % amount of the pay award. This applies only to councils that apply the national pay awards and those with local conditions that mean that the same % award is made.
What is the scope of work involved? Does the provider (i.e., us) have to update 1 row per council - or 1000 rows per council? Answer - The provider would update as many rows of data as the councils that want the pay award applied have submitted (some councils with local pay arrangements may not want the award applied). This could be in the region of 350 per council but could be more as for some surveys councils can enter as many roles as they wish.
Where can we find the national pay deal information?
Answer - This is announced when the pay award is agreed. London Councils will email the provider with the notification. You can see the Local Government Association website for general information about pay for Local Government Services staff.
Row Number 87 Data to be uploaded by councils using custom-designed Excel input forms the content design and layout of which to be as specified by London Councils to exactly match those in current use. These to be downloadable by users from the provider’s website. Please provide examples of the custom-designed Excel input forms the content design and layout.
Answer - This is not deemed relevant to assessment of the bids. It is anticipated that the successful bidder will have their own approach and methods for collecting, holding and presenting the information. Whilst, London Councils has a current methodology for data collection, if the successful bidder identifies a methodology that might be more effective this can be used. The key is to enable output data that can be easily accessed/ read/ interpreted by data users.
Row Number 88 and 89 These outputs are as specified by London Councils in the form of custom-designed Excel spreadsheets to match those in current use. The outputs to be available for users to download as compiled sets of data with calculated fields, numeric and text values including free text and drop-down selections. All including the presentation layout and appearance are to be as specified by London Councils. Exports must reflect latest version of data. For example, the HR Resources survey outputs comprise an Excel workbook of 7 custom-designed spreadsheets including a table showing a compilation of free text entries per council; tables showing top-line summaries of average FTE employee numbers by 5 different categories, headcount and average of HR FTE ratios to workforce headcount and number of the survey responses by "as at" date; table of average FTE of HR by work type and grade band for all councils in the region; table of average FTE of HR by work type and grade band for Inner London; same for Outer London (in the case of London but by other council categories for other regions - ie: County/ Metropolitan Borough/Unitary council and District Councils) all values to be calculated from the data provided by each council in its custom-designed Excel upload form); table of outsourced HR work by council by work type with name of provider; table of shared HR work by work type with name of partner/partners. As this survey does not have a raw data export option. the provider will need to give the relevant Regional Head their councils' raw data on request to enable them to conduct data checks. Question: how many unique designs are there?
Answer - At the moment the surveys using the custom forms are as set out in Appendix A in the tender documents. The designs may change and additional custom designs may be required. Whilst, London Councils has a current methodology for data collection, if the successful bidder identifies a methodology that might be more effective this can be used. The key is to enable output data that can be easily accessed/ read/ interpreted by data users.
For a survey, does it have just one customised Excel spreadsheet, or are there different designs for each Council?
Answer - There is one custom sheet per survey for inputting (they may differ slightly between regions). Outputs may require multiple custom sheets (as per the example you refer to in Rows Number 88 and 89). Whilst, London Councils has a current methodology for data collection, if the successful bidder identifies a methodology that might be more effective this can be used. The key is to enable output data that can be easily accessed/ read/ interpreted by data users.
Please provide example Excel spreadsheets.
Answer - This is not deemed relevant to assessment of the bids.
Enquiry 2
1. Users to have the ability to generate their own bespoke results outputs including reports and scorecards and Excel outputs, which can be customised. Would you be able to provide some detail as to the type of reports they would need to generate? Our platform enables users to create their own scorecards and surveys and there are elements of extracts available as well as using the dashboard to surface survey results as a KPIs. An example of the type of excel output and type of customisation would be helpful if you are able to.
Answer - This is not deemed relevant to assessment of the bids. It is anticipated that the successful bidder will have their own approach and methods for collecting, holding and presenting the information. The key is to enable output data that can be easily accessed/ read/ interpreted by data users.
2. The platform must offer backwards compatibility to IE8 – is this absolutely compulsory? Our platform supports IE11 onwards and due to various technical and security reasons we would not be able to partake should this requirement be essential.
Answer - London Councils is conducting a survey of users on which web browser they are using. Users have been asked to respond by 23 December 2020. This question and answer response will be updated once the results of the survey are known.
**Enquiry 3**
a. Could I request the full data collection and publication timetable for 2020/2021
Answer - The timetable is attached. It is currently under review and likely to change
b. Could you provide me a sample of a survey (to understand the (1) typical survey formats and (2) one that is most complex)
Answer - An example is described in the Technical Specification. London Councils is not providing survey documents for this tender. This is not deemed relevant to assessment of the bids.
c. What is the typical size of each survey (or the number of rows/columns for a typical survey)
Answer - An example is described in the Technical Specification. London Councils is not providing survey documents for this tender. This is not deemed relevant to assessment of the bids.
d. Do you allow members who have not submitted a particular survey to retrospectively submit in order to participate in that benchmark (in the same regard are surveys locked and final once posted or can be corrected post date)
Answer – Not as rule, but exceptions have been made if it deemed appropriate to enable a better benchmarking output and assessment of results. The determination comes from the client’s needs, the ease with which additional/late information can be accommodated and whether the final data usage and output of results will enable analysis and insight.
e. In terms of the migration of the previous data, can you provide information on the current database/system that is already being used (including if the previous datasets are in a database, excel format or a csv)
Answer - This is not deemed relevant to assessment of the bids. The successful bidder will be provided with relevant information to enable successful migration of data from the current system to a new one. Relevant project methodology for migration can be outlined by bidders and will be sufficient for evaluation.
## Appendix A
| Survey Title | Survey start date | Deadline for returns | |--------------------------------------------------|-------------------------------------------------------|-----------------------------------------------------------| | Analysis of DfE CSW Workforce data | n/a this survey uses data published by DfE | n/a data published by DfE | | HR Resources | 22 February 2021 (collecting current data) | 23 April 2021 | | Gender Pay Gap | n/a this survey uses data published by Cabinet Office | n/a data published by Cabinet Office | | Human Capital Metrics | 3 May 2021 (collecting 2020-21 data) | 9 July 2021 | | CO Pay & Benefits | 10 May 2021 (collecting data as at 1 April 2021) | 2 July 2021 | | Pay & Benefits (SW) | 10 May 2021 (collecting data as at 1 April 2021) | 16 July 2021 | | Pay & Benefits (exc SW) | 10 May 2021 (collecting data as at 1 April 2021) | 16 July 2021 2021 | | TU Membership and Facilities Time | 20 September 2021 (collecting current data) | 29 October 2021 | | Terms and Conditions | 18 October 2021 (snapshot of current data as at the time of the survey) | 26 November 2021 | | HR Outputs | 29 November 2021 (collecting 2019-20 data) | 21 January 2022 | | HR Resources | 21 February 2022 (snapshot of current data at the time of the survey) | 1 April 2022 |
Timescales depend on councils providing data by the deadline. Dates may change. Each borough should ensure that the data it provides has been produced in accordance with the survey guidance; and reflects the true position within their council.
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7ccba2ba502df106f13754f679d9995d046d58b1 | The National Archives Education Service
Enquiring Into Elizabeth
Preparation materials for workshops at The National Archives and Westminster Abbey
## Contents
| Section | Page | |-------------------------------|------| | Teacher Preparation | 3 | | Student Preparation | 4 | | Who’s who? | 5 | | Glossary | 6 | | Document 1: SP 15/17/113 | 7 | This study day is made up of two sessions. One session takes place at The National Archives and the other at Westminster Abbey. Timings of the day have been negotiated with your school and can be found on your booking form.
**Transport** We recommend that you travel between the two sites on public transport to save time. The National Archives is a ten minute walk from Kew Gardens underground station (District line). Westminster Abbey is a five minute walk from St James’ Park underground station (District line). Journey time between the underground stations is approx. 35 minutes but please allow time for the walk at either side.
**Contact information on the day** Education department National Archives 020 8876 3444 ext. 5298 Education department Westminster Abbey 020 7654 4965
**Aims of the Study Day** The ‘Enquiring into Elizabeth’ study day has been designed to give students a hands-on practical approach to History whilst developing their knowledge about Elizabeth I. They will use original documents and the Abbey building as historical sources. Students should have some background knowledge to Elizabeth’s reign before the day. Please see the preparation notes below.
At **The National Archives** students will examine original Tudor State Papers to discover more about Queen Elizabeth’s personality and her style of rule. They will learn practical skills regarding the handling of documents from our collection and use these skills to examine original Elizabethan letters and speeches. These include;
- Elizabeth’s ‘Declaration of Intent’, 1558
- Her speech to Parliament on the subject of her marriage, 1563
- Her letter to Mary Queen of Scots commenting on Mary’s third and hasty marriage, 1567
- Her letter to her cousin Henry Carey following his victory over the northern Earls, 1570
- Her letter to King James VI counselling her fellow monarch on foreign policy, 1602 They will use their historical skills to analyse how Elizabeth used language and imagery to influence the portrayal of her sovereignty.
At **Westminster Abbey** students will explore the building to find out more about Elizabeth’s concept of sovereignty and monarchy. They will also draw conclusions about Elizabeth’s religious settlement as they tour around the Abbey church. Elizabeth knew the Abbey well. Like all monarchs before her, she was crowned here. She is buried here too alongside her Tudor family in the stunning 16th Century Lady Chapel. Students will be encouraged to think about the function of this special building and what it meant to Elizabeth. They will also try to solve a puzzle and work out which of Elizabeth’s courtiers has the largest tomb in the Abbey! Student Preparation
Students will get the most out of this day if they have some knowledge of the following:
- Changes in religion under Henry VIII, Edward VI and Mary I.
- The situation on Elizabeth’s accession.
- Key challenges to her reign (pressure to marry, rebellions, religious settlement).
Please ensure that students have a copy of our ‘Who’s who?’ to help them on the day.
The following films, programmes and books could be used in preparation for the visit or for further study:
*Elizabeth* directed by Shekhar Kapur, starring Cate Blanchett, 1998.
David Starkey’s series on Elizabeth is still available on 4ondemand [http://www.channel4.com/programmes/elizabeth/episode-guide](http://www.channel4.com/programmes/elizabeth/episode-guide)
BBC online summary of Elizabeth’s life using an interactive timeline [http://www.bbc.co.uk/timelines/ztfxtfr](http://www.bbc.co.uk/timelines/ztfxtfr)
*Elizabeth, The Queen* by Alison Weir.
*Elizabeth I* by Cristopher Haigh.
*Elizabeth I* David M. Loades. Who’s who?
Anne Boleyn. Mother of Elizabeth. Executed 1536.
Catherine Parr. Influential step mother to Elizabeth.
Mary I. Reigned 1553-1558. Elizabeth’s half sister.
Elizabeth I. Reigned 1558-1603.
Mary Queen of Scots. Cousin of Elizabeth and mother of James I. Executed 1587.
William Cecil, Lord Burghley. Chief adviser to Elizabeth.
Henry Carey, Baron Hunsdon. Cousin of Elizabeth.
James I. Succeeded the throne after Elizabeth’s death. Son of Mary Queen of Scots. Students will also benefit from an understanding of the following terms. A good idea would be to print this out back-to-back with the Who's who? sheet, so that students can refer to it during the workshops.
**ABBEEY**: A monastery run by an Abbot.
**CANONISED**: To be made a saint.
**CLOISTER**: A covered walkway forming a quadrangle. The place where monks study.
**CORONATION**: The ceremony that celebrates the crowning of a new king or queen.
**ILLEGITIMATE**: Used to describe a child whose parents are not legally married.
**FOREIGN POLICY**: The monarch or government’s strategy in working with other nations.
**MONARCH**: The king or the queen.
**PRIVY COUNCIL**: Advisors appointed by the monarch to help them govern.
**SHRINE**: Where a saint is buried.
**SOVEREIGNTY**: Supreme power or authority. This is an example of the type of document that students will study. It is a letter from The National Archives' collection of state papers. The state papers domestic are the accumulated papers of the secretaries of state relating to home affairs. They contain information on every aspect of early modern government, including social and economic affairs, law and order and religious policy. This particular document is a letter written by Queen Elizabeth to her cousin Henry Carey. In the letter, Elizabeth congratulates Henry on helping to defeat the rebellion of the northern earls. Students will be able to see the original document and will try their hand at reading original Tudor script (simplified transcripts will be available to help them!) The Education Officer will lead a discussion about what the document reveals about Elizabeth’s style of rule.
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a9a96ae3684f6f7c6acccf7a854be7b122677f43 | Enterprising councils Getting the most from trading and charging 2012 edition
## Contents
| Section | Page | |--------------------------------------------------------------|------| | What is an enterprising council? | 4 | | Why this matters to councillors and senior officers | 5 | | How this guide can help | 6 | | Preparing to trade or charge | 7 | | Charging | 11 | | Trading | 13 | | Checklist for councils and contacts | 25 | | Further reading | 26 | What is an enterprising council?
Every council is an enterprising council in one way or another. Councils have led the way in the public sector, demonstrating initiative and resourcefulness to rise to the social, economic and environmental challenges that our communities are facing.
It is this willingness to not just think about doing things differently but to actually take action that has made local government the most efficient part of the public sector.
The Localism Act 2011 introduces a new General Power of Competence (GPC), which explicitly gives councils the power to do anything that an individual can do which is not expressly prohibited by other legislation. This activity can include charging or it can be undertaken for a commercial purpose, and could be aimed at benefiting the authority, the area or its local communities.
By giving councils the flexibility to act in their own financial interests, the GPC will allow councils to do more than was previously sanctioned under wellbeing powers. This guide will focus on how councils, on their own or working with other public bodies, can be enterprising by increasingly trading and charging. Why does this matter to councillors and senior officers?
We all know that in the decade ahead public services will need to adjust to significantly lower levels of central funding than in the past. The Chancellor of the Exchequer confirmed in Budget 2012 that significant cuts to departmental spending can be expected at least through to 2016/17. As it is, local authorities are absorbing a 28 per cent cut to their core funding while facing mounting pressures across service areas like adult social care, safeguarding children and waste management. Cuts to Government grant have been further exacerbated by a loss of revenue from existing fees and charges.
At the same time, councils are facing tough decisions about their council tax rates. Given that all services are effectively paid for by the taxpayer, the service user or both, it makes sense to consider whether it would provide more fairness to the taxpayer to ask those who benefit from a service to cover part or even all of its costs.
Across councils, officers and members are becoming more and more commercial in their acumen, outlook and skills to meet future funding challenges. Trading (ie to generate efficiencies, surpluses and profits) and charging (ie to recover the costs of providing a discretionary service) are important options on the menu of innovative ways of working to meet local needs through delivering value for money, sustaining communities and providing choice.
Councillors are playing a critical role, providing leadership to their councils and local partners during these much tougher times. In this context, there are no easy choices. But where choices have to be made they are best made locally by elected representatives who are in daily contact with the people they serve. How can this guide help?
This guide is designed to help councillors and senior officers work together to navigate their way through difficult choices to be made about engagement in trading activities and charging for services.
In this updated version we will look at:
• The legal options councils currently have for trading and charging including the most recent rule changes introduced by the GPC under the Localism Act 2011.
• Examples of good practice from councils across the country to help your authority prepare to introduce new trading or charging arrangements.
We need to point out that this short guide is not intended to be a definitive statement of the law and, as ever, councils need to take their own legal and financial advice.
The contents of this guide apply only to England; different arrangements are in force in Wales, Scotland and Northern Ireland. Preparing to trade or charge
Whether your council is thinking about generating income through trading or charging, you will need to consider:
What are you trying to achieve?
Delivering value for money Keeping pace with local citizens’ expectations is an uphill struggle when central funding is reducing. Exploring new and more efficient ways of working through collaboration between public bodies may be one approach. Generating additional income is another choice available to councils and other public sector partners. That is why it is important to consider all the options for trading and charging.
Profits and surpluses generated through trading activities can be used to help hold down council tax and/or can be directed into frontline services. Income generated from charging for the costs of supplying discretionary services can also help the council’s financial position.
Sustaining communities In some parts of the country communities struggle to thrive because the market does not supply the services local people need at a price they can afford to pay. The recent recession showed this in sharp relief. Market failure of this kind needs to be addressed if communities are to be kept viable.
In many areas, enterprising councils have stepped in to correct market failure of this kind by providing services themselves. For example, Essex Cares Limited, a trading company owned by Essex County Council, provides support for over 100,000 Essex citizens every year. The business, formed in July 2009, provides services supporting people to live active lives and remain independent at home.
By entering the market the council may be seeking to moderate prices for essential services. This may be necessary where the absence of competition means that price rises are not being kept in check. The Localism Act 2011 now supplements and strengthens the statutory powers of councils to offer alternative solutions.
The delivery of discretionary services, charged for on a cost-recovery basis, is an option for councils faced with a challenge of this kind. Charges may be subsidised where this is merited. Establishing a local authority commercial trading company primarily to make profits is another option although the commercial purpose of this type of trading entity means that it would not suit every situation.
Providing choice Individual citizens and local communities vary widely in their needs and aspirations. Councils seek to be responsive by tailoring services and offering choice where appropriate. For example, a council might decide to provide a new discretionary service, that is an addition to or enhancement of a statutory service, and then charge for it. The additional service could be requested by an individual or collectively by a neighbourhood. Using powers in this way, it is possible to make a discretionary service pay for itself through usage and demand. This approach will not be suitable for all services. Statutory duties arising from pre-existing legislation govern the provision of services and how their costs should be met. If such duties exist, they must continue to be observed.
Some councils are looking at establishing a trading enterprise to exploit existing skills and expertise to a wider market. Through a commercial trading company these councils hope to extend and improve the range of services offered and introduce new players into the market - for example other councils and businesses not necessarily based in the authority’s area. Often the council will be exploring trading in a market or sector it already operates in (eg trading standards or social care). Sometimes it will seek to fill a gap in the market where it believes there is untapped demand for a particular service e.g. translation services offered to other public bodies or offering library transcription services for the blind and extending such service offers to banks, utility companies and other agencies so they can send out bills and statements in tape (or other suitable) format.
How will you involve relevant service users, communities and staff?
This is particularly important when charging for a service, where the costs previously have been met by council tax or other income. Charging for a discretionary service could be controversial and unpopular. Similarly increasing charges for existing services must be handled with care to prevent perceptions and accusations of taxation by stealth and potential legal challenge from interest groups and affected individuals.
Taking the time to adequately consult with the market and users of the service who are most likely to be affected by charging can help to mitigate some of these problems and avoid damage to relations with local communities. In some cases, there may also be a statutory requirement to consult if the activity is covered by a separate statutory code.
The following measures will help to meet concerns and opposition to charging and income generating initiatives:
• providing proper transparency and accountability of the charging regime • explaining the context of the charges, how they have been assessed and the basis upon which charges have been calculated • setting out the context within which the new (or additional) charges are being considered and what the income will be used for (eg to enhance a particular service such as libraries, leisure and recreational facilities or other discretionary services) • demonstrate you have considered the impact of charges on different sections of the community • undertaking thorough market research on what other councils are doing, what they are charging and what other private and voluntary bodies are doing in the same or similar markets • being able to demonstrate that the end user is getting value for money despite the introduction of charges.
In 2007 Ipsos MORI completed research for the Audit Commission to explore residents’ views towards service-specific charges: http://tinyurl.com/dyhxhxa
Meanwhile if you are looking to move staff from the council to form part of a local authority trading vehicle make sure you:
• consult early with staff, sell them the vision, listen to their suggestions and adapt proposals accordingly • develop trust and commitment to the new organisation and take employees with you on the journey • research and explain all issues relating to terms and conditions of employment, specifically pensions and other areas covered by the Transfer of Undertakings (Protection of Employment) Regulations (TUPE) • ensure that staff who transfer to the new enterprise want to be there and are committed to its objectives.
From a workforce perspective the key to success when any organisation spins out of local government is effective employee engagement.
How does the law help you to achieve your objective?
Trading and charging for services has been a feature of local government for a considerable time. For example:
• **Specific powers** to charge for services are contained in a variety of local government statutes.
• Under the **Local Authorities (Goods and Services) Act 1970** councils were given powers to enter into agreements with each other and with a long list of other designated public bodies.
• The **Local Government Act 2003** added further possibilities. It enables councils to trade in activities related to their functions on a commercial basis with a view to profit through a company. In addition, the 2003 Act empowers councils to charge for any discretionary services on a cost recovery basis. Originally, trading through a company was confined to certain categories of councils but a Trading Order, in force since October 2009, removed such restrictions.
• The new **General Power of Competence (GPC) contained in the Localism Act 2011** now sits alongside local government’s existing powers to trade and charge. Under the Localism Act 2011 commercial trading through a special purpose trading company is now an option open to many more public bodies including eligible parish councils, fire and rescue authorities, integrated transport authorities, passenger transport executives and economic prosperity boards in England. New powers contained in the Localism Act also provide the ability to charge for discretionary services on a cost recovery basis. What is the General Power of Competence?
The Localism Act 2011 will repeal and replace wellbeing powers in England but not in Wales. The wellbeing powers, introduced in 2000, provided councils with powers to do anything they considered likely to promote or improve the economic, social or environmental wellbeing of the area. Whilst these powers were very widely drafted, litigation as to the proper scope of wellbeing caused some uncertainty.
The General Power of Competence (GPC) within the Localism Act 2011 removes these uncertainties. It simply states that: “A local authority has power to do anything that individuals generally may do”. It is worth noting that while the definition of a ‘local authority’ in the Act doesn’t explicitly reference unitary authorities and metropolitan borough councils these are captured by this definition by the references to district and county councils.
Through the GPC Parliament has expressly granted local authorities all the powers to do anything that an individual of full capacity generally may do (unless expressly prohibited by another statutory provision). Parliament has recognised the important indirect benefits to communities of giving councils the freedom and flexibility to act in innovative and resourceful ways. Consequently, the GPC effectively removes many of the unhelpful boundaries that have constrained their activities in the past (eg preventing a group of councils creating a mutual insurance company) to enable local authorities to do things:
- anywhere in the UK or elsewhere
- for a commercial purpose or otherwise, or for a charge or without charge
- for, or otherwise than for, the benefit of the authority, its area or persons resident or present in its area.
There are provisos to these new freedoms. For example, the GPC will not:
- provide local authorities with any new power to raise tax or precepts, or to borrow
- enable councils to set charges for mandatory services, impose fines or create offences or byelaws affecting the rights of others, over and above existing powers to do so.
Councils will need to determine whether any overlapping powers exist in other legislation. Overlapping powers enacted before the GPC may place ‘pre-commencement limitations’ on the GPC, but powers enacted after commencement will only apply to the general power if expressed to do so.
Despite these limitations, GPC is clearly designed to allow councils to get on with the job of working innovatively with others to drive down costs and meet local people’s needs. The Secretary of State retains a power within the Localism Act to make orders amending, repealing, revoking or dis-applying any statutory provision that prevents the GPC being used in this way. It is essential that local authorities are pro-active in helping Government identify any remaining unhelpful restrictions.
The remainder of this guide explores opportunities for trading and charging in more detail to help you identify the best powers to achieve your objective. Charging
There are specific powers to charge for services scattered throughout local government legislation. For example:
- section 19 of the Local Government (Miscellaneous Provisions) Act 1976 permits charging for the use of leisure and recreational facilities
- section 38 of the 1976 Act permits entering into agreements with other persons to make full use of local authority computers and equipment
- the Civic Restaurants Act 1947 permits district councils and London boroughs to run restaurants and otherwise provide for the supply to the public of meals and refreshments and use best endeavours to ensure its income is sufficient to cover its expenditure.
The Local Government Act 2003 introduced a general power to charge for the provision of any discretionary service. The charging power is available to all ‘best value authorities’. This includes all counties, unitary authorities, London boroughs, metropolitan boroughs, and districts councils alongside a number of other local authorities.
The charging powers do not apply to services which an authority is mandated or has a duty to provide. However, councils can charge for discretionary services (that is, services they have power to provide but are not obliged or have a duty to provide by law).
The recipient of the discretionary service must have agreed to pay for the provision of such services.
The 2003 Act power cannot be used where charging is prohibited or where another specific charging regime applies. Charging is limited to cost recovery and statutory guidance published in 2003 outlines how costs and charges should be established and that guidance remains in force (see Further Reading).
The charging provisions contained in the Localism Act 2011 follow, very closely, the requirements of the 2003 Act to allow local authorities to charge up to full cost recovery for discretionary services. These provisions will continue side-by-side rather than replace the Local Government Act 2003 powers. The general power to charge is subject to a duty to secure that, taking one financial year with another, the income from charges does not exceed the costs of provision.
As with the 2003 Act powers, charging for things done in exercise of the GPC is not a power to make a profit from those activities. So authorities wishing to engage in commercial trading for profit will need to rely on other powers to trade, which are explored in the next section of this guide. Rushcliffe Borough Council, Nottinghamshire
Rushcliffe, in common with many other councils, is faced with making significant cost savings. Charging for green waste was one of the many income generation projects that they hope will help with these challenging targets. The council had provided green bin collections as a free discretionary service to residents for many years but noticed they were also collecting a lot of nearly empty bins which was very inefficient. They decided to explore introducing a cost recovery charging scheme for customers who use the service frequently and who opt to pay for it.
They recognised that it was a challenge to introduce a charge for a previously free service. After researching the legal powers to charge for this service (in this case the Environmental Protection Act 1990 and the Controlled Waste Regulations 1992 Schedule 2) and examples of what some other Councils were doing in this area, the council conducted Rushcliffe’s largest ever customer contact exercise. The call centre was ‘hot’, proactive and non-stop. It received 17,500 calls in just four months – a 50 per cent increase over normal volumes. Rushcliffe received significant take up of the scheme with over 40 per cent of residents who agreed to the service opting to pay online, which is secure, efficient and fast.
The outcome: To date, performance has far exceeded Rushcliffe’s expectations. The original target was set to get 15,000 homes signed up to the services based on experience from other councils however currently:
- 26,000 households have joined (over two-thirds of homes)
- many customers opted to buy extra bins as they are such good value for money
- expected target income has doubled to £670,000.
As the Rushcliffe example shows, one important consideration when introducing new charges is to find the most cost effective way to recover those charges – for example charging at the point of use and using online systems – to avoid additional administrative costs associated with recovering debts. The legislation relevant to local authority trading uses the term ‘commercial purpose’ to describe trading activities. Government guidance suggests ‘commercial purpose’ means having a primary objective to make a profit from the trading activities in question.
In this guide, the term ‘trading’ is used much more broadly to cover a range of arrangements that councils might wish to enter into to make efficiencies through reducing costs; improving services for the benefit of users and, potentially, to generate profits. These may involve establishing new business relationships with other councils and public bodies or with the private sector, voluntary and community sector and individuals.
For councils considering a new trading venture it will be essential to first determine whether it is acting pursuant to a ‘commercial purpose’. If so, the law requires councils to pursue that commercial purpose via a company. If not, alternative arrangements to establishing a company are also explored below.
Trading within the public sector
The term ‘shared services’ in this guide means the provision of services from one public body to one or more others. The very important distinguishing feature of shared service arrangements is that such an enterprise will usually be exclusively comprised of public bodies who will not be seeking to sell services or goods to the general public or to any other party such as a private sector entity. In this way the market is contained, easily identified and limited in range and potential risk. The partners to such an arrangement will all be likely to be sharing the risk and rewards of the venture.
Shared service arrangements can be achieved either:
1. directly through a lead authority and joint committee arrangement, and/or
2. by agreement or contract, or
3. via a delivery vehicle such as a company.
4. The Local Government Act 1972, Section 101 permits local authorities to arrange for the discharge of their functions by a committee, sub-committee, an officer or by another local authority. Many shared service arrangements are set up under these public administrative arrangements, usually with one of the authorities involved taking the lead. The South West Audit Partnership
The South West Audit Partnership or ‘SWAP’ was formed in 2005 as a Joint Committee under the provisions of Section 101 of the Local Government Act 1972. The Partnership started with only two councils, although it was planned from the start for two more local authorities to join later in its first year of operation. The model chosen for the joint service delivery was originally intended for a relatively small partnership, for which the Joint Committee model is particularly well suited.
By working in partnership, SWAP aims to:
• provide a cost effective, high quality internal audit service to its partners • strive to reduce costs without any negative impact on service delivery • continually improve the quality of internal audit services to the partners • share best practice ideas observed during the internal audit process • ensure continuity of internal audit services to the partners in an equitable manner • continually seek to improve the standard of corporate governance, risk management and internal control systems for all partners • reduce net costs year-on-year. • complete 95 per cent of planned audits on time and on budget • attract new partners where it is beneficial both to the partnership and the prospective partner • obtain non-partner contracted internal audit work that represents 10 per cent to 20 per cent of the total partnership budget.
Changing environment
The world in which SWAP operates is changing rapidly and will continue to do so. The 2010 Comprehensive Spending Review cuts across government departments required savings averaging 20 per cent over four years. SWAP has expanded significantly over its six year existence and has 12 partner authorities spanning four county council areas. SWAP Management Board members are considering the appropriateness of the current governance model and the options for incorporating the undertaking by way of a ‘Teckal exempt’ in-house trading vehicle owned by the participating members of the partnership.
Local Partnerships’ options appraisal
Local Partnerships was commissioned by SWAP to assist with exploring the key options and issues, particularly in the light of the new powers and opportunities offered by the Localism Act 2011, to enable SWAP stakeholders and member local authorities to identify an option which most appropriately fits SWAP’s requirements. In the light of the full options appraisal carried out, SWAP are conducting a member review to determine whether the partnership should continue its business through the current joint committee structure or alternatively, whether it should establish a Teckal compliant, wholly owned corporate vehicle to conduct future business by and between its public sector clients. 2. The Local Authorities (Goods and Services) Act 1970 remains the bedrock for establishing shared service or joint arrangements between two or more public bodies through an agreement or contract. It permits councils to enter into ‘agreements’ with other local authorities or other designated public bodies, for the provision of goods, materials and administrative, professional and technical services, for the use of vehicles, plant and apparatus and associated staff, and for the carrying out of maintenance. These powers remain particularly useful where authorities are seeking to provide goods or services of a relatively modest value to each other, and the costs and time associated with setting up a commercial trading company would be disproportionate.
The 1970 Act leaves it to the public bodies concerned to use an ‘agreement’ to set out payment terms or otherwise that the parties consider appropriate. This offers flexibility and does not limit arrangements to simply cost recovery. Some councils have established shared services enterprises through a combination of public administrative arrangement such as a joint committee under section 101 of the Local Government Act 1972 and an agreement using 1970 Act powers.
Local authorities (and indeed other public bodies) can use these powers to ‘test the waters’ and explore whether collaborative arrangements can be established which make for more effective and efficient working.
Tax and fiscal considerations will also be paramount here, as setting up a company creates a new statutory body which may (depending on the type of company established and the trading activities it carries out) be subject to the corporation tax regime and will be treated separately for VAT, National Non-Domestic Rates (NNDR) and stamp duty land tax purposes.
Using an agreement or joint committee structure where the arrangements are established for the better performance of public administration may also provide a better fit with the limited exceptions from EU procurement rules, known as the Teckal exemption, which is briefly outlined below.
Overall this approach provides time for joint enterprises in the public sector to evolve through a joint committee arrangement and/or by agreement whilst retaining the option to establish a company structure at some later date, if desired.
What is a Teckal exemption? In simple terms the Teckal exemption means where an authority or authorities set up arrangements, including wholly owned companies to supply services back to those authorities, in the same manner as an in-house arrangement. In these cases the EU procurement rules do not apply to those arrangements. 3. Setting up a company is another route by which public bodies can establish shared services arrangements. Public bodies could, for example, establish a company to perform a trading function of a specific and limited nature to provide services to its member/owners. ‘Teckal’ compliance features would need to be built into the constitution of the company to ensure its operations and management remain in the control of the owner/members and that the company supplies the significant proportion of its business to those owner/members.
This type of ‘Teckal’ company would not be expected (or permitted) to trade commercially with the public at large. Local authorities creating a Teckal company need to very clearly articulate what sort of enterprise they are intending to establish and what sort of custom or ‘trade’ that company would undertake to distinguish it from a more market orientated commercial trading undertaking.
Commercial trading companies, unlike companies set up for trading by and between local authority members would be outward facing and would seek to attract business from any source.
The GPC powers might be used to establish a company which is set up for non-commercial public administrative functions and which is to be wholly under the control of its member local authorities/public bodies. The members should be able to engage with the company without going through a procurement exercise provided these arrangements are akin to ‘in-house’ arrangements to comply with the ‘Teckal’ exemption. How do European Union procurement, state aid and competition laws impact on trading activities between public bodies?
**EU Procurement issues**
In brief, the EU procurement rules, (as implemented in the UK by the Public Contracts Regulations 2006) require a procurement process to be followed for the award of certain public works, supplies and services contracts. There is no exception from the rules simply because public bodies wish to supply services to one another.
The EU case of Teckal (C-107/98) does however, provide an exemption from the application of the procurement rules for so called ‘in house’ arrangements, where:
- the contracting authority exercises a control over the goods, services or works provider which is similar to that which it exercises over its own departments (the ‘control test’) and
- at the same time, the provider carries out the essential part of its activities with the controlling contracting authority or authorities (the ‘function test’).
In Brent London Borough Council v Risk Management Partners Limited [2011] (‘Brent’) the Supreme Court held that insurance contracts could be placed with a shared services company jointly owned and controlled by a group of local authorities and that, following the Teckal case, those contracts did not need to be tendered via the Official Journal of the European Union (OJEU).
The Teckal exemption is likely to be very relevant to arrangements involving two or more public bodies which are set up to promote more effective or efficient public administration. However, the Teckal exemption is not likely to be applicable where a local authority establishes a commercial trading company (under the Localism Act or under the Local Government Act 2003 Section 95) to trade with the wider market. This is because the entity’s market orientation will cause it to not meet the function test referred to above. Such an entity will need to be operated at ‘arms length’ of the authority, with support costs or other assistance being recovered from the trading entity by the authority concerned.
**State aid**
If a local authority establishes a separate entity, namely a company, it may wish to consider providing financial assistance to that entity. In doing so, the local authority must have regard to state aid rules. This is a specialist area, where external advice is likely to be necessary. In outline, the State Aid rules are intended to ensure that market forces may operate freely across Europe with no unwarranted interference through the State (national government) or an ‘organ of the State’ such as a local authority. The following criteria must be met in order for State Aid issues to arise:
- the aid must have the potential of affecting competition and trade between Member States
- the measure granting aid must be capable of or have the effect of distorting competition by conferring an advantage or benefit on a selective basis • the aid must be paid through (directly or indirectly) state resources, and this can take a variety of forms such as grants, interest and tax reliefs, guarantees, government holdings of all or part of a company, or the provision of goods and services on preferential terms, and
• the aid favours certain undertakings, or the production of certain goods.
To avoid conferring a benefit, the authority must ensure that it does not indirectly subside the undertaking, and treats it at arm’s length in the same way as any other third party contractor. If a State Aid issue arises, the assistance proposed must be approved in advance by the European Commission through:
• the Commission approving a formal notification
• the assistance being compatible with an existing approved notified scheme, or
• the assistance being compatible with one of the State Aid block exemptions issued by the Commission.
The consequences of unlawful State Aid are potentially serious, including damages payable by the authority to any third parties who can show they have suffered a loss as a result of the aid, and recovery of the aid (plus interest) from the recipient.
**Competition law**
The requirement to use companies for trading under section 95 of the LGA 2003 and the Localism Act Section 4, places local authorities in the same position as any other commercial undertaking as to the need to meet costs and make a profit.
If a local authority trading operation were to prove successful, there could be some impact on local markets especially small businesses. The successful development of larger trading operations by local authorities however, could reasonably be expected to lead to new economic opportunities as well as possible disadvantages for small businesses, as suppliers or in specialist markets.
Authorities should consider any proposed charging and trading activities very carefully against the requirements of competition law, consulting their own lawyers as necessary. Trading by local authorities may be subject to the provisions in the Competition Act 1998 and/or Articles 101 and 102 of the Treaty on the Functioning of the EU (formerly Articles 81 and 82 of the EC Treaty). These articles set out rules on anti competitive practices and the abuse of a dominant position. New partners in the public sector
It is worth noting that the Localism Act has an impact not only on councils but also provides new powers for:
- **Parish and town councils**: ‘Eligible’ parish and town councils will also be able to use the General Power of Competence, which means these neighbourhood councils will have access to wider trading and charging powers.
- **Fire and Rescue Authorities (FRAs)**: Principal local authorities, including county councils will have access to the GPC. This includes the 15 county councils who are also fire and rescue authorities, as they are the principal local authority for the county and exercise significantly wider functions than stand-alone fire and rescue authorities. The Act also introduces a general power for single-purpose fire and rescue authorities (FRAs) and simplifies the existing charging regime for FRAs. This will allow them the freedom to do whatever they consider appropriate, where the outcome is intended to be beneficial to the delivery of their functions, integrate functions with other emergency services, and charge for non-core discretionary services. They can also exercise these new powers for a commercial purpose but if so doing, they must pursue such commercial purpose through a company or an industrial and provident society (as per principal authorities) (Sections 9 and 10 Localism Act 2011). Section 19 of the Fire and Rescue Service Act 2004 enables FRAs to charge and the Localism Act introduces some revisions to these provisions.
- **Integrated Transport Authorities (ITAs) and Passenger Transport Executives (PTAs)**: general purpose powers have been made available to these authorities under the Localism Act which include powers to trade through companies etc (Part 1 Chapter 3, Section 12 Localism Act 2011).
- **Economic Prosperity Boards and combined authorities**: again new general purpose powers and powers to trade through companies etc (Part 1 Chapter 3, Section 13 Localism Act 2011).
The General Power of Competence and new general powers for other types of authorities offer opportunities for innovative arrangements to develop between public sector agencies or with private sector providers or not-for-profit organisations to deliver more integrated, economical services leading to better outcomes for citizens. Trading beyond the public sector
After many years of experience trading between public bodies, the Local Government Act 2003 added new possibilities for councils to extend their trading activities to provide services to other users beyond the ‘defined public bodies’ listed in the 1970 Act. This includes the wider market, private individuals and other bodies or organisations. In 2009 the Government permitted all best value authorities1 in England “to do for a commercial purpose” anything which they are authorised to do for the purpose of carrying on their ordinary functions.
The Localism Act 2011 has extended opportunities to trade for a commercial purpose much further. For example the General Power of Competence (GPC) does not require councils to identify a statutory function upon which to ‘hang’ their trading activity. In other words, local authorities are allowed to expand their trading activities into areas not related to their existing functions. It also effectively removes geographical boundaries to local authority activity so that they can set up trading company that can trade anywhere in the UK or elsewhere. But the law continues to prevent councils trading with individuals where they have a statutory duty to provide that service to them already.
GPC also extend trading powers to ‘eligible parish councils’. These are defined by the Secretary of State in secondary legislation as parish councils who have:
- two-thirds or more of members of the council who have been elected at ordinary elections or at a by-election, as opposed to being co-opted or appointed
- a clerk to the parish council who holds one of the listed qualifications and has completed relevant training in the exercise of the GPC, provided in accordance with the National Association of Local Council’s national training strategy, and
- passed a resolution that it meets the other conditions of eligibility.
Under both the Local Government Act 2003 and Localism Act 2011, the power to trade must be exercised through a company. There are different definitions of ‘company’ in the relevant legislation but there appears to be no substantive difference between the types of entity permitted as trading companies, namely companies limited by shares, companies limited by guarantee or industrial and provident societies:
- Local Government Act 2003: refers to Part V of Local Government and Housing Act 1989
- Localism Act 2011: refers to the Companies Act 2006 s 1(1) or society registered or deemed registered under Co-operative and Community Benefit Societies and Credit Unions Act 1965.
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1 Which did not include parish councils. With trading companies wholly owned by a council, any profits generated may go back to the council through dividends or service charges. These can then be used to hold down council tax and/or can be invested into frontline services.
Local authorities may also consider participating in someone else’s trading venture through a company, such as a social enterprise, as long as that entity is a company within the relevant definitions. A limited partnership or limited liability partnerships do not fall within the permitted categories for local authority commercial trading.
Commercial trading and risk
All commercial activity involves risk and potential losses as well as the potential to make profits. These risks and opportunities must be fully understood and scoped before embarking upon such enterprises, with the potential to mitigate and manage these risks explored. A key part of this is the development of a business case. The 2009 Trading Order requires that a business case (‘a comprehensive statement’) be prepared and approved before exercising the trading powers. This covers objectives and associated investment and other resources required, business risks with an indication of their significance, and the expected financial results and any other relevant outcomes expected. It also places an obligation on the authority concerned to recover the costs of any accommodation, goods, services, staff or any other thing that it supplies to a company in pursuance of any agreement or arrangement to facilitate the exercise of the trading power. No similar requirement is currently contained in the Localism Act. In any event the rules on State Aid would need to be considered in this respect.
Other important legal, commercial and financial considerations for councils setting up a trading company include company law issues, the cost of bidding for contracts, tax liability (corporation tax and VAT), EU procurement law and state aid rules and employment law (TUPE and pensions). There also needs to be a business plan for the operation of the company. The Norse Group is a holding company owned by Norfolk County Council and has a combined turnover in excess of £250 million. The Group brings together three local authority trading companies providing services to councils, the NHS, the emergency services, housing associations, and numerous private sector organisations. Its three operating companies are:
- Norse Commercial Services Ltd providing facilities management
- NPS Group Ltd providing property design and management consultancy, and
- Norse Care Ltd.
Norse Care, the newest of the companies, provides 26 residential care homes and 13 ‘housing with care’ schemes across Norfolk and employs 2000 staff. Over the next 15 years, it will invest in and undertake a programme of reprovision of the Council’s current care accommodation, as part of the County’s pledge to meet the changing needs of its older population and the increasing demands on social care services.
The Norse Group, in partnership with Norfolk County Council, opted to form Norse Care Ltd to achieve a number of key outcomes including:
- **Revenue generation**: to find a more locally responsive and efficient way of delivering care to the elderly to meet their needs, whilst also generating income.
- **Employment flexibility**: recruiting and employing staff via the company provides the opportunity to introduce different terms and conditions that better meet modern business and employee needs.
- **Market moderation**: the trading vehicle provides an alternative to either in-house delivery of care services or outsourcing to a single large private sector provider.
- **Correct market failure**: creating the opportunity for occupational therapy, for which there were no local providers, to be delivered as part of social care services.
The arrangements have allowed the council to concentrate on its strategic commissioning role to assess local needs, design and procure appropriate services and monitor outcomes, whilst Norse Care concentrates on the delivery of a high quality public service.
The Norse Group expects the pay back to Norfolk County Council to grow to £5-£6 million over the next five years in the form of a profit share, and is a major employer in the region with over 10,000 staff.
The Norse Group and Norfolk County Council’s experience of starting to trade in this way has highlighted a number of key lessons including the need for:
- full political backing to provide both strategic and financial support to the venture
- sufficient cash flow to keep operating and the Council putting real money into the initial venture, and
- awareness that pension liabilities can potentially create a significant deficit on the opening balance sheet, which may make bidding for further work tricky.
These aren’t, however, insurmountable issues and the fact that the Norse Group is now made up of three companies illustrates this point, as well as highlighting opportunities for existing business infrastructure to make it easier to start local authority trading companies in the future. Other examples include:
**Essex Cares** was the first local authority trading company to offer social care services in the county. The company specialises in delivering support to adults across Essex providing:
1. community support: such as helping someone with a learning disability to improve their job prospects and independence
2. home support: such as installing grab rails to help them get in and out of the house.
In 2009 some 850 county staff were transferred to this business. During 2010/11 Essex Cares made a profit of £3.5million and within the same period over 115,000 people across Essex had contact and support from the company to enable them to maintain and improve their independence with services designed to meet their needs and choices. Key impacts included using individual outcome-focused support programmes to help 80 per cent of those referred to their Crisis Response service avoid being admitted to hospital.
**Solutions SK** is wholly-owned by Stockport Council. It provides a wide range of services ranging from facilities management, including catering, to highways and waste management. It was formed in 2006 from the council’s direct services department when some 1,000 staff transferred. Today, turnover is around £40 million.
**Swindon Commercial Services** has followed a similar path and provides a parallel range of services, including most recently the survey, design, installation and maintenance of domestic solar panels. It was established as a trading company early in 2010 and now employs over 850 dedicated and skilled employees with a turnover in excess of £65 million p.a. It provides services to a wide range of clients including local government, housing associations and private businesses in Wiltshire and beyond. Kent County Council (KCC) has a significant track record of undertaking trading activities including:
**KCC Commercial Services:** Commercial Services is the trading arm of Kent County Council, which sells and brokers in excess of £780 million per annum, supplying a range of goods and services to a wide customer base comprising local authorities and other publicly funded bodies. Commercial Services is a non-budget funded organisation providing a significant and growing financial return to Kent County Council. It provides a wide range of services including Kent County Supplies, Kent Fleet, Passenger Services, County Print and Design and LASER (energy buying group). Operating independently of Commercial Services, KCC supplies private and public sector customers with a range of services via Kent Top Travel and Kent Top Temps. Commercial Services is also exploring potential opportunities through the General Power of Competence.
**KCC Schools Personnel Service:** The Schools Personnel Service provides specialist advice and support on a range of personnel issues relating to both teaching and support staff, specifically tailored for the education sector. The service was established as a trading arm three years ago, providing personnel services to over 570 schools in Kent, charging a competitive market rate. It has since produced a surplus every year.
Moreover, it has created a model to expand for other schools support services; **EduKent** is a trading company that now provides a ‘one stop shop’ for schools and academies to buy all of the support services they need to run a school effectively. It has been developed in response to the rapidly changing educational environment, to meet the needs of schools and academies for high quality, competitively priced services delivered by experienced staff, to assist them in improving outcomes for their pupils.
**KCC Legal:** The ‘Kent Model’ of legal services delivery is nationally recognised as the leading exemplar and most successful trading operation of its kind anywhere in the country, with a significant revenue of more than £1 million per year. It already supplies legal services direct (without a company structure) to any organisation to which KCC is statutorily empowered to provide services. That currently effectively means the whole of the public sector except central government. Checklist for councils
Has your council:
• Carried out a **fundamental review** of its activities – in conjunction with local partners – and as part of that looked at use of trading and charging powers?
• Adopted a **policy** on trading and charging that is aligned to council strategy and a delivery plan?
• Considered how a move to greater commercialism will impact on the current and future workforce of the council and what **training and development** may be needed?
If you are considering introducing a new charging scheme or trading in a new way, have you:
• Carried out **option appraisals** (including early legal, financial, tax, HR advice and market research)?
• **Consulted** with service users and the wider community where the council proposes to introduce new charges (particularly for services that have previously been provided for free)?
• **Effectively engaged employees** where new trading activities are likely to involve transferring existing council employees to a company?
• Approved a **business case** for selected options (especially where this is a statutory requirement) and an operational **business plan**?
**Contacts**
Rob Hann\
Director, Legal Services\
Local Partnerships\
Local Government House\
Smith Square\
London SW1P 3HZ\
Telephone 07768 906 391\
Email [email protected]\
www.localpartnerships.org.uk
LGA Localism Programme Team\
Local Government House\
Smith Square\
London SW1P 3HZ\
Telephone 020 7664 3000\
Email [email protected]\
www.local.gov.uk Further reading
‘General Power for Best Value Authorities to Charge for Discretionary Services’, ODPM, 2003
‘General Power for Local Authorities to Trade in Function Related Activities Through a Company’, ODPM, 2004
And the Addendum to that Guidance issued in April 2007, [NB. To be read in light of 2009 Trading Order]
‘Using the New Powers to Trade and Charge: Local Authority Case Studies’, LGA, 2005
‘Local Authority Trading: Research Report’, CLG (INLOGOV), 2007
‘Positively Charged: Maximising the Benefits of Local Public Service Charges’, Audit Commission, 2008
‘SI 2009/2393, The Local Government (Best Value Authorities) (Power to Trade) (England) Order 2009’ [2009 Trading Order]
‘Joint Ventures: A Guidance Note for Public Sector Bodies Forming Joint Ventures with the Private Sector’, HM Treasury, 2010
Capital investment, regeneration and joint ventures – Local Partnerships Guidance for Local Authorities 2011 www.localpartnerships.org.uk
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4c657c6dad6a74e95a0960cedf92b02fe524d169 | Dear Len
Rail Industry Environmental Performance Indicators
Thank you for your letter of 17 December 2008 updating me on progress in developing the environmental indicators the industry committed to produce in December 2007.
We look forward to receiving the outstanding environmental indicators and associated commentary in the revised timescales indicated and continuing to work with the industry through the Rail Sustainable Development Group to achieve this.
Yours sincerely
Bill Emery
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127000540275f49cf23034b9918bd8114a344ee7 | Mr Bill Emery\
Chief Executive\
Office of Rail Regulation\
One Kemble Street\
London WC2B 4AN
17 December 2008
Dear Bill
Rail Industry Environmental Performance Indicators
This letter follows on from our letter of December 2007 setting out the industry’s proposals for the development of environmental indicators to be potentially reported to the Office of Rail Regulation (ORR).
In the previous letter the industry proposed reporting on two environmental indicators immediately and an expanded set of environmental indicators after further development work. This letter updates progress in both of these areas.
Environmental Indicators proposed for immediate reporting\
The indicators proposed were:
- Total traction energy consumption (aggregated) and
- Total carbon dioxide emissions from traction energy (aggregated).
A protocol has been developed by an industry working group, facilitated by RSSB, which defines these indicators and the process for collecting data. This was agreed within the industry and with the ORR and approved by the Rail Sustainable Development Group (RSDG) at the 18 June 2007 meeting. The rail industry has supplied data for these indicators covering the years 2005-06 and 2006-07 which were published in ORR’s National Rail Trends Yearbook 2007-2008, beginning a cycle of annual reporting.
Environmental indicators proposed for potential reporting to ORR in the future\
The industry proposed the following list of indicators for potential future reporting to ORR after further development.
- Traction energy efficiency and carbon intensity indicators
- Air emissions
- Noise impact
18/12/08
- Non traction energy consumption
- Non traction carbon intensity
- Waste material generated
- Water consumption
Table 1 in Appendix A provides a detailed update on their development.
If you have any queries on this submission or require further detail please do not hesitate to contact me.
Yours sincerely
Len Porter
c.c. Members of the Rail Sustainable Development Group APPENDIX A
Table 1 – Progress on the development of proposed future environmental indicators
| Issue | Indicator as defined in December 2007 letter | Work originally thought to be required 2007 | Original timescale | Progress and proposed way forward 2008 | |--------------------------------------------|---------------------------------------------|---------------------------------------------|--------------------|----------------------------------------| | Short term | | | | RSSB facilitated the creation of a working group to develop the protocol for this indicator. The protocol for the collection of passenger data has now been developed and was approved at the RSDG meeting on the 6th November 2008. This data will be provided annually to ORR at the same time as total traction energy consumption and carbon emissions. Data for this indicator covering the years 2005-06, 2006-07 and 2007-08 will be provided to ORR in early 2009. The working group concluded this indicator is not of relevance to rail freight operations as it is more concerned with separating energy efficiency from increased passenger loading on passenger services. RSDG agreed this at their 6th November 2008 meeting. | | Traction energy efficiency and carbon intensity indicators | This indicator will aim to illustrate the energy efficiency and carbon intensity of rail operations per se, independent of passenger numbers or freight volume. For example energy normalised by seat km. | Work is required to develop the data to normalise energy consumption data in this way. | It has been agreed that data reporting for the industry voluntary commitment will be complete by the end of Quarter 3 2008. | | | Issue | Indicator as defined in December 2007 letter | Work originally thought to be required 2007 | Original timescale | Progress and proposed way forward 2008 | |---------------|---------------------------------------------|---------------------------------------------|--------------------|---------------------------------------| | Short term continued | | | | | | Air emissions | Likely to include average GB rail emissions figures for CO, SO₂, NOx and PM. These can be calculated using the energy consumption data and conversion factors. The conversion factors must be agreed within the industry and the accuracy of calculating at such a high level tested prior to the industry’s first reporting cycle. | This indicator requires work on collection procedures and conversion factors. | Data likely to be ready for reporting in Aug 2008 | RSDG created an Air Quality Working Group (AQWG) to look at the development of this indicator. This group reported back to RSDG on 6th Nov 2008. The AQWG identified that emissions factors are available to calculate all emissions from electric traction and SO₂ emissions from diesel at present. However, reliable, accurate emissions factors have not been found for the calculation of all other emissions from diesel traction. It is scientifically possible to carry out a measurement programme to obtain accurate emissions factors but the AQWG’s review has estimated that this would be cost prohibitive and deliver no operational benefit to the industry over and above improvements being driven by legislation. RSDG have requested that the AQWG look again at the issue of conversion factors, commissioning research if necessary, to establish the validity of available conversion factors. It is anticipated that they will report back to RSDG in early 2009. RSDG also agreed that no emissions reporting should be carried out until a full suite is available. | | Issue | Indicator as defined in December 2007 letter | Work originally thought to be required 2007 | Original timescale | Progress and proposed way forward 2008 | |-------|---------------------------------------------|---------------------------------------------|-------------------|---------------------------------------| | Short term continued | | | | RSDG will update the ORR on proposals for emissions reporting after the AQWG reports back to RSDG in early 2009. | | Air Quality cont’d | | | | | | Noise impact | This indicator should show the number of people affected by rail noise above a threshold level. The indicator and the threshold level would be drawn from the DEFRA and Scottish Government Strategic Noise Mapping exercises which is based on their noise calculation model. | The data for this indicator is being produced in response to the timescales for the Environmental Noise Directive. It is assumed that the ORR can obtain the noise data direct from DEFRA and the Scottish Government. | The data for Scotland is available now. Timescales for England and Wales are not clear but their mapping should be complete by the end of 2007 to comply with the END timescales. The availability of this data is completely dependant on the national mapping programmes. | Noise issues are being monitored for the industry by the Railway Forum Noise Working Group (which is attended by representatives from RSSB, RSDG, ORR, ATOC and others). Strategic noise maps were published as follows: - Scottish Government (SG) - Sept 2007 - Defra (for England) - May 2008 - Welsh Assembly Gov’t (WAG) - June 2008 The SG is currently consulting on draft noise action plans. The WAG is currently consulting on the noise action planning process and Defra is soon to commence a similar consultation. At present the Governments’ final use of the data in the maps is unclear and it is hoped this will be clarified by the consultation from Defra. It is anticipated further clarification will determine what the data is suitable for and any proposed threshold levels. Until this becomes clearer the development of the indicator cannot progress. Once all of these issues are clarified RSSB will facilitate the development of a protocol | | Issue | Indicator as defined in December 2007 letter | Work originally thought to be required 2007 | Original timescale | Progress and proposed way forward 2008 | |-------|---------------------------------------------|---------------------------------------------|-------------------|--------------------------------------| | **Medium term** | | | | | | Non traction energy consumption & Non traction carbon intensity | It is proposed that the non-traction energy and carbon indicators will be based on data collected in response to the Carbon Reduction Commitment (CRC) scheme currently being discussed with Defra. | Defra's current proposals require energy reporting for all sites with annual electricity consumption from mandatory half hourly meters in excess of 6,000 MWh. Non-traction CO₂ emissions would be calculated from this data. | It is anticipated that data reporting for non-traction energy will be aligned to the requirements of the CRC scheme which are yet to be finalised. | This has been addressed by a working group who concluded that this work should be aligned to CRC reporting timescales. It is anticipated that the reporting will be required, for the first year's emissions, by end July 2011, which will cover the period Oct 2009 to March 2010. Once the process is clear RSSB will facilitate the development and approval of a protocol to clarify the reporting of this data to ORR. | | **Longer term** | | | | | | Waste material generated & Water consumption | Not yet defined. | These indicators are at a much earlier stage in development and require the development of definitions and a more detailed understanding of the feasibility and resource implications of data collection. | It is proposed that further work is done by the industry on potential waste and water indicators and that RSSB and RSDG brings forward more detailed proposals in spring 2009. | Further thinking on these indicators is planned for presentation to RSDG in Spring 2009. |
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a5d51e7ff915ec4c0336f613625bc75920dae698 | Environment Agency Information Management Assessment: statement on closure of action plan
The National Archives undertook an Information Management Assessment of the Environment Agency in May 2009. A report was published on The National Archives highlighting 31 recommendations. An action plan was subsequently developed by the agency.
The National Archives’ report rated the Environment Agency as “Good” under five out of 20 headings and “Satisfactory” under a further seven. The report identified eight headings where particular attention was needed and where further work would improve the agency’s all-round performance.
A formal review of progress against the agency’s action plan was held on 2 June 2010, with improvement recognised by The National Archives under four out of 20 headings. Further action plan review meetings were held in February and December 2011 at which the agency’s efforts to tackle areas of concern and raise the profile of information management were outlined. Following these, it was mutually agreed that the agency had made sufficient progress for the action plan to be closed. Remaining issues will be taken forward via regular progress meetings with the agency’s Information Management Consultant.
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bd9b94042f63f57c984f3f9c73c2d0545580de94 | Options for Mitigation of Groundwater flooding
1. **Controlling Groundwater Levels in the Subsurface**
Engineering solutions to mitigate groundwater flooding are limited because of the large volumes of water and spatial areas involved, and because it is not contained or channelled.
**Pumping:**
Wide scale dewatering of chalk (or other) aquifers by pumping are not a viable option. Lowering the risk of flooding over large areas will not be effective due to the constraints of well installation/design and operation coupled with the sheer volume of water involved. In addition there would be significant logistical problems associated with dealing with the discharges (where you pump the water to).
The opportunity to reduce flooding by pumping groundwater will be very site specific. The cone of depression (the area in which groundwater is lowered), generally ranges from a few hundred meters to a few kilometres depending on the nature of the local aquifer (storage/permeability) and the ability to pump harder without compromising the borehole (moving the packing material/mobilising turbidity etc.).
Pumping is generally only possible with a specifically designed well field to enable cones of depression to overlap. Clearly it would not be possible to drill a large number of bespoke boreholes for this purpose and the existing borehole sites may only occasionally be situated at sites which may benefit from dewatering.
Pumping would be impractical on any large scale but it may be worthwhile for LLFAs to work with Water Companies and other key infrastructure providers to:
a) Identify if there are any candidate sites in existence where boreholes and pumping systems are already in place (e.g. a public water supply site upstream of a village with groundwater flooding). If such sites exist then consideration can be given to setting up potential pilot studies.
b) Consider based upon the impact and threat to existing infrastructure (electricity, gas, water etc.) whether a site-specific groundwater control/dewatering scheme could be viable in future as a contingency measure to increase resilience. 2. **Controlling Groundwater levels at the Surface**
Where groundwater emerges as a spring it will rapidly inundate low lying areas and begin to flow following the local topography/ground levels. Impacts not immediately above the point of emergence can thus be protected in the same way as handling surface water flooding. Options exist therefore for:
- Channelling and diverting the flow of water at the surface away from sensitive downstream receptors.
- Dealing with “pinch points” where water is forced through a narrow corridor such as an existing culvert – causing water to backup and flood the vicinity.
By capturing data on the extent and behaviour of groundwater flooding within their areas during the current incident, Lead Local Flood Authorities can identify alternatives for potential overflow/diversion channels and dealing with “pinch points”.
3. **Controlling Recharge to Aquifers**
Some of the options for management of upland areas that would have an effect on mitigating surface water flooding may (to a lesser degree) have an impact on controlling the recharge of water into aquifers and hence the potential for groundwater flooding.
Wetlands may prevent flooding by functioning as natural sponges that trap and slowly release groundwater. Woodlands may act to decrease the rate of recharge during the spring and summer due to evapo-transpiration and may increase soil moisture deficits having the effect of shortening the period over which recharge is most effective.
4. **Dealing with the Consequences of Groundwater Flooding**
**Strategic Actions:**
Following 2012/13 groundwater flooding event in West Dorset, Dorset County Council commissioned their own investigation of the causes of flooding in the villages of Martinstown, Winterbourne Steepleton and Winterbourne Abbas. The purpose of the study was to improve understanding of the flood risks in the area and to identify possible measures for flood alleviation. The following recommendations were made to improve management of flood risk across all three villages:
- A Community Flood Action Group to be formed to create a representative voice for flood concerns for the community and to share responsibility for management and maintenance of the South Winterbourne.
- Household level flood protection to be implemented to protect individual properties against groundwater, surface water and fluvial flooding. • The potential for encouraging improved land management techniques in the catchment to reduce flood risk in the catchment to be explored, working in collaboration with Wessex Water and other potential partners such as the West Countries River Trust and the Farming and Wildlife Action Group South West.
• Additionally, specific recommendations were made to improve management of flood risk for each village.
We would recommend that a similar approach is adopted by LLFAs as part of the recovery phase from this incident.
**Site Specific (Property Owner) Actions:**
Property owners and specifically householders can be encouraged to help themselves. Joint badged LGA / EA Advice is already available via our website (See [http://www.environment-agency.gov.uk/static/documents/Leisure/flho0911bugi-e-e.pdf](http://www.environment-agency.gov.uk/static/documents/Leisure/flho0911bugi-e-e.pdf)).
The advice includes the following:
• Floors, lower parts of walls and openings such as airbricks are the most vulnerable parts of properties and can be sealed to prevent or limit water entry. • Sump and Pump Systems can be operated at basement and ground floor levels in buildings, but can only have a localised effect and may not be effective with large volumes of groundwater. • Foul drainage (waste from sinks, baths and toilets) - Foul sewage systems often back up and causes problems during ground water flooding.
Contingency measures include:
• Main drainage systems - range of non-return valves are available which may be able to help a continuing problem with sewage flooding. • Septic tanks and cess pits - trap solids and then discharge semi-treated fluid to soak away or land drains. Adding a pump to the outlet side of the tank may help and pump the sewage to high ground above the groundwater table. • Cess pits are sealed tanks which store five or six week’s worth of waste and are better protected with a concrete surround.
Other specific measures for property owners include the following, but their effectiveness will depend on the pressure exerted by the groundwater level:
• Basements - ‘Tanking’ materials can be applied on the outside walls to seal the walls, but this can increase water pressure which may cause structural damage • Floors - A replacement floor constructed to a high standard with reinforced concrete and with a continuous damp proof membrane can be effective where groundwater pressures are low. • Suspended floors - constructed with concrete (often by raising floor levels) can create a void beneath the floor which will flood before water rises to enter the house.
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2cd9aea9b65b23597970ba4f5c630b9f096512dd | Digitisation at The National Archives
Last updated: August 2016
© Crown copyright 2016
You may re-use this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence
Where we have identified any third-party copyright information, you need to obtain permission from the copyright holder(s) concerned.
This publication is available for download at nationalarchives.gov.uk. Digitisation at The National Archives
Contents 1 Introduction ........................................................................................................................................... 4 1.1 Who is this document for? ............................................................................................................. 4 1.2 References .................................................................................................................................... 4 2 Document handling during the scanning process .............................................................................. 5 2.1 Preparing documents for scanning ............................................................................................... 5 2.2 Document handling training .......................................................................................................... 5 2.3 Support of documents .................................................................................................................... 5 2.4 Page turning, unfolding corners .................................................................................................... 5 2.5 Staples, pins, paperclips ................................................................................................................ 6 2.6 Handling seals ............................................................................................................................... 6 2.7 Keeping documents in order .......................................................................................................... 6 2.8 Annotation and labelling ............................................................................................................... 6 2.9 The scanning area ........................................................................................................................ 7 2.10 Use of gloves, tools, cleaning liquids and related items ............................................................... 7 3 Scanning equipment .......................................................................................................................... 7 4 Image capture and quality .................................................................................................................. 8 5 File format ........................................................................................................................................... 8 5.1 Colour space .................................................................................................................................. 8 5.2 Compression .................................................................................................................................. 8 5.3 Resolution .................................................................................................................................... 9 5.3.1 Embedded Capture Resolution Information ........................................................................... 9 5.3.2 Result of calculations in both examples .................................................................................. 10 5.4 Physical dimensions ...................................................................................................................... 11 6 JPEG2000 profile for a digitised record ............................................................................................ 11 7 Converting master images (TIFF and so on) to JP2 for digitised records ........................................ 12 8 JPEG2000 profile for a digital surrogate .......................................................................................... 13 9 Converting master images (TIFF and so on) to JP2 for digital surrogates ....................................... 13 10 Metadata .......................................................................................................................................... 14 1 Introduction
This document sets out The National Archives' standards and requirements for the digitisation of analogue records in our collection. It covers the whole digitisation process from initial scanning through to delivery of the images for preservation, including The National Archives' scanned image specification (see sections 6 and 8).
This document covers the scanning of records where the resultant images will become the legal public record for permanent preservation. For purposes of clarity we refer to these images as digitised records. This document also covers the scanning of records where the resultant images will become digital surrogates with the original paper records being retained and remaining the legal public record. For purposes of clarity we refer to these images as digital surrogates.
1.1 Who is this document for?
We recommend that government departments who wish to digitise any of their paper records follow the processes set out in this document. Please contact your Information Management Consultant (IMC) for further information if it is likely that these records will be transferred to The National Archives at a future date. Other organisations are welcome to use this document for reference when developing their own standards for digitisation.
For further information regarding digitisation projects at The National Archives, please contact the Digitisation and Data Conversion Manager: [email protected]
For any queries about the technical aspects of this document please contact: [email protected]
1.2 References
In preparing the technical imaging and metadata standards The National Archives have had regard to the following (and other standards referred to therein):
- BS 10008:2008 Evidential weight and legal admissibility of electronic information. Specification
- The Archives New Zealand/Te Rua Mahara o te Kāwanatanga Digitisation Toolkit: http://archives.govt.nz/advice/guidance-and-standards/guidance-subject/digitisation-toolkit
- The Minimum Digitization Capture Recommendations from ALA http://www.al.org/alcts/resources/preserv/minimum-digitization-capture-recommendations
- US FADGI Guidelines: Technical Guidelines for Digitizing Cultural Heritage Materials
- Netherlands: http://www.metamorfoze.nl/english/digitization
- In drawing up our specifications for surrogates we have also reviewed published information by 2 Document handling during the scanning process
The guidance in this section is drawn from widely accepted standards for handling archival records. The restrictions recommended for ‘the scanning area’ will be familiar from standard document reading room restrictions.
2.1 Preparing documents for scanning
Ideally a professional conservator will carry out this preparation and will:
- assess the condition of the records to ensure documents are not too fragile for scanning. As well as general fragility you should look for mould, pages stuck together and inserts obscuring records
- assess the condition of records, looking for any damage which has affected the legibility of the text
- remove any staples
2.2 Document handling training
New scanning operators should undergo document handling training by the conservator(s) prior to handling any documents and receive annual refresher training thereafter
2.3 Support of documents
- Use both hands at all times when moving boxes and documents.
- Ensure scanning beds are large enough to support the whole document.
- Never leave documents exposed on the scanner when unattended.
- Support books and other bound documents with a book cradle or book wedges.
2.4 Page turning, unfolding corners
- Turn pages from the fore edge (right edge) of the document not from the tail (bottom) edge.
- It is not acceptable to use moisture (including licked fingers) for page turning.
- Do not pinch document corners together to turn the page.
- The scanning operator should unfold folded corners but should not then fold them back on themselves. • Where documents are attached to each other and cannot be separated, scan the document in a way which prevents the introduction of new creases.
2.5 Staples, pins, paperclips
• Ideally a conservator should have removed all varieties of staple as part of the process of preparing the documents for scanning. If any have been missed, inform the conservator(s). • Scanning operators should remove pins, split pins and paperclips carefully but removal should not be forced if this will cause damage. • Cut all treasury tags immediately prior to scanning and replace them with appropriate length nylon ended tags as soon as the file is scanned. • The tag should be at least three times as long as the depth of the pile of papers.
2.6 Handling seals
• Take care with applied and pendant seals as they are fragile. They must not be knocked or have weight or pressure applied to them. Neither should they be left to hang off the edge of a workstation. • Do not use glass without adjustments approved by the conservator(s) (for example, lowering the document bed, putting blocks under the glass so there is no weight on the document). The same applies to documents with pigments.
2.7 Keeping documents in order
• The contents of boxes should stay together and stay in the sequence in which they came from the box. • Work on only one document at a time so that boxes and documents do not get mixed up. • Replace documents in closed boxes at the end of the day and return them to storage.
2.8 Annotation and labelling
• Annotation or labelling of any part of a document, including the box, is not permitted. Do not use sticky (Post-it®) notes or similar to mark documents. You can use paper markers, provided that you remove them from the document after scanning. 2.9 The scanning area
- Scanning operators’ workstations should provide adequate surface area to ensure the full support of documents and allow for an organised workspace. Too little space can have a negative impact on document handling.
- Keep the scanning area clean and tidy - keep bags and coats in lockers and do not take them into the scanning area.
- No food or drink (including chewing gum) should be permitted in the scanning area.
- You may use pencils only - without erasers. No pens or correction fluid are permitted.
- Do not use hand and face moisturisers, moisturising wipes, lip balms or anything similar that is applied by hand.
- Hands should be clean and dry at all times whilst handling documents.
2.10 Use of gloves, tools, cleaning liquids and related items
- Do not wear cotton gloves or powdered gloves
- You may wear unpowdered nitrile/latex (or similar) gloves if instructed specifically by the conservator(s), for example, for photographic material.
- Do not use handling aids such as rubber thimbles and other tools unless approved by the conservator(s).
- Do not use cleaning liquids unless approved by the conservator(s).
Note: if any damage to documents is found during scanning bring this to the attention of the conservator(s) for repair before scanning takes place.
3 Scanning equipment
The National Archives approves scanning equipment for each project.
In general, The National Archives considers overhead cameras and scanners with a flat scanning bed suitable for scanning. You may use supported glass except in cases where the material may be at risk. You may only use flatbed scanners and automatic feed scanners with the approval of the conservator(s).
Similarly, the conservator(s) must approve the use of weights prior to scanning. Lights should not generate too much heat; ideally use cold light sources. Brightness levels must not have a negative impact on the health and safety of operators. 4 Image capture and quality
- Images should be de-skewed as necessary to achieve nominal skew of not greater than one degree.
- All digital images should be legible and at least as readable as the original image from which they are derived.
- Final images should be single page, unless information crosses both pages.
- All images should be viewed immediately after scanning as a check on satisfactory capture (for example images complete or not inverted) and rescanned if required.
5 File format
Sections 5 to 8 set out the technical specification The National Archives uses for producing scanned images of analogue records. Please note that this specification reflects the requirements of The National Archives and may not be suitable for implementation in other organisations.
From March 2013 all records digitised at, or for, The National Archives will be delivered for preservation as JPEG 2000 part 1 files conformant with the latest version of ISO/IEC 15444-1 JPEG 2000 part 1 and saved with the extension .jp2. If scanning software does not produce .jp2 files natively, images must be converted from a suitable intermediate file format to expected resolution and quality standards. See sections 7 and 9.
Access to the original images (for example, TIFFs) should be maintained until the master JP2 images are signed off.
5.1 Colour space
Scan images in 24 bit colour using the Enumerated sRGB colourspace profile, or for microform material in 8 bit grayscale using the Enumerated greyscale colourspace profile.
5.2 Compression
Use lossless compression for digitised records (where sole access is to be provided via the scanned image).
Lossy compression is acceptable for digital surrogates (where the original paper records are to be retained as the primary record). See section 6 below. 5.3 Resolution
Requirements as to Pixel per inch (PPI) vary according to the format of the material to be scanned:
- use a default of 300 PPI for ordinary documents
PPI should be considerably higher for any photographic media:
- photographs should be at 600 PPI
- photographic transparencies should be at 4000 PPI
For microform the requirement should be for a resolution equivalent to 300 PPI at the size of the original document. If this is not physically possible we would agree on the maximum feasible resolution.
5.3.1 Embedded Capture Resolution Information
Image capture resolution information should be written to the JP2’s ‘Capture Resolution Box’. This is held within the parent ‘Resolution Box’, which is located within the ‘JP2 Header Box’. The Capture Resolution Box specifies the resolution at which the source was digitised, by flatbed scanner or other device, to create code-stream image samples. Resolution is detailed by way of a set of values written to the following parameters:
- vRcN = vertical grid resolution numerator
- vRcD = vertical grid resolution denominator
- vRcE = vertical grid resolution exponent
- hRcN = horizontal grid resolution numerator
- hRcD = horizontal grid resolution denominator
- hRcE = horizontal grid resolution exponent
The parameter values are used by the following calculations to state Vertical Resolution capture and Horizontal Resolution capture values (‘VRc’ and ‘HRc’):
[ VRc = \\frac{vRcN}{vRcD} \\times 10^{vRcE} ]
[ HRc = \\frac{hRcN}{hRcD} \\times 10^{hRcE} ]
The parameter values written may vary by numerator value and the relative adjustment of denominator and exponent, but the resulting values of ‘VRc’ and ‘HRc’ by calculation must return the correct image resolution values – measurements stated in ‘Pixels Per Meter’ from which Pixels Per Inch values can be derived (1 pixel per meter = 0.0254 pixels per inch.)
Two examples of different, but correct values for a 300 PPI (Pixels Per Inch) image are shown below:
Example 1:
- vRcN: 30000
- vRcD: 254
- hRcN: 30000
- hRcD: 254
- vRcE: 2
- hRcE: 2
Example 2:
- vRcN: 300
- vRcD: 254
- hRcN: 300
- hRcD: 254
- vRcE: 4
- hRcE: 4
5.3.2 Result of calculations in both examples
Example 1:
[ VRc = \\frac{VRcN}{VRcD} \\times 10^{VRcE} ]
[ \\frac{30,000}{254} \\times 10^2 = 11811.02362204724 \\text{ PPM} ]
[ 11811.02362204724 \\times 0.0254 = 300 \\text{ PPI} ]
Example 2:
[ VRc = \\frac{VRcN}{VRcD} \\times 10^{VRcE} ]
[ \\frac{300}{254} \\times 10^4 = 11811.02362204724 \\text{ PPM} ]
[ 11811.02362204724 \\times 0.0254 = 300 \\text{ PPI} ] Confirmation of correct values can be made by running a Jpylyzer validation report, which will return written values and confirm image resolution detail by calculation. An example tag-set with values from such a report is given below:
```xml
<resolutionBox>
<captureResolutionBox>
<vRcN>300</vRcN>
<vRcD>254</vRcD>
<hRcN>300</hRcN>
<hRcD>254</hRcD>
<vRcE>4</vRcE>
<hRcE>4</hRcE>
</captureResolutionBox>
</resolutionBox>
```
The Per Meter and Per Inch values below are calculated by Jpylyzer from the above parameter values:
```xml
<vRescInPixelsPerMeter>11811.02</vRescInPixelsPerMeter>
<hRescInPixelsPerMeter>11811.02</hRescInPixelsPerMeter>
<vRescInPixelsPerInch>300.0</vRescInPixelsPerInch>
<hRescInPixelsPerInch>300.0</hRescInPixelsPerInch>
```
There are JP2 encoder software tools available (such as Kakadu, v7 onwards) that can automatically populate the JP2’s Capture Resolution Box with the horizontal and vertical (x and y) Pixels Per Meter image resolution values, which can then be read from the file by software viewers and image editing tools. There are also imaging SDKs (such as ImageGear for .Net) that can be used to build configurable toolset implementations to achieve the same results.
### 5.4 Physical dimensions
- All scans should be size-for-size (for microfilm this refers to the size of the original), with a sufficient clear border/margin to demonstrate to users that the entire page has been captured.
- If a single scan cannot capture the page in its entirety, there should be sufficient overlap to allow users to determine clearly which of the separate digital images form the whole of the original paper page.
### 6 JPEG2000 profile for a digitised record
The most important aspect of this profile is the use of lossless compression (the 5-3 reversible transform). We have chosen not to lose any data because the images will become the legal Public Record. As individual tiles in a JPEG2000 image may use different compression methods we stipulate a single tile to make verification of the compression method more straightforward. | JPEG2000 option | Value | |----------------------------------|----------------------------------------------------------------------| | Standard: | JP2 Part 1 | | Transform: | 5-3 reversible (lossless) | | Compression ratio: | N/A | | Levels: | 7 | | Layers: | 1 | | Progression: | RPCL | | Tiles: | Not defined (single tile) | | Bypass: | Selective | | Colour-space: | Enumerated sRGB profile | | Embedded Capture Resolution | Vertical Resolution and Horizontal Resolution values as appropriate to the document | | Information: | | | Code block size | N/A | | Precinct size | N/A | | Regions of interest | N/A | | Tile length markers | N/A |
7 Converting master images (TIFF and so on) to JP2 for digitised records
We have anticipated that the application of the conversion from a suitable intermediate file format of expected resolution and quality standards will be automated and that JP2 encoder parameters would result in a profile matching The National Archives standard for digitised records, and could be incorporated in a script. 8 JPEG2000 profile for a digital surrogate
For digital surrogates use lossy 6:1 compression. However, compression ratio values may vary, depending on the characteristics and visual complexity of the documents to be scanned.
| JPEG2000 option | Value | |--------------------------|----------------------------------------------------------------------| | Standard: | JP2 Part 1 | | Transform: | 9-7 irreversible (lossy) | | Compression ratio: | Default 6:1 | | | It is expected that the minimum compression will be 4:1 and the maximum 10:1 depending on the nature of the original material | | Levels: | 7 | | Layers: | 1 | | Progression: | RPCL | | Tiles: | 1024x1024 pixels | | Colour-space: | Enumerated sRGB profile | | Embedded Capture Resolution Information: | Vertical Resolution and Horizontal Resolution values as appropriate to the document | | Bypass: | Selective | | Code block size | N/A | | Precinct size | N/A | | Regions of interest | N/A | | Tile length markers | N/A |
9 Converting master images (TIFF and so on) to JP2 for digital surrogates
In the above table we have anticipated that the application of the conversion from a suitable intermediate file format of expected resolution and quality standards will be automated and that JP2 encoder parameters would result in a profile matching The National Archives standard for digital surrogates and could be incorporated in a script. 10 Metadata
10.1 Embedded metadata
The National Archives requires that a small amount of metadata should be embedded within the image file itself. This metadata is designed to assist in the long-term management of the images by making them easier to identify.
This metadata comprises:
- a copyright statement; this is usually a statement of Crown Copyright as used in the example below, or a statement indication of third party copyright
- a universally unique identifier (UUID) created for each image, see below
- a uniform resource identifier (URI) which allows us to reference the image uniquely
This metadata should constitute a well-formed XML document, which can be validated against an XML Schema provided by us - see example below. The UUID should be a uniquely generated Version 4 UUID, see below.
The image must remain a valid JPEG2000 image after the metadata has been embedded.
10.1.1 Example of embedded metadata in xml
```xml
<?xml version="1.0" encoding="utf-8"?>
<DigitalFile
xmlns="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
xmlns:xsi="http://www.w3.org/2001/XMLSchema-instance">
<UUID>c87fc84a-ee47-47ee-842c-29e969ac5131</UUID>
<URI>http://datagov.nationalarchives.gov.uk/66/WO/409/27@1/c87fc84a-ee47-47ee-842c-29e969ac5131</URI>
<Copyright>© Crown copyright: The National Archives of the UK</Copyright>
</DigitalFile>
```
10.1.2 Explanation of the URI
The URI (for example, see www.ietf.org/rfc/rfc3986.txt) is formed from The National Archives’ reference data domain (currently datagov.nationalarchives.gov.uk) followed by a code that represents The National Archives in its Archon directory of archival repositories (or another repository if public records are held elsewhere under The National Archives’ Place of deposit rules), followed by the catalogue reference to Digitisation at The National Archives
piece level (please note that the ITEM level should not be included in file embedded metadata), and the UUID of the image:
- URI Description: {TNA DOMAIN}/{TNA ARCHON No.}/{DEPT}/{SERIES}/{PIECE}/{UUID}
- example Base String: http://datagov.nationalarchives.gov.uk/66/AIR/79/18727/
- example UUID: c87fc84a-ee47-47ee-842c-29e969ac5131
So the full Reference URI would be:
http://datagov.nationalarchives.gov.uk/66/AIR/79/18727/c87fc84a-ee47-47ee-842c-29e969ac5131
10.1.3 Creating the UUID
UUIDs must be compliant with the specification for Version 4 UUIDs as outlined in RFC4122: www.ietf.org/rfc/rfc4122.txt. Utilities are available to create such UUIDs. You should express UUIDs in lower-case hexadecimal format. These should be generated and associated with the images (as image metadata) and then embedded in the image files produced.
Programming implementations which output this standard exist in (at least):
- Java
- C
- JavaScript
- PHP
- Python
- Ruby
An example implemented in Java 6 might look like:
```java
import java.util.UUID;
public class UuidExample {
public static void main(String[] args) {
final UUID uuid = UUID.randomUUID();
System.out.println(uuid);
}
}
```
10.1.4 Validation of embedded metadata
Example of an XML schema used to validate embedded metadata:
```xml
<?xml version="1.0" encoding="utf-8"?>
<xs:schema
xmlns:xs="http://www.w3.org/2001/XMLSchema"
xmlns="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
targetNamespace="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
elementFormDefault="qualified"
attributeFormDefault="unqualified"
version="1.0">
<xs:annotation>
<xs:documentation xml:lang="en">
XML Schema document for embedding metadata in digitised image records held by The National Archives.
</xs:documentation>
</xs:annotation>
<xs:element name="DigitalFile">
<xs:complexType>
<xs:sequence>
<xs:element name="UUID" type="UUIDv4StringType"/>
<xs:element name="URI" type="uriType"/>
<xs:element name="Copyright" type="copyrightType"
default="© Crown copyright: The National Archives of the UK"/>
</xs:sequence>
</xs:complexType>
</xs:element>
<xs:simpleType name="uriType">
<xs:restriction base="xs:string">
<!-- Concatenation of URI eg. http://datagov.nationalarchives.gov.uk/66/WO/40/27/1/ with UUID -->
<!-- Ref string: http://datagov.nationalarchives.gov.uk/66/WO/40/27/1/c87fc84a-ee47-47ee-842c-29e969ac5131 -->
<!-- URI: http://datagov.nationalarchives.gov.uk/{TNA ARCHON No.}/DEPT}/{SERIES}/{PIECE}/{UUID} -->
</xs:restriction>
</xs:simpleType>
</xs:schema>
```
10.2 External metadata
The National Archives requires the collection of a variety of technical metadata relating to the creation of digitised images and the creation of electronic text (transcription) from such images. The aim of collecting this metadata is to allow for the long term management and preservation of the images and to enable us to describe the digitised content online. Digitisation at The National Archives
Where the images represent digitised records rather than digital surrogates this technical metadata also captures the provenance of the digitised record allowing us to demonstrate its authenticity and integrity when the original paper document is destroyed.
The National Archives performs a variety of checks on this metadata to examine its internal consistency and compliance with our requirements.
10.2.1 Technical metadata
The technical metadata about the creation of digitised images broadly describes the hardware, software, and processes used to create the images. This allows the identification of any systemic issues uncovered during quality assurance process (if one particular scanner is producing poor quality images, or a software package appears to have a bug). Where the images represent digitised records rather than digital surrogates we also need to know when the actions were carried out.
The National Archives requires technical metadata to be delivered as UTF-8 (tools.ietf.org/html/rfc3629) encoded, CSV (Comma Separated Value) text files formatted according to the RFC 4180 specification (tools.ietf.org/html/rfc4180).
10.2.1.1 Explanation of Checksums
The National Archives requires that a checksum based on the SHA256 Cryptographic Hash Function (CHF) be calculated for each final image after metadata has been added, and supplied as part of the image metadata. See: csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf.
This is to ensure that data has not been corrupted in transit. A checksum must also be generated for the metadata files themselves. Upon receipt of the batch, The National Archives recalculates the SHA256 hash value for each of the images and metadata files concerned and confirms that the newly calculated values match the values supplied in the metadata and hash value text files. In the event that the values do not match, the batch or piece(s) within it may be rejected and returned to the supplier.
10.2.1.2 Technical acquisition and technical environment metadata requirements for digitised records
Two metadata files are required for each batch of digitised records; one file describing the technical acquisition metadata and the other file describing the technical environment metadata.
The metadata files are named: tech\_\_<type>_metadata_v<versionnumber>_<batchcode>.csv
Where <type> is either 'acq' for acquisition metadata or 'env' for environment metadata, <versionnumber> is the version of the particular metadata file standard provided by The National Archives and <batchcode> is a unique code for the batch being delivered and that matches the value of the batchcode field in the metadata itself and the volume label of the media the batch is delivered on.
For example: using version 1 of the acquisition metadata file standard and a batch with a batchcode “testbatchY16B001” the file name would be:
```
tech_acq_metadata_v1_testbatchY16B001.csv
```
The checksum for this file would be saved with file name:
```
tech_acq_metadata_v1_testbatchY16B001.csv.sha256
```
The contents of that file would be a string of the form “tech_acq_metadata_v1_testbatchY16B001.csv e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855” where the long string beginning “e3b0c...” is the SHA256 hash value for the file. This should be a simple UTF-8 encoded text file. There are up to 42 technical acquisition metadata fields for paper digitisation projects (not all will be relevant for every project):
- Batch code
- Department
- Division
- Series
- Sub series
- Sub sub series
- Piece
- Item
- Description
- Ordinal
- File UUID
- File path
- File checksum
- Resource URI
- Scan Operator
- Scan ID
- Scan location
- Scan native format
- Scan timestamp
- Image Resolution
- Image width
- Image height
- Image tonal resolution
- Image format
- Image colour space
- Image split
- Image split ordinal
- Image split other UUID
- Image split operator
- Image split timestamp
- Image crop
- Image crop operator
- Image crop timestamp
- Image de-skew
- Image de-skew operator
- Image de-skew timestamp
- Process location
- Jp2 creation timestamp
- UUID time stamp
- Embed timestamp
- QA Code
- Comments Digitisation at The National Archives
For microform or photographic negatives the following three fields will also be added (to give a total of 45 fields):
- image_inversion
- image_inversion_operator
- image_inversion_timestamp
For microform the following field may also be added (to give a total of 46 fields):
- fiche reference
For further information see Appendix A Technical acquisition metadata for digitised records.
There are eight technical environment metadata fields for digitised records:
- Batch code
- Company name
- Image de-skew software
- Image split software
- Image crop software
- Jp2 creation software
- UUID software
- Embed software
For microform or photographic negative projects, a further field is added (giving a total of nine):
- Image inversion software
For further information see Appendix B Technical environment metadata for digitised records.
10.2.1.3 Technical acquisition metadata requirements for digital surrogates
One metadata file should be delivered with each batch of digital surrogates; this file describes technical acquisition metadata. The naming of this file and checksum file is as above.
There is no technical environment metadata required for digital surrogates.
There are up to 30 technical acquisition metadata fields for digital surrogates. They are a sub-set of those required for digitised records:
- Batch code
- Department
- Division
- Series
- Sub series Digitisation at The National Archives
- Sub sub series
- Piece
- Item
- Ordinal
- Description
- File UUID
- File path
- File checksum
- Resource URI
- Scan operator
- Scan ID
- Scan location
- Image resolution
- Image width
- Image height
- Image tonal resolution
- Image format
- Image compression
- Image colour space
- Image split
- Image split ordinal
- Image split other UUID
- Image crop
- Image de-skew
- Comments
For further information see Appendix C Technical acquisition metadata requirements for digital surrogates.
10.2.2 Transcription metadata
Transcription metadata is more variable in content, dependent on the records to be transcribed. However, this section lays out some general principles relating to The National Archives’ desired approach to transcription, particularly in relation to common pieces of data to be transcribed such as names, dates and addresses.
Previous experience has shown that two elements of transcription can be particularly difficult to deal with:
- ordering images into the correct sequence to form ‘documents’ of correctly ordered pages
- dates - in terms of onward processing due to the large numbers of possible combinations of format (day, month or year) being missing or partially unreadable (or occasionally nonsensical - 30 February) The National Archives believes that the complexity of dealing with these issues can be reduced in the following ways:
10.2.2.1 Ordering images
An ordinal number in the metadata records the position of a single image within its parent Piece or Item. This allows images to be reordered at any time within the boundaries of a Piece or Item without renaming files.
However, should an image need to move from one Piece or Item to another this would be reflected in the ordinals, but would additionally require a rename and move of the image.
Ordinals are context sensitive, which is to say they are only unique within their Parent container, and as such should start from 1 within each Item or Piece and be incremented sequentially. If, as part of the transcription process, it is also required that material previously arranged only at Piece level is split into Items, there is no need to rename files; just record each new item in the CSV with the relevant ordinals.
So if piece 1 originally contained 12 images which transcription shows should be split into 3 items:
- item 1 might consist of the first 3 images, 0001.jp2, 0002.jp2, 0003.jp2 with ordinals 1, 2 and 3 respectively (within item 1)
- item 2 the next 5 images, 0004.jp2, 0005.jp2, 0006.jp2, 0007.jp2 0008.jp2 with ordinals 1, 2, 3, 4 and 5 respectively (within item 2)
- item 3 the final 4 images 0009.jp2, 0010.jp2, 0011.jp2, 0012.jp2 with ordinals 1, 2, 3 and 4 respectively (within item 3)
10.2.2.2 Dates
Transcribing the date parts separately will make it easier to check the status (missing, incomplete and so on) of each part without complicated parsing. Also the ability to disambiguate between omitted transcription dates and dates that were truly missing from the original allows for some automated quality assurance (QA) checking.
See Appendix D for an example of the types of fields required in a transcription metadata CSV file. 11 Validation of scanned images and external metadata
11.1 Metadata validation
The National Archives undertakes a variety of tests on the metadata to ensure it is internally consistent. Where values such as UUIDs can be repeated in different fields for the same image (for example, in both the UUID field and as part of the image URI) we will check that the same value is given in each case. We also check that rows are not duplicated. Where we have specified particular data types, character sets or character patterns, these will also be validated.
The primary tool used for this is our CSV Validator, working with our CSV Schema language. Full details of these can be found at http://digital-preservation.github.io/csv-validator/. The relevant schema for a project will be supplied in advance of imaging (and usually with the project ITT). For ease of reference the schema name will match that of the metadata file to which it applies, but with the numeric part of the reference set to zeroes, and with the format extension .csvs. So, for the example metadata filename given above, tech_acq_metadata_v1_testbatchY16B001.csv, the related schema would be tech_acq_metadata_v1_testbatchY16B000.csvs.
11.2 Image validation
The National Archives expects its suppliers to carry out general quality assurance on images through a defined process which tests all aspects of the specification laid out above. Suppliers give details of the process to The National Archives at the start of a project and provide regular reports on the application of the process and issues detected.
During our image QA process, if we find any missing images we will flag these to the scanning supplier and they will need to scan the missing images, insert them into the correct location within the piece, renumber all subsequent image numbers, update the .CSV files and redeliver either the whole batch or resubmit individual piece(s) as part of later batches back to us.
We use programmatic techniques to validate all images ensuring general compliance with the JPEG2000 part 1 specification and with the specific profiles laid out in this document (including the embedding of image metadata) see 11.2.1 Tools for validation, below. Non-compliant images are rejected and are regenerated (if necessary by rescanning).
The tools and scripts used by us are freely available and are listed in sections 11.2.1 and 11.2.2 of this document. Some individual scripts will also be developed for particular projects and made available to suppliers on request. We suggest suppliers to The National Archives incorporate these, or similar tools, into internal QA process in order to reduce the likelihood of images being rejected. Up to 10% of images per batch on every project may be inspected. Evaluation may cover:
- correctness of mode
- correctness of resolution
- correctness of image size
- lack of sharpness
- loss of detail or image corruption
- correctness of orientation
- correctness of cropping
- skew
- overall too dark or light
- overall too low or high contrast
- correctness of file name, and
- correctness and completeness of metadata
If the random sampling suggests that more than 1% of the total batch fails to meet the required standards then the entire batch is returned to the suppliers for further quality control examination and rescanning as necessary. Where smaller proportions of images do not meet our standards only the piece(s) containing those images will be rejected from the batch and the rest of the batch will continue through the ingest process. Those piece(s) should then be resubmitted within later batches.
We can then inspect any re-scanned images if necessary. We notify suppliers of any errors found during the technical and visual QA processes by sending them a CSV file or alternative reporting formats as agreed, for example:
| Field | Data Format | Description | Options or Example | |-------------|--------------------------------------------------|-----------------------------------------------------------------------------|--------------------| | batch_code | Up to 16 alpha-numeric characters | An identifier for each batch of records. The same batch number will be included in the first row of every metadata file related to that batch of records | testbatchY16B001 | | file_uuid | Universally unique identifier (UUID) - must adhere to UUID Version 4 format see www.ietf.org/rfc/rfc4122.txt | Universally unique identifier embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | | Field | Data Format | Description | Options or Example | |---------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------| | file_path | Must be a valid URI see [www.ietf.org/rfc/rfc3986.txt](http://www.ietf.org/rfc/rfc3986.txt) | Location of file on storage as specified in the competition. For example: DeptCode/SeriesNo/Piece_Number_ItemNo_ImageNumber_ItemNo_ImageNumber.jp2 | file:///WO/409/27_1/1/27_1_0001.jp2 | | file_checksum | Must adhere to the SHA-256 standard and be expressed in lower-case hexadecimal characters, see [csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf](http://csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf) | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855 | | error_description | From list below | | |
**Error description**
- Incorrect mode
- Incorrect resolution
- Incorrect image size
- Lack of sharpness
- Loss of detail or image corruption
- Incorrect orientation
- Incorrect cropping
- Skew
- Overall too dark
- Overall too light
- Incorrect file name
- Incorrect header information
- Incomplete header information 11.2.1 Tools for validation
11.2.1.1 Tools for JPEG2000 format validation
As the JPEG2000 format is relatively new, experience has shown that not all tools/encoders implement the standard correctly in all scenarios. Therefore, the recommended approach is to use a combination of tools to increase confidence in the validity of the image.
Tools employed by The National Archives have included:
**Jasper Imginfo 1.900.1**
Imginfo is part of the Jasper toolkit which is a reference implementation for the JPEG2000 standard. Imginfo parses the entire codestream to output information about the JPEG2000 codestream. The parser may fail if the image is not valid. This tool extracts minimal technical metadata such as height and width of the image in pixels. It has been found to be useful in reporting corruption in the image code-stream that can result in visual distortion or artefacts. See [www.ece.uvic.ca/~frodo/jasper/](http://www.ece.uvic.ca/~frodo/jasper/)
**OPF jpylyzer**
Jpylyzer was produced by Johan van der Knijff for the Open Planets Foundation; it validates the JPEG2000 file structure by performing tests against the published standard and also extracts file properties. The result of this tool should indicate that the file is valid JP2 and the values extracted by the tool for levels, layers and so on meet the requirements set out in this document. See [www.openplanetsfoundation.org/software/jpylyzer](http://www.openplanetsfoundation.org/software/jpylyzer)
It is possible for these tools to be wrapped or incorporated within automated validation workflows. We would strongly promote the use of such tools to check conformance of generated JP2 files with the latest published standard and to ensure that they also match the relevant The National Archives profile.
11.2.1.2 Tools for XML metadata validation
The XML document generated to embed into the JPEG2000 images must be valid according to an XML Schema provided by The National Archives, as above. To ensure the validity of the XML document, various tools exist for validating it against the Schema. Some of the more popular include:
- Apache Xerces: [xerces.apache.org](http://xerces.apache.org)
- Saxonica Saxon EE: [www.saxonica.com](http://www.saxonica.com)
- LibXml xmllint: [xmlsoft.org/xmllint.html](http://xmlsoft.org/xmllint.html) 12 Folder structure
The National Archives requires all images to be delivered in a folder structure which reflects the original archival hierarchy of the records.
It may sometimes be necessary to extend this hierarchy by adding more detailed cataloguing information to identify (for example) the images which relate to a single individual or those which represent a particular month’s reports.
Example of such a folder structure based on a recent project:
```
AIR79Y16B001 (Batch ID – series reference Y year batch)
AIR_79 (department and series level folder)
content (content folder)
205 (piece level folder)
18727 (item level folder)
205_18727_0001.jp2 (file level)
```
The catalogue reference for this image would be AIR 79/205/18727.
The filenames quoted above are deliberately neutral to stress that files will be identified and managed through the folder structure and the unique identifier embedded in each file.
At The National Archives an item is defined as all the images relating to a single individual or other appropriate grouping.
In some instances, there may be images which do not obviously relate to the previous or subsequent item. Such images are generically referred to as orphans.
As part of The National Archives’ own in-house QA process to quality assure scanned images we check anything identified as an orphan. If necessary we will also advise on how material which has been missed during the scanning process should be integrated into the folder structure.
Images are delivered in one or more batches. All the metadata files for a batch should be at the content folder level of this folder structure with their respective checksum files, alongside the content folder rather than inside it. Each batch would contain a single file system of the layout specified. A batch will Digitisation at The National Archives
normally comprise several pieces, but please note that an individual piece should arrive within a single batch, not split across multiple batches.
Example of the location of metadata files within the folder structure:
```
AIR_79 (department and series level folder)
tech_acq_metadata_v1_AIR79Y16B001.csv
tech_env_metadata_v1_AIR79Y16B001.csv
tech_acq_metadata_v1_AIR79Y16B001.csv.sha256
tech_env_metadata_v1_AIR79Y16B001.csv.sha256
tech_acq_metadata_v1_AIR79Y16B000.csv
tech_env_metadata_v1_AIR79Y16B000.csv
content (content folder)
```
13 Overview of the process
The scanning process used must ensure that both sides of all pages are captured (even if blank) only once. Record details of the scanning machine used and a code for the operator.
Perform any tasks such as cropping, de-skewing and image splitting as required. Record software used and operator.
If scanning software does not produce .jp2 files natively, then convert images. Record details of all conversion software used. Retain original images until all quality assurance (QA) is completed and The National Archives confirms they can be destroyed.
Since the final filename is required to contain elements of the catalogue reference, and to contain a number to indicate its position within an individual record, it may not be possible to construct this filename at this point of the scanning process. There should be a repeatable (and auditable) process for this allocation.
As well as external technical acquisition (for digitised records and digital surrogates) and environment metadata (for digitised records only) The National Archives requires a variety of XML elements to be embedded into the .jp2 images to assist with long-term management of the files. Since this includes the catalogue reference, allocation into the archival hierarchy must have been completed by this stage.
To allow long-term assurance that the file received is the same as when originally created and has not been corrupted or tampered with a SHA256 checksum should be calculated for each image file - this should be stored in the metadata spreadsheet. A checksum for the spreadsheet itself is also required. Appendix A: Technical acquisition metadata for digitised records
All fields listed below record details of every individual image and the processes carried out on it before delivery to The National Archives. These fields will be the column headings in the metadata CSV file.
| Field | Data format | Description | Options or example | Justification | Consistency check | |---------------|-------------|-------------------------------|--------------------|-------------------------------------------------------------------------------|-----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | TestbatchY16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | series | Up to 8 characters | Archival hierarchy | 79 | | | | sub_series | Up to 8 characters | Archival hierarchy | | | May be empty | | sub_sub_series| Up to 8 characters | Archival hierarchy | | | May be empty | | piece | Up to 8 characters | Archival hierarchy | 1 | | | | item | Up to 8 characters | Archival hierarchy | 2 | | May be empty | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------|-------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|--------------------------------------------------------| | description | Unstructured text | Catalogue description provided by the Authority for each piece/item. May be left blank. | 2 Infantry Brigade: 2 Battalion King's Royal Rifle Corps. | Required for the Authority's ingest process, and will also support QA as the description and date range shown can be sense checked against the captured images | Must match values supplied by The Authority | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | ordinal | Integer starting from 1 | Describes the order of a file within an item. Should start at 1 within each item. See the note on ordering images above | 1 | To keep the images in order. | Expected range will usually be checked, along with a uniqueness check on the combination of piece, item and ordinal | | file_uuid | Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: [http://www.ietf.org/rfc/rfc4122.txt](http://www.ietf.org/rfc/rfc4122.txt) | Universally Unique Identifier for the image embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | QA - and unique identification of digitised records and digital surrogates for efficient processing | Aim is to ensure all image files are delivered once and only once. Check the UUID against the UUID that forms part of the URI and also against the UUID embedded in the file at the file_path provided, to ensure they match | | file_path | The file path to the image. Must be a valid URI, see: [http://www.ietf.org/rfc/rfc3986.txt](http://www.ietf.org/rfc/rfc3986.txt) | Location of file relative to the root of the file system containing the batch | file:///AIR_79/content/1/2/1_2_0001.jp2 | QA | All image files on the file system provided must have a row in this metadata file and all file_path must have a matching file at the location given | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|--------------------------------------------------------------------------------| | file_checksum | Must adhere to the SHA-256 standard and should be expressed in lower-case hexadecimal characters | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855 | QA - to ensure the image file was received without corruption or tampering | The National Archives will generate a checksum upon receipt of the image and expect it to match the checksum given here | | resource_uri | The URI that is embedded into the Digital Image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | A unique identifier with a predictable pattern | http://datagov.nationalarchives.gov.uk/66/AIR/79/1/2/daf49885-e182-4211-80f7-29bb0bb35112 | QA | The Authority will check that this URI is the same as the URI embedded in the file stored at the file_path provided | | scan_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the scanner that produced the image; this should be an anonymised code that the supplier can decode | ABG001 | QA - the data is anonymised in order that The National Archives does not hold any personal data | Validation by The National Archives | | scan_id | Up to 12 alpha-numeric characters | An individual identifier of the scanning device used to produce the | 002A | QA - specific scanner id to trace back | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|-------------|--------------------------------------------------|--------------------|---------------|------------------------------------| | image | | image | | | problems with an image to a specific machine | | scan_location | Text | Physical location of scanner | The National Archives, Kew, Richmond, Surrey, TW9 4DU | QA | Validation by The National Archives | | scan_native_format | Text | Format and version expressed as text | Cannon Raw v1.4 | Provenance and QA | Validation by The National Archives | | scan_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: [www.w3.org/TR/xmlschema-2/#dateTime](http://www.w3.org/TR/xmlschema-2/#dateTime) | Date and time the paper scan ends | 2010-01-02T02:17:21Z | Provenance | Validation by The National Archives | | image_resolution | Integer | Number in pixels per inch of the image with respect to the original object. | 300 600 | QA | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|-------------|-------------------------------|--------------------|---------------|-----------------------------------------------------------------------------------| | image_width | Integer | Dimensions are always in pixels | 4407 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_height | Integer | Dimensions are always in pixels | 3030 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_tonal_resolution | Value from provided enumeration | 24-bit colour | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_format | A PRONOM unique identifier (PUID) see: nationalarchives.gov.uk/aboutapps/pronom/puid.htm | The code used to uniquely identify a file format | x-fmt/392 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_colour_space | Value from provided enumeration | sRGB | QA | The Authority will validate this against the image file stored at the file_path provided. | | image_split | Lower case text strings "yes" or "no" | Specifies if the image was the result of an image split | yes | QA | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|----------------------|-----------------------------------------------------------------------------|--------------------|---------------|-------------------| | image_split_ordinal | Only integers allowed| For composites (see previous field), this field is used to confirm the ordering of the images. Numbering is from top left, along the top row of separate images, then from the left of each successive row (there should be overlap between adjacent images) | 1 2 3 4 5 6 7 8 9 | | Validation by The National Archives |
It may be helpful to use the comments field to provide a more human readable version of this e.g. 1=top left, 2=top middle, 3=top right, 4=middle left, 5=middle middle, 6=middle right, 7=bottom left, 8=bottom middle, 9=bottom right or similar. | Field | Data format | Description | Options or example | Justification | Consistency check | |------------------------|------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|---------------|----------------------------------------------------------------------------------| | image_split_other_uuid | One or more (separated by a comma) Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: http://www.ietf.org/rfc/rfc4122.txt | If the image was split, this field must contain the UUIDs of the other images that were split from the same original image as this image. If there more than two images as part of a split, this field may contain multiple UUIDs separated by a comma | 0d0b88c6-9a6e-4731-ace3-b50794c1356b,a2915f99-6efa-45d4-a0c9-8fd2555643ec | QA | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes”\
QA will ensure that the other split images exist, and that they also reciprocally point back to this image through their image_split_other_uuid fields | | image_split_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the split software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that the Authority does not hold any personal data | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes” | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|---------------|----------------------------------------------------------------------------------| | image_split_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: | The date and time the file was split | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes” | | image_crop | Lower case text strings "auto", "manual" or "none" | Specifies if the image was cropped and if it was what type of crop was carried out | auto | QA | is("auto") or is("manual") or is("none") else must be blank | | image_crop_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the crop software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data | Field shall be empty if image_crop = “none” or if image_crop = “auto” and populated with valid data if image_crop = “manual” | | image_crop_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: | The date and time the image was cropped | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if image_crop = “none” and populated with valid data if image_crop = “auto” or if image_crop = “manual” | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------------------|--------------------------------------------------|-----------------------------------------------------------------------------|--------------------|---------------|-----------------------------------------------------------------------------------| | image_deskew | Lower case text strings "yes" or "no" | Specifies if the image was deskewed | no | QA | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | image_deskew_operator | Up to 12 alphanumeric characters | Code representing the specific operator using the deskew software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | image_deskew_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the image was deskewed | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | process_location | Text | Physical location of image processing procedures | The National Archives, Kew, Richmond, Surrey, TW9 4DU | Provenance and QA | | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------------------|------------------------------|------------------------------------------------------------------------------|--------------------|---------------|-------------------| | jp2_creation_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the JPEG 2000 image was created | 2012-08-09T09:15:37+01:00 | Provenance | | | uuid_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the UUID was created for file | 2010-08-02T04:17:21+01:00 | Provenance | | | embed_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time metadata was embedded in the image file | 2010-01-02T05:17:21+0:00 | Provenance | | | image_inversion | Only valid values allowed: lower case text strings "auto", "manual" | Microform or photographic negative projects only Specifies if the image | auto | Provenance and QA. | Contains only valid values | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | image_inversion_operator | Up to 12 alphanumeric characters | **Microform or photographic negative projects only**<br>Code representing the specific operator using the inversion software that produced the image for a manual inversion; this is to be an anonymised code that the supplier can decode. | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data. | Field shall be empty if image_crop = “none” or if image_crop = “auto” and populated with valid data if image_crop = “manual” | | image_inversion_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: <br>http://www.w3.org/TR/xmlschema-2/#dateTime | **Microform or photographic negative projects only**<br>The date and time the image was inverted | 2010-01-02T06:17:21Z | Provenance. | Field shall be empty if image_crop = “none” and populated with valid data if image_crop = “auto” or if image_crop = “manual” | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------|-------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|--------------------| | qa_code | | Codes to use to indicate where information is illegible due to damage to the document. | **For paper:** A. Missing Area: Corner or edge B. Missing area: hole in page C. Tears D. Text obscured by tape or other document (can’t be removed/separated) E. Discolouration or staining of paper (text is difficult to read) F. Ink stains or other spill (text is obscured) G. Faint text H. Blurred or smudged text I. Offsetting of ink to facing page, or bleed through of ink from other side of page. J. Burn damage (from fire or metal corrosion)
**Notes:** B. Including intentional holes such as tag holes, and holes from pest damage | This records pre-existing damage to the material being digitised. With surrogates, if it appears information has been lost due to damage to the original, the original may be produced to confirm this. For digitised records this option will not be available | Must be either blank or numbers between 01 and 20 (for paper) or 40-47 (for microform) |
**For microform:** Digits from 40 to 44, or a comma separated list of such double digits | | | | | | | Field | Data format | Description | Options or example | Justification | Consistency check | |-------|-------------|-------------|--------------------|---------------|-------------------| | | | E. Would include staining from mould damage, discolouration, foxing, water damage etc. | For microform: 40: microform scratched 41: illegible: image too dark 42: illegible: image too light 43: Microform breakage 44: No foliation | QA | Populated at the supplier’s discretion | | comments | Text | Operator’s comments, may be empty | | | | Appendix B: Technical environment metadata for digitised records
All fields listed below record details of the technical environment used during the scanning process; this environment should be consistent for all scanned images within a batch, and as such needs only be captured once. These fields will be the column headings in the metadata CSV file.
| Field | Data Format | Description | Example | Consistency Check | |------------------------|----------------------|--------------------------------------------------|---------------------|-----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | TestbatchY16B001 | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | company_name | Text | Name of the company undertaking the process | Bob’s Scan Ltd | | | image_deskew_software | Text | Name and version of the software used for deskewing images | GNU GIMP 2.6 | | | image_split_software | Text | Name and version of the software used for splitting images | GNU GIMP 2.6 | | | Field | Data Format | Description | Example | Consistency Check | |------------------------|-------------|-----------------------------------------------------------------------------|--------------------------|-------------------| | image_crop_software | Text | Name and version of the software used for image cropping | GNU GIMP 2.6 | | | jp2_creation_software | Text | Name and version of the software used for creating the JPEG2000 file from the acquired image | ImageMagick 6.8.0-5 | | | uuid_software | Text | Name and version of the software used to generate the UUID. If programmatic, use the software library name and version | Oracle Java JDK 1.6 | | | embed_software | Text | Name and version of the software used to embed the metadata into the image | Luratech Lurawave 11a | |
### Appendix C: Technical acquisition metadata requirements for digital surrogates
All fields listed below record details of every individual image and the processes carried out on it. These fields will be the column headings in the metadata CSV file.
| Field | Data Format | Description | Options or Example | Justification | Consistency Check | |------------------|-------------|----------------------------------|--------------------|-------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | testbatchY16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |-------------|-----------------|----------------------|--------------------|---------------|-------------------| | series | Up to 8 characters | Archival hierarchy | 79 | | | | sub_series | Up to 8 characters | Archival hierarchy | | May be empty | | | sub_sub_series | Up to 8 characters | Archival hierarchy | | May be empty | | | piece | Up to 8 characters | Archival hierarchy | 1 | | | | item | Up to 8 characters | Archival hierarchy | 2 | May be empty | | | ordinal | Integer starting from 1 | Describes the order of a file within an item. Should start at 1 within each item. See the note on ordering images above | 1 | To keep the images in order. | Expected range will usually be checked, along with a uniqueness check on the combination of piece, item and ordinal | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |------------|------------------------------|------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------------------|---------------------------------------------------------| | description | Unstructured text | Catalogue description provided by the Authority for each piece/item. | 2 Infantry Brigade: 2 Battalion King's Royal Rifle Corps. | Required for the Authority's ingest process, and will also support QA as the description and date range shown can be sense checked against the captured images | Must match values supplied by The Authority | | file_uuid | Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: www.ietf.org/rfc/rfc4122.txt | Universally Unique Identifier for the image embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | QA and unique identification of digitised records and digital surrogates for efficient processing | Aim is to ensure all image files are delivered once and only once | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------|-------------|------------------------------------------------------------------------------|--------------------|---------------|-------------------| | file_path | The file path to the image. Must be a valid URI, see www.ietf.org/rfc/rfc3986.txt | Location of file relative to the root of the file system containing the batch | file:///AIR_79/1/2/0001.jp2 | QA | All image files on the file system provided must have a row in this metadata file and all file_path must have a matching file at the location given | | file_checksum | Must adhere to the SHA-256 standard and should be expressed in lower-case hexadecimal characters, see: csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427a4e4649b934ca495991b7852b855 | QA | The National Archives will generate a checksum upon receipt of the image and expect it to match the checksum given here | | resource_uri | The URI that is embedded into the Digital Image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | A unique identifier with a predictable pattern | http://datagov.nationalarchives.gov.uk/66/AIR/79/1/2/daf49885-e182-4211-80f7-29bb0bb35112 | QA | The Authority will check that this URI is the same as the URI embedded in the file stored at the file_path provided | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |------------------|------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|-------------------| | scan_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the scanner that produced the image; this should be an anonymised code that the supplier can decode | ABG001 | QA - the data is anonymised in order that The National Archives does not hold any personal data | | | scan_id | Up to 12 alpha-numeric characters | An individual identifier of the scanning device used to produce the image | 002A | QA - specific scanner id to trace back problems with an image to a specific machine | | | scan_location | Text | Physical location of scanner | The National Archives, Kew, Richmond, Surrey, TW9 4DU | QA | | | image_resolution | Integer between 1 and 10000 | Number in pixels per inch of the image with respect to the original object | 300 | QA | Validation by The National Archives | | image_width | Integer | Dimensions are always in pixels | 4407 | QA | Validation by The National Archives | | image_height | Integer | Dimensions are always in pixels | 3030 | QA | Validation by The National Archives | | image_tonal_resolution | Value from provided enumeration | | 24-bit colour | QA | Validation by The National Archives | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|---------------|----------------------------------------| | image_format | A PRONOM unique identifier (PUID) see: www.nationalarchives.gov.uk/aboutapps/pronom/puid.htm | The code used to uniquely identify a file format | x-fmt/392 | QA | Validation by The National Archives | | image_compression | Integer between 1 and 99 | The value of N in the lossy image compression ratio N:1 used to compress the image. Note 1:1 means no-compression employed | 6 | QA | Validation by The National Archives | | image_colour_space | Value from provided enumeration | | sRGB | QA | The Authority will validate this against the image file stored at the file_path provided | | image_split | Lower case text strings "yes" or "no" | Specifies if the image was the result of an image split | yes | QA | | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------------|----------------------|-----------------------------------------------------------------------------|--------------------|---------------|-------------------| | image_split_ordinal | Only integers allowed| For composites (see previous field), this field is used to confirm the ordering of the images. Numbering is from top left, along the top row of separate images, then from the left of each successive row (there should be overlap between adjacent images) | 1 2 | | Validation by The National Archives | | | | Or | 3 4 | | | | | | Etc. | 1 2 3 | | | | | | Etc. | 4 5 6 | | | | | | Etc. | 7 8 9 | | | | | | It may be helpful to use the comments field to provide a more human readable version of this e.g. 1=top left, 2=top middle, 3=top right, 4=middle left, 5=middle middle, 6=middle right, 7=bottom left etc. | | | | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |------------------------|-------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|---------------|-------------------| | image_split_other_uuid | One or more (separated by a comma) Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: www.ietf.org/rfc/rfc4122.txt | If the image was split, this field must contain the UUIDs of the other images that were split from the same original image as this image. If there are more than two images as part of a split, this field may contain multiple UUIDs separated by a comma | 0d0b88c6-9a6e-4731-ace3-b50794c1356b,a2915f99-6efa-45d4-a0c9-8fd2555643ec | QA | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes” TNA QA will ensure that the other split images exist, and that they also reciprocally point back to this image through their image_split_other_uuid fields | | image_crop | Lower case text strings “auto”, “manual” or “none” | Specifies if the image was cropped and if it was what type of crop was carried out | auto | QA | | | image_deskew | Lower case text strings “yes” or “no” | Specifies if the image was deskewed | no | QA | | | comments | Text | Operator’s comments, may be empty | | QA | Populated at the supplier’s discretion |
## Appendix D: An example of the types of fields required in a transcription metadata CSV file
| Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|------------------------------|-------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | batch_code | Up to 16 alpha-numeric characters | An identifier for each batch of records. Supplied by the Authority | Testbatch Y16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | series | Up to 8 characters | Archival hierarchy | 79 | | | | sub_series | Up to 8 characters | Archival hierarchy | | | May be empty | | sub_sub_series| Up to 8 characters | Archival hierarchy | | | May be empty | | piece | Up to 8 characters | Archival hierarchy | 1 | | | | item | Up to 8 characters | Archival hierarchy | 2 | | May be empty | | metadata_type | Up to 12 alpha-numeric characters. Taken from an enumeration | Valid metadata types are provided by The National Archives along with a list of enumerated values | ITWW01 | For enabling us to validate the content of a row based on the data expected in that row | The metadata_type is a code describing which fields must and should be completed in any particular row. Rows will be validated using this code | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|------------------------------------------------------------------------------|----------------------------------------------------------------------|----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|-------------------| | file_path | The file path to the image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | Location of file relative to the root of the file system containing the batch | file:///AIR_79/content/1/2/1_2_0001.jpg | The file must exist | | | ordinal | Integer starting from 1 | Describes the order of a file within an item or piece. Should start at 1 within each piece or item. See the textual explanation of 'Ordering' above | 1 | | | | uuid | Must adhere to UUID Version 4 format www.ietf.org/rfc/rfc4122.txt | The UUID read from the image | c87fc84a-ee47-47ee-842c-29e969ac5131 | Uniquely identifies each image | | | first_date_day| 2 digits - zero padded as appropriate. ? or ?? are used to indicate where individual digits are illegible in the original. If the original is blank then use a single * character | This field will also need to accept impossible dates such as 30 February or 31 April. The first and last dates are intended to capture the date range of the document and may be supplied as a fixed range | 1? | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|----------------------------------------------------------------------------|----------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|-------------------| | first_date_month | In full, title-case, no leading or trailing spaces, no punctuation, ? to indicate where characters are illegible. If the original is blank then use a single * character | February | | | | | first_date_year | 4 digits, no leading or trailing spaces, no punctuation, ? to indicate where characters are illegible. ???? to indicate where completely illegible. If the original is blank then use a single * character | For 2 digit years in the original The National Archives will provide advice on a Further Competition basis to establish the century. | ??14 | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|----------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|---------------|-------------------| | last_date_day | 2 digits zero padded as appropriate.? or ?? are used to indicate where individual digits are illegible in the original. If the original is blank then use a single * character | This field will also need to accept impossible dates such as 30 February or 31 April. The first and last dates are intended to capture the date range of the document and may be supplied as a fixed range | 03 | | | | last_date_month | In full, title-case, no leading or trailing spaces, no punctuation, ? to indicate where characters illegible. If the original is blank then use a single * character | | December | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|------------------------------------------------------------------------------|----------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|-------------------| | last_date_year | 4 digits, no leading or trailing spaces, no punctuation, ? to indicate where characters illegible. ???? to indicate where completely illegible. If the original is blank then use a single * character | For 2 digit years in the original The National Archives will provide advice to establish the century | 1897 | | | | description | | Different for every collection - could be structured in a number of fields or a single field with a short narrative | | | | | language | Three characters representing the ISO 639-3 standard language identification code, see: www.iso.org/iso/catalogue_detail?csnumber=39534 and www.sil.org/iso639-3/default.asp | If all material is in English, this field will not be required. | eng | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |-----------|-------------|-------------------------------------------|--------------------|---------------|----------------------------------------| | comments | Text | For transcription staff’s comments, may be empty | QA | Populated at the supplier’s discretion |
| olmocr | 2025-03-31T00:00:00 | 2025-03-31T00:00:00 | {
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"olmocr-version": "0.1.60",
"pdf-total-pages": 60,
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9d5d4e6e67a46ecf0981ad115207f4f802d47613 | Digitisation at The National Archives
Last updated: August 2016
© Crown copyright 2016
You may re-use this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence
Where we have identified any third-party copyright information, you need to obtain permission from the copyright holder(s) concerned.
This publication is available for download at nationalarchives.gov.uk. Digitisation at The National Archives
Contents 1 Introduction ........................................................................................................................................... 4 1.1 Who is this document for? ............................................................................................................. 4 1.2 References .................................................................................................................................... 4 2 Document handling during the scanning process .............................................................................. 5 2.1 Preparing documents for scanning ............................................................................................... 5 2.2 Document handling training .......................................................................................................... 5 2.3 Support of documents .................................................................................................................... 5 2.4 Page turning, unfolding corners .................................................................................................... 5 2.5 Staples, pins, paperclips ................................................................................................................ 6 2.6 Handling seals ............................................................................................................................... 6 2.7 Keeping documents in order ......................................................................................................... 6 2.8 Annotation and labelling ............................................................................................................... 6 2.9 The scanning area ........................................................................................................................ 7 2.10 Use of gloves, tools, cleaning liquids and related items .............................................................. 7 3 Scanning equipment .......................................................................................................................... 7 4 Image capture and quality .................................................................................................................. 8 5 File format ........................................................................................................................................... 8 5.1 Colour space .................................................................................................................................. 8 5.2 Compression .................................................................................................................................. 8 5.3 Resolution ..................................................................................................................................... 9 5.3.1 Embedded Capture Resolution Information ........................................................................... 9 5.3.2 Result of calculations in both examples .................................................................................. 10 5.4 Physical dimensions ...................................................................................................................... 11 6 JPEG2000 profile for a digitised record ............................................................................................ 11 7 Converting master images (TIFF and so on) to JP2 for digitised records ........................................ 12 8 JPEG2000 profile for a digital surrogate .......................................................................................... 13 9 Converting master images (TIFF and so on) to JP2 for digital surrogates ....................................... 13 10 Metadata .......................................................................................................................................... 14 1 Introduction
This document sets out The National Archives’ standards and requirements for the digitisation of analogue records in our collection. It covers the whole digitisation process from initial scanning through to delivery of the images for preservation, including The National Archives’ scanned image specification (see sections 6 and 8).
This document covers the scanning of records where the resultant images will become the legal public record for permanent preservation. For purposes of clarity we refer to these images as digitised records. This document also covers the scanning of records where the resultant images will become digital surrogates with the original paper records being retained and remaining the legal public record. For purposes of clarity we refer to these images as digital surrogates.
1.1 Who is this document for?
We recommend that government departments who wish to digitise any of their paper records follow the processes set out in this document. Please contact your Information Management Consultant (IMC) for further information if it is likely that these records will be transferred to The National Archives at a future date. Other organisations are welcome to use this document for reference when developing their own standards for digitisation.
For further information regarding digitisation projects at The National Archives, please contact the Digitisation and Data Conversion Manager: [email protected]
For any queries about the technical aspects of this document please contact: [email protected]
1.2 References
In preparing the technical imaging and metadata standards The National Archives have had regard to the following (and other standards referred to therein):
- BS 10008:2008 Evidential weight and legal admissibility of electronic information. Specification
- The Archives New Zealand/Te Rua Mahara o te Kāwanatanga Digitisation Toolkit: http://archives.govt.nz/advice/guidance-and-standards/guidance-subject/digitisation-toolkit
- The Minimum Digitization Capture Recommendations from ALA http://www.ala.org/alcts/resources/preserv/minimum-digitization-capture-recommendations
- US FADGI Guidelines: Technical Guidelines for Digitizing Cultural Heritage Materials
- Netherlands: http://www.metamorfoze.nl/english/digitization
- In drawing up our specifications for surrogates we have also reviewed published information by 2 Document handling during the scanning process
The guidance in this section is drawn from widely accepted standards for handling archival records. The restrictions recommended for ‘the scanning area’ will be familiar from standard document reading room restrictions.
2.1 Preparing documents for scanning
Ideally a professional conservator will carry out this preparation and will:
- assess the condition of the records to ensure documents are not too fragile for scanning. As well as general fragility you should look for mould, pages stuck together and inserts obscuring records
- assess the condition of records, looking for any damage which has affected the legibility of the text
- remove any staples
2.2 Document handling training
New scanning operators should undergo document handling training by the conservator(s) prior to handling any documents and receive annual refresher training thereafter
2.3 Support of documents
- Use both hands at all times when moving boxes and documents.
- Ensure scanning beds are large enough to support the whole document.
- Never leave documents exposed on the scanner when unattended.
- Support books and other bound documents with a book cradle or book wedges.
2.4 Page turning, unfolding corners
- Turn pages from the fore edge (right edge) of the document not from the tail (bottom) edge.
- It is not acceptable to use moisture (including licked fingers) for page turning.
- Do not pinch document corners together to turn the page.
- The scanning operator should unfold folded corners but should not then fold them back on themselves. • Where documents are attached to each other and cannot be separated, scan the document in a way which prevents the introduction of new creases.
2.5 Staples, pins, paperclips
• Ideally a conservator should have removed all varieties of staple as part of the process of preparing the documents for scanning. If any have been missed, inform the conservator(s). • Scanning operators should remove pins, split pins and paperclips carefully but removal should not be forced if this will cause damage. • Cut all treasury tags immediately prior to scanning and replace them with appropriate length nylon ended tags as soon as the file is scanned. • The tag should be at least three times as long as the depth of the pile of papers.
2.6 Handling seals
• Take care with applied and pendant seals as they are fragile. They must not be knocked or have weight or pressure applied to them. Neither should they be left to hang off the edge of a work station. • Do not use glass without adjustments approved by the conservator(s) (for example, lowering the document bed, putting blocks under the glass so there is no weight on the document). The same applies to documents with pigments.
2.7 Keeping documents in order
• The contents of boxes should stay together and stay in the sequence in which they came from the box. • Work on only one document at a time so that boxes and documents do not get mixed up. • Replace documents in closed boxes at the end of the day and return them to storage.
2.8 Annotation and labelling
• Annotation or labelling of any part of a document, including the box, is not permitted. Do not use sticky (Post-it®) notes or similar to mark documents. You can use paper markers, provided that you remove them from the document after scanning. 2.9 The scanning area
- Scanning operators’ workstations should provide adequate surface area to ensure the full support of documents and allow for an organised workspace. Too little space can have a negative impact on document handling.
- Keep the scanning area clean and tidy - keep bags and coats in lockers and do not take them into the scanning area.
- No food or drink (including chewing gum) should be permitted in the scanning area.
- You may use pencils only - without erasers. No pens or correction fluid are permitted.
- Do not use hand and face moisturisers, moisturising wipes, lip balms or anything similar that is applied by hand.
- Hands should be clean and dry at all times whilst handling documents.
2.10 Use of gloves, tools, cleaning liquids and related items
- Do not wear cotton gloves or powdered gloves
- You may wear unpowdered nitrile/latex (or similar) gloves if instructed specifically by the conservator(s), for example, for photographic material.
- Do not use handling aids such as rubber thimbles and other tools unless approved by the conservator(s).
- Do not use cleaning liquids unless approved by the conservator(s).
Note: if any damage to documents is found during scanning bring this to the attention of the conservator(s) for repair before scanning takes place.
3 Scanning equipment
The National Archives approves scanning equipment for each project.
In general, The National Archives considers overhead cameras and scanners with a flat scanning bed suitable for scanning. You may use supported glass except in cases where the material may be at risk. You may only use flatbed scanners and automatic feed scanners with the approval of the conservator(s).
Similarly, the conservator(s) must approve the use of weights prior to scanning. Lights should not generate too much heat; ideally use cold light sources. Brightness levels must not have a negative impact on the health and safety of operators. 4 Image capture and quality
- Images should be de-skewed as necessary to achieve nominal skew of not greater than one degree.
- All digital images should be legible and at least as readable as the original image from which they are derived.
- Final images should be single page, unless information crosses both pages.
- All images should be viewed immediately after scanning as a check on satisfactory capture (for example images complete or not inverted) and rescanned if required.
5 File format
Sections 5 to 8 set out the technical specification The National Archives uses for producing scanned images of analogue records. Please note that this specification reflects the requirements of The National Archives and may not be suitable for implementation in other organisations.
From March 2013 all records digitised at, or for, The National Archives will be delivered for preservation as JPEG 2000 part 1 files conformant with the latest version of ISO/IEC 15444-1 JPEG 2000 part 1 and saved with the extension .jp2. If scanning software does not produce .jp2 files natively, images must be converted from a suitable intermediate file format to expected resolution and quality standards. See sections 7 and 9.
Access to the original images (for example, TIFFs) should be maintained until the master JP2 images are signed off.
5.1 Colour space
Scan images in 24 bit colour using the Enumerated sRGB colourspace profile, or for microform material in 8 bit grayscale using the Enumerated greyscale colourspace profile.
5.2 Compression
Use lossless compression for digitised records (where sole access is to be provided via the scanned image).
Lossy compression is acceptable for digital surrogates (where the original paper records are to be retained as the primary record). See section 6 below. 5.3 Resolution
Requirements as to Pixel per inch (PPI) vary according to the format of the material to be scanned:
- use a default of 300 PPI for ordinary documents
PPI should be considerably higher for any photographic media:
- photographs should be at 600 PPI
- photographic transparencies should be at 4000 PPI
For microform the requirement should be for a resolution equivalent to 300 PPI at the size of the original document. If this is not physically possible we would agree on the maximum feasible resolution.
5.3.1 Embedded Capture Resolution Information
Image capture resolution information should be written to the JP2’s ‘Capture Resolution Box’. This is held within the parent ‘Resolution Box’, which is located within the ‘JP2 Header Box’. The Capture Resolution Box specifies the resolution at which the source was digitised, by flatbed scanner or other device, to create code-stream image samples. Resolution is detailed by way of a set of values written to the following parameters:
- vRcN = vertical grid resolution numerator
- vRcD = vertical grid resolution denominator
- vRcE = vertical grid resolution exponent
- hRcN = horizontal grid resolution numerator
- hRcD = horizontal grid resolution denominator
- hRcE = horizontal grid resolution exponent
The parameter values are used by the following calculations to state Vertical Resolution capture and Horizontal Resolution capture values (‘VRc’ and ‘HRc’):
[ VRc = \\frac{vRcN}{vRcD} \\times 10^{vRcE} ]
[ HRc = \\frac{hRcN}{hRcD} \\times 10^{hRcE} ]
The parameter values written may vary by numerator value and the relative adjustment of denominator and exponent, but the resulting values of ‘VRc’ and ‘HRc’ by calculation must return the correct image resolution values – measurements stated in ‘Pixels Per Meter’ from which Pixels Per Inch values can be derived (1 pixel per meter = 0.0254 pixels per inch.)
Two examples of different, but correct values for a 300 PPI (Pixels Per Inch) image are shown below:
**Example 1:**
- vRcN: 30000
- vRcD: 254
- hRcN: 30000
- hRcD: 254
- vRcE: 2
- hRcE: 2
**Example 2:**
- vRcN: 300
- vRcD: 254
- hRcN: 300
- hRcD: 254
- vRcE: 4
- hRcE: 4
### 5.3.2 Result of calculations in both examples
**Example 1:**
[ VRc = \\frac{VRcN}{VRcD} \\times 10^{VRcE} ]
[ 30,000/254 \\times 10^2 = 11811.02362204724 \\text{ PPM} ]
[ 11811.02362204724 \\times 0.0254 = 300 \\text{ PPI} ]
**Example 2:**
[ VRc = \\frac{VRcN}{VRcD} \\times 10^{VRcE} ]
[ 300/254 \\times 10^4 = 11811.02362204724 \\text{ PPM} ]
[ 11811.02362204724 \\times 0.0254 = 300 \\text{ PPI} ] Confirmation of correct values can be made by running a Jpylyzer validation report, which will return written values and confirm image resolution detail by calculation. An example tag-set with values from such a report is given below:
```xml
<resolutionBox>
<captureResolutionBox>
<vRcN>300</vRcN>
<vRcD>254</vRcD>
<hRcN>300</hRcN>
<hRcD>254</hRcD>
<vRcE>4</vRcE>
<hRcE>4</hRcE>
</captureResolutionBox>
</resolutionBox>
```
The Per Meter and Per Inch values below are calculated by Jpylyzer from the above parameter values:
```xml
<vRescInPixelsPerMeter>11811.02</vRescInPixelsPerMeter>
<hRescInPixelsPerMeter>11811.02</hRescInPixelsPerMeter>
<vRescInPixelsPerInch>300.0</vRescInPixelsPerInch>
<hRescInPixelsPerInch>300.0</hRescInPixelsPerInch>
```
There are JP2 encoder software tools available (such as Kakadu, v7 onwards) that can automatically populate the JP2’s Capture Resolution Box with the horizontal and vertical (x and y) Pixels Per Meter image resolution values, which can then be read from the file by software viewers and image editing tools. There are also imaging SDKs (such as ImageGear for .Net) that can be used to build configurable toolset implementations to achieve the same results.
### 5.4 Physical dimensions
- All scans should be size-for-size (for microfilm this refers to the size of the original), with a sufficient clear border/margin to demonstrate to users that the entire page has been captured.
- If a single scan cannot capture the page in its entirety, there should be sufficient overlap to allow users to determine clearly which of the separate digital images form the whole of the original paper page.
### 6 JPEG2000 profile for a digitised record
The most important aspect of this profile is the use of lossless compression (the 5-3 reversible transform). We have chosen not to lose any data because the images will become the legal Public Record. As individual tiles in a JPEG2000 image may use different compression methods we stipulate a single tile to make verification of the compression method more straightforward.
### JPEG2000 option
| Option | Value | |-------------------------------|----------------------------------------------------------------------| | Standard: | JP2 Part 1 | | Transform: | 5-3 reversible (lossless) | | Compression ratio: | N/A | | Levels: | 7 | | Layers: | 1 | | Progression: | RPCL | | Tiles: | Not defined (single tile) | | Bypass: | Selective | | Colour-space: | Enumerated sRGB profile | | Embedded Capture Resolution Information: | Vertical Resolution and Horizontal Resolution values as appropriate to the document | | Code block size | N/A | | Precinct size | N/A | | Regions of interest | N/A | | Tile length markers | N/A |
### 7 Converting master images (TIFF and so on) to JP2 for digitised records
We have anticipated that the application of the conversion from a suitable intermediate file format of expected resolution and quality standards will be automated and that JP2 encoder parameters would result in a profile matching The National Archives standard for digitised records, and could be incorporated in a script. 8 JPEG2000 profile for a digital surrogate
For digital surrogates use lossy 6:1 compression. However, compression ratio values may vary, depending on the characteristics and visual complexity of the documents to be scanned.
| JPEG2000 option | Value | |--------------------------|----------------------------------------------------------------------| | Standard: | JP2 Part 1 | | Transform: | 9-7 irreversible (lossy) | | Compression ratio: | Default 6:1 | | | It is expected that the minimum compression will be 4:1 and the maximum 10:1 depending on the nature of the original material | | Levels: | 7 | | Layers: | 1 | | Progression: | RPCL | | Tiles: | 1024x1024 pixels | | Colour-space: | Enumerated sRGB profile | | Embedded Capture Resolution Information: | Vertical Resolution and Horizontal Resolution values as appropriate to the document | | Bypass: | Selective | | Code block size | N/A | | Precinct size | N/A | | Regions of interest | N/A | | Tile length markers | N/A |
9 Converting master images (TIFF and so on) to JP2 for digital surrogates
In the above table we have anticipated that the application of the conversion from a suitable intermediate file format of expected resolution and quality standards will be automated and that JP2 encoder parameters would result in a profile matching The National Archives standard for digital surrogates and could be incorporated in a script. 10 Metadata
10.1 Embedded metadata
The National Archives requires that a small amount of metadata should be embedded within the image file itself. This metadata is designed to assist in the long-term management of the images by making them easier to identify.
This metadata comprises:
- a copyright statement; this is usually a statement of Crown Copyright as used in the example below, or a statement indication of third party copyright
- a universally unique identifier (UUID) created for each image, see below
- a uniform resource identifier (URI) which allows us to reference the image uniquely
This metadata should constitute a well-formed XML document, which can be validated against an XML Schema provided by us - see example below. The UUID should be a uniquely generated Version 4 UUID, see below.
The image must remain a valid JPEG2000 image after the metadata has been embedded.
10.1.1 Example of embedded metadata in xml
```xml
<?xml version="1.0" encoding="utf-8"?>
<DigitalFile
xmlns="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
xmlns:xsi="http://www.w3.org/2001/XMLSchema-instance">
<UUID>c87fc84a-ee47-47ee-842c-29e969ac5131</UUID>
<URI>http://datagov.nationalarchives.gov.uk/66/WO/409/27@1/c87fc84a-ee47-47ee-842c-29e969ac5131</URI>
<Copyright>© Crown copyright: The National Archives of the UK</Copyright>
</DigitalFile>
```
10.1.2 Explanation of the URI
The URI (for example, see www.ietf.org/rfc/rfc3986.txt) is formed from The National Archives’ reference data domain (currently datagov.nationalarchives.gov.uk) followed by a code that represents The National Archives in its Archon directory of archival repositories (or another repository if public records are held elsewhere under The National Archives’ Place of deposit rules), followed by the catalogue reference to Digitisation at The National Archives
piece level (please note that the ITEM level should not be included in file embedded metadata), and the UUID of the image:
- URI Description: {TNA DOMAIN}/{TNA ARCHON No.}/{DEPT}/{SERIES}/{PIECE}/{UUID}
- example Base String: http://datagov.nationalarchives.gov.uk/66/AIR/79/18727/
- example UUID: c87fc84a-ee47-47ee-842c-29e969ac5131
So the full Reference URI would be:
http://datagov.nationalarchives.gov.uk/66/AIR/79/18727/c87fc84a-ee47-47ee-842c-29e969ac5131
10.1.3 Creating the UUID
UUIDs must be compliant with the specification for Version 4 UUIDs as outlined in RFC4122: www.ietf.org/rfc/rfc4122.txt. Utilities are available to create such UUIDs. You should express UUIDs in lower-case hexadecimal format. These should be generated and associated with the images (as image metadata) and then embedded in the image files produced.
Programming implementations which output this standard exist in (at least):
- Java
- C
- JavaScript
- PHP
- Python
- Ruby
An example implemented in Java 6 might look like:
```java
import java.util.UUID;
public class UuidExample {
public static void main(String[] args) {
final UUID uuid = UUID.randomUUID();
System.out.println(uuid);
}
}
```
10.1.4 Validation of embedded metadata
Example of an XML schema used to validate embedded metadata:
```xml
<?xml version="1.0" encoding="utf-8"?>
<xs:schema
xmlns:xs="http://www.w3.org/2001/XMLSchema"
xmlns="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
targetNamespace="http://nationalarchives.gov.uk/2012/dri/artifact/embedded/metadata"
elementFormDefault="qualified"
attributeFormDefault="unqualified"
version="1.0">
<xs:annotation>
<xs:documentation xml:lang="en">
XML Schema document for embedding metadata in digitised image records held by The National Archives.
</xs:documentation>
</xs:annotation>
<xs:element name="DigitalFile">
<xs:complexType>
<xs:sequence>
<xs:element name="UUID" type="UUIDv4StringType"/>
<xs:element name="URI" type="uriType"/>
<xs:element name="Copyright" type="copyrightType"
default="© Crown copyright: The National Archives of the UK"/>
</xs:sequence>
</xs:complexType>
</xs:element>
<xs:simpleType name="uriType">
<xs:restriction base="xs:string">
<!-- Concatenation of URI eg. http://datagov.nationalarchives.gov.uk/66/WO/40/27/1/ with UUID -->
<!-- Ref string: http://datagov.nationalarchives.gov.uk/66/WO/40/27/1/c87fc84a-ee47-47ee-842c-29e969ac5131 -->
<!-- URI: http://datagov.nationalarchives.gov.uk/{TNA ARCHON No.}/{DEPT}/{SERIES}/{PIECE}/{UUID} -->
</xs:restriction>
</xs:simpleType>
</xs:schema>
```
10.2 External metadata
The National Archives requires the collection of a variety of technical metadata relating to the creation of digitised images and the creation of electronic text (transcription) from such images. The aim of collecting this metadata is to allow for the long term management and preservation of the images and to enable us to describe the digitised content online. Digitisation at The National Archives
Where the images represent digitised records rather than digital surrogates this technical metadata also captures the provenance of the digitised record allowing us to demonstrate its authenticity and integrity when the original paper document is destroyed.
The National Archives performs a variety of checks on this metadata to examine its internal consistency and compliance with our requirements.
10.2.1 Technical metadata
The technical metadata about the creation of digitised images broadly describes the hardware, software, and processes used to create the images. This allows the identification of any systemic issues uncovered during quality assurance process (if one particular scanner is producing poor quality images, or a software package appears to have a bug). Where the images represent digitised records rather than digital surrogates we also need to know when the actions were carried out.
The National Archives requires technical metadata to be delivered as UTF-8 (tools.ietf.org/html/rfc3629) encoded, CSV (Comma Separated Value) text files formatted according to the RFC 4180 specification (tools.ietf.org/html/rfc4180).
10.2.1.1 Explanation of Checksums
The National Archives requires that a checksum based on the SHA256 Cryptographic Hash Function (CHF) be calculated for each final image after metadata has been added, and supplied as part of the image metadata. See: csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf.
This is to ensure that data has not been corrupted in transit. A checksum must also be generated for the metadata files themselves. Upon receipt of the batch, The National Archives recalculates the SHA256 hash value for each of the images and metadata files concerned and confirms that the newly calculated values match the values supplied in the metadata and hash value text files. In the event that the values do not match, the batch or piece(s) within it may be rejected and returned to the supplier.
10.2.1.2 Technical acquisition and technical environment metadata requirements for digitised records
Two metadata files are required for each batch of digitised records; one file describing the technical acquisition metadata and the other file describing the technical environment metadata.
The metadata files are named: tech\_\_<type>\_metadata_v<versionnumber>\_v<batchcode>.csv
Where <type> is either 'acq' for acquisition metadata or 'env' for environment metadata, <versionnumber> is the version of the particular metadata file standard provided by The National Archives and <batchcode> is a unique code for the batch being delivered and that matches the value of the batchcode field in the metadata itself and the volume label of the media the batch is delivered on.
For example: using version 1 of the acquisition metadata file standard and a batch with a batchcode “testbatchY16B001” the file name would be:
```
tech_acq_metadata_v1_testbatchY16B001.csv
```
The checksum for this file would be saved with file name:
```
tech_acq_metadata_v1_testbatchY16B001.csv.sha256
```
The contents of that file would be a string of the form “tech_acq_metadata_v1_testbatchY16B001.csv e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855” where the long string beginning “e3b0c...” is the SHA256 hash value for the file. This should be a simple UTF-8 encoded text file. There are up to 42 technical acquisition metadata fields for paper digitisation projects (not all will be relevant for every project):
- Batch code
- Department
- Division
- Series
- Sub series
- Sub sub series
- Piece
- Item
- Description
- Ordinal
- File UUID
- File path
- File checksum
- Resource URI
- Scan Operator
- Scan ID
- Scan location
- Scan native format
- Scan timestamp
- Image Resolution
- Image width
- Image height
- Image tonal resolution
- Image format
- Image colour space
- Image split
- Image split ordinal
- Image split other UUID
- Image split operator
- Image split timestamp
- Image crop
- Image crop operator
- Image crop timestamp
- Image de-skew
- Image de-skew operator
- Image de-skew timestamp
- Process location
- Jp2 creation timestamp
- UUID time stamp
- Embed timestamp
- QA Code
- Comments Digitisation at The National Archives
For microform or photographic negatives the following three fields will also be added (to give a total of 45 fields):
- image_inversion
- image_inversion_operator
- image_inversion_timestamp
For microform the following field may also be added (to give a total of 46 fields):
- fiche reference
For further information see Appendix A Technical acquisition metadata for digitised records.
There are eight technical environment metadata fields for digitised records:
- Batch code
- Company name
- Image de-skew software
- Image split software
- Image crop software
- Jp2 creation software
- UUID software
- Embed software
For microform or photographic negative projects, a further field is added (giving a total of nine):
- Image inversion software
For further information see Appendix B Technical environment metadata for digitised records.
10.2.1.3 Technical acquisition metadata requirements for digital surrogates
One metadata file should be delivered with each batch of digital surrogates; this file describes technical acquisition metadata. The naming of this file and checksum file is as above.
There is no technical environment metadata required for digital surrogates.
There are up to 30 technical acquisition metadata fields for digital surrogates. They are a sub-set of those required for digitised records:
- Batch code
- Department
- Division
- Series
- Sub series Digitisation at The National Archives
- Sub sub series
- Piece
- Item
- Ordinal
- Description
- File UUID
- File path
- File checksum
- Resource URI
- Scan operator
- Scan ID
- Scan location
- Image resolution
- Image width
- Image height
- Image tonal resolution
- Image format
- Image compression
- Image colour space
- Image split
- Image split ordinal
- Image split other UUID
- Image crop
- Image de-skew
- Comments
For further information see Appendix C Technical acquisition metadata requirements for digital surrogates.
10.2.2 Transcription metadata
Transcription metadata is more variable in content, dependent on the records to be transcribed. However, this section lays out some general principles relating to The National Archives’ desired approach to transcription, particularly in relation to common pieces of data to be transcribed such as names, dates and addresses.
Previous experience has shown that two elements of transcription can be particularly difficult to deal with:
- ordering images into the correct sequence to form ‘documents’ of correctly ordered pages
- dates - in terms of onward processing due to the large numbers of possible combinations of format (day, month or year) being missing or partially unreadable (or occasionally nonsensical - 30 February) The National Archives believes that the complexity of dealing with these issues can be reduced in the following ways:
10.2.2.1 Ordering images
An ordinal number in the metadata records the position of a single image within its parent Piece or Item. This allows images to be reordered at any time within the boundaries of a Piece or Item without renaming files.
However, should an image need to move from one Piece or Item to another this would be reflected in the ordinals, but would additionally require a rename and move of the image.
Ordinals are context sensitive, which is to say they are only unique within their Parent container, and as such should start from 1 within each Item or Piece and be incremented sequentially. If, as part of the transcription process, it is also required that material previously arranged only at Piece level is split into Items, there is no need to rename files; just record each new item in the CSV with the relevant ordinals.
So if piece 1 originally contained 12 images which transcription shows should be split into 3 items:
- item 1 might consist of the first 3 images, 0001.jp2, 0002.jp2, 0003.jp2 with ordinals 1, 2 and 3 respectively (within item 1)
- item 2 the next 5 images, 0004.jp2, 0005.jp2, 0006.jp2, 0007.jp2 0008.jp2 with ordinals 1, 2, 3, 4 and 5 respectively (within item 2)
- item 3 the final 4 images 0009.jp2, 0010.jp2, 0011.jp2, 0012.jp2 with ordinals 1, 2, 3 and 4 respectively (within item 3)
10.2.2.2 Dates
Transcribing the date parts separately will make it easier to check the status (missing, incomplete and so on) of each part without complicated parsing. Also the ability to disambiguate between omitted transcription dates and dates that were truly missing from the original allows for some automated quality assurance (QA) checking.
See Appendix D for an example of the types of fields required in a transcription metadata CSV file. 11 Validation of scanned images and external metadata
11.1 Metadata validation
The National Archives undertakes a variety of tests on the metadata to ensure it is internally consistent. Where values such as UUIDs can be repeated in different fields for the same image (for example, in both the UUID field and as part of the image URI) we will check that the same value is given in each case. We also check that rows are not duplicated. Where we have specified particular data types, character sets or character patterns, these will also be validated.
The primary tool used for this is our CSV Validator, working with our CSV Schema language. Full details of these can be found at http://digital-preservation.github.io/csv-validator/. The relevant schema for a project will be supplied in advance of imaging (and usually with the project ITT). For ease of reference the schema name will match that of the metadata file to which it applies, but with the numeric part of the reference set to zeroes, and with the format extension .csvs. So, for the example metadata filename given above, tech_acq_metadata_v1_testbatchY16B001.csv, the related schema would be tech_acq_metadata_v1_testbatchY16B000.csvs.
11.2 Image validation
The National Archives expects its suppliers to carry out general quality assurance on images through a defined process which tests all aspects of the specification laid out above. Suppliers give details of the process to The National Archives at the start of a project and provide regular reports on the application of the process and issues detected.
During our image QA process, if we find any missing images we will flag these to the scanning supplier and they will need to scan the missing images, insert them into the correct location within the piece, renumber all subsequent image numbers, update the .CSV files and redeliver either the whole batch or resubmit individual piece(s) as part of later batches back to us.
We use programmatic techniques to validate all images ensuring general compliance with the JPEG2000 part 1 specification and with the specific profiles laid out in this document (including the embedding of image metadata) see 11.2.1 Tools for validation, below. Non-compliant images are rejected and are regenerated (if necessary by rescanning).
The tools and scripts used by us are freely available and are listed in sections 11.2.1 and 11.2.2 of this document. Some individual scripts will also be developed for particular projects and made available to suppliers on request. We suggest suppliers to The National Archives incorporate these, or similar tools, into internal QA process in order to reduce the likelihood of images being rejected. Up to 10% of images per batch on every project may be inspected. Evaluation may cover:
- correctness of mode
- correctness of resolution
- correctness of image size
- lack of sharpness
- loss of detail or image corruption
- correctness of orientation
- correctness of cropping
- skew
- overall too dark or light
- overall too low or high contrast
- correctness of file name, and
- correctness and completeness of metadata
If the random sampling suggests that more than 1% of the total batch fails to meet the required standards then the entire batch is returned to the suppliers for further quality control examination and rescanning as necessary. Where smaller proportions of images do not meet our standards only the piece(s) containing those images will be rejected from the batch and the rest of the batch will continue through the ingest process. Those piece(s) should then be resubmitted within later batches.
We can then inspect any re-scanned images if necessary. We notify suppliers of any errors found during the technical and visual QA processes by sending them a CSV file or alternative reporting formats as agreed, for example:
| Field | Data Format | Description | Options or Example | |------------|--------------------------------------------------|-----------------------------------------------------------------------------|--------------------| | batch_code | Up to 16 alpha-numeric characters | An identifier for each batch of records. The same batch number will be included in the first row of every metadata file related to that batch of records | testbatchY16B001 | | file_uuid | Universally unique identifier (UUID) - must adhere to UUID Version 4 format see www.ietf.org/rfc/rfc4122.txt | Universally unique identifier embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | | Field | Data Format | Description | Options or Example | |---------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------| | file_path | Must be a valid URI see [www.ietf.org/rfc/rfc3986.txt](http://www.ietf.org/rfc/rfc3986.txt) | Location of file on storage as specified in the competition. For example: DeptCode/SeriesNo/Piece_Number_ItemNo_ImageNumber_ItemNo_ImageNumber.jp2 | file:///WO/409/27_1/1/27_1_0001.jp2 | | file_checksum | Must adhere to the SHA-256 standard and be expressed in lower-case hexadecimal characters, see [csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf](http://csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf) | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855 | | error_description | From list below | | |
**Error description**
- Incorrect mode
- Incorrect resolution
- Incorrect image size
- Lack of sharpness
- Loss of detail or image corruption
- Incorrect orientation
- Incorrect cropping
- Skew
- Overall too dark
- Overall too light
- Incorrect file name
- Incorrect header information
- Incomplete header information 11.2.1 Tools for validation
11.2.1.1 Tools for JPEG2000 format validation
As the JPEG2000 format is relatively new, experience has shown that not all tools/encoders implement the standard correctly in all scenarios. Therefore, the recommended approach is to use a combination of tools to increase confidence in the validity of the image.
Tools employed by The National Archives have included:
**Jasper Imginfo 1.900.1**
Imginfo is part of the Jasper toolkit which is a reference implementation for the JPEG2000 standard. Imginfo parses the entire codestream to output information about the JPEG2000 codestream. The parser may fail if the image is not valid. This tool extracts minimal technical metadata such as height and width of the image in pixels. It has been found to be useful in reporting corruption in the image code-stream that can result in visual distortion or artefacts. See [www.ece.uvic.ca/~frodo/jasper/](http://www.ece.uvic.ca/~frodo/jasper/)
**OPF jpylyzer**
Jpylyzer was produced by Johan van der Knijff for the Open Planets Foundation; it validates the JPEG2000 file structure by performing tests against the published standard and also extracts file properties. The result of this tool should indicate that the file is valid JP2 and the values extracted by the tool for levels, layers and so on meet the requirements set out in this document. See [www.openplanetsfoundation.org/software/jpylyzer](http://www.openplanetsfoundation.org/software/jpylyzer)
It is possible for these tools to be wrapped or incorporated within automated validation workflows. We would strongly promote the use of such tools to check conformance of generated JP2 files with the latest published standard and to ensure that they also match the relevant The National Archives profile.
11.2.1.2 Tools for XML metadata validation
The XML document generated to embed into the JPEG2000 images must be valid according to an XML Schema provided by The National Archives, as above. To ensure the validity of the XML document, various tools exist for validating it against the Schema. Some of the more popular include:
- Apache Xerces: [xerces.apache.org](http://xerces.apache.org)
- Saxonica Saxon EE: [www.saxonica.com](http://www.saxonica.com)
- LibXml xmllint: [xmlsoft.org/xmllint.html](http://xmlsoft.org/xmllint.html) 12 Folder structure
The National Archives requires all images to be delivered in a folder structure which reflects the original archival hierarchy of the records.
It may sometimes be necessary to extend this hierarchy by adding more detailed cataloguing information to identify (for example) the images which relate to a single individual or those which represent a particular month’s reports.
Example of such a folder structure based on a recent project:
```
AIR79Y16B001 (Batch ID – series reference Y year batch)
AIR_79 (department and series level folder)
content (content folder)
205 (piece level folder)
18727 (item level folder)
205_18727_0001.jp2 (file level)
```
The catalogue reference for this image would be AIR 79/205/18727.
The filenames quoted above are deliberately neutral to stress that files will be identified and managed through the folder structure and the unique identifier embedded in each file.
At The National Archives an item is defined as all the images relating to a single individual or other appropriate grouping.
In some instances, there may be images which do not obviously relate to the previous or subsequent item. Such images are generically referred to as orphans.
As part of The National Archives’ own in-house QA process to quality assure scanned images we check anything identified as an orphan. If necessary we will also advise on how material which has been missed during the scanning process should be integrated into the folder structure.
Images are delivered in one or more batches. All the metadata files for a batch should be at the content folder level of this folder structure with their respective checksum files, alongside the content folder rather than inside it. Each batch would contain a single file system of the layout specified. A batch will Digitisation at The National Archives
normally comprise several pieces, but please note that an individual piece should arrive within a single batch, not split across multiple batches.
Example of the location of metadata files within the folder structure:
```
AIR_79 (department and series level folder)
tech_acq_metadata_v1_AIR79Y16B001.csv
tech_env_metadata_v1_AIR79Y16B001.csv
tech_acq_metadata_v1_AIR79Y16B001.csv.sha256
tech_env_metadata_v1_AIR79Y16B001.csv.sha256
tech_acq_metadata_v1_AIR79Y16B000.csv
tech_env_metadata_v1_AIR79Y16B000.csv
content (content folder)
```
13 Overview of the process
The scanning process used must ensure that both sides of all pages are captured (even if blank) only once. Record details of the scanning machine used and a code for the operator.
Perform any tasks such as cropping, de-skewing and image splitting as required. Record software used and operator.
If scanning software does not produce .jp2 files natively, then convert images. Record details of all conversion software used. Retain original images until all quality assurance (QA) is completed and The National Archives confirms they can be destroyed.
Since the final filename is required to contain elements of the catalogue reference, and to contain a number to indicate its position within an individual record, it may not be possible to construct this filename at this point of the scanning process. There should be a repeatable (and auditable) process for this allocation.
As well as external technical acquisition (for digitised records and digital surrogates) and environment metadata (for digitised records only) The National Archives requires a variety of XML elements to be embedded into the .jp2 images to assist with long-term management of the files. Since this includes the catalogue reference, allocation into the archival hierarchy must have been completed by this stage.
To allow long-term assurance that the file received is the same as when originally created and has not been corrupted or tampered with a SHA256 checksum should be calculated for each image file - this should be stored in the metadata spreadsheet. A checksum for the spreadsheet itself is also required. Appendix A: Technical acquisition metadata for digitised records
All fields listed below record details of every individual image and the processes carried out on it before delivery to The National Archives. These fields will be the column headings in the metadata CSV file.
| Field | Data format | Description | Options or example | Justification | Consistency check | |---------------|-------------|-------------------------------|--------------------|-------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | TestbatchY16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | series | Up to 8 characters | Archival hierarchy | 79 | | | | sub_series | Up to 8 characters | Archival hierarchy | | | May be empty | | sub_sub_series| Up to 8 characters | Archival hierarchy | | | May be empty | | piece | Up to 8 characters | Archival hierarchy | 1 | | | | item | Up to 8 characters | Archival hierarchy | 2 | | May be empty | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------|-----------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|---------------------------------------------------------| | description| Unstructured text| Catalogue description provided by the Authority for each piece/item. | 2 Infantry Brigade: 2 Battalion King's Royal Rifle Corps. | Required for the Authority's ingest process, and will also support QA as the description and date range shown can be sense checked against the captured images | Must match values supplied by The Authority | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | ordinal | Integer starting from 1 | Describes the order of a file within an item. Should start at 1 within each item. See the note on ordering images above | 1 | To keep the images in order. | Expected range will usually be checked, along with a uniqueness check on the combination of piece, item and ordinal | | file_uuid | Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: [http://www.ietf.org/rfc/rfc4122.txt](http://www.ietf.org/rfc/rfc4122.txt) | Universally Unique Identifier for the image embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | QA - and unique identification of digitised records and digital surrogates for efficient processing | Aim is to ensure all image files are delivered once and only once. Check the UUID against the UUID that forms part of the URI and also against the UUID embedded in the file at the file_path provided, to ensure they match | | file_path | The file path to the image. Must be a valid URI, see: [http://www.ietf.org/rfc/rfc3986.txt](http://www.ietf.org/rfc/rfc3986.txt) | Location of file relative to the root of the file system containing the batch | file:///AIR_79/content/1/2/1_2_0001.jp2 | QA | All image files on the file system provided must have a row in this metadata file and all file_path must have a matching file at the location given | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------|-------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|--------------------| | file_checksum | Must adhere to the SHA-256 standard and should be expressed in lower-case hexadecimal characters | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855 | QA - to ensure the image file was received without corruption or tampering | The National Archives will generate a checksum upon receipt of the image and expect it to match the checksum given here | | resource_uri | The URI that is embedded into the Digital Image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | A unique identifier with a predictable pattern | http://datagov.nationalarchives.gov.uk/66/AIR/79/1/2/daf49885-e182-4211-80f7-29bb0bb35112 | QA | The Authority will check that this URI is the same as the URI embedded in the file stored at the file_path provided | | scan_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the scanner that produced the image; this should be an anonymised code that the supplier can decode | ABG001 | QA - the data is anonymised in order that The National Archives does not hold any personal data | Validation by The National Archives | | scan_id | Up to 12 alpha-numeric characters | An individual identifier of the scanning device used to produce the | 002A | QA - specific scanner id to trace back | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|-------------|--------------------------------------------------|--------------------|---------------|------------------------------------| | image | | image | | | problems with an image to a specific machine | | scan_location | Text | Physical location of scanner | The National Archives, Kew, Richmond, Surrey, TW9 4DU | QA | Validation by The National Archives | | scan_native_format | Text | Format and version expressed as text | Cannon Raw v1.4 | Provenance and QA | Validation by The National Archives | | scan_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: [www.w3.org/TR/xmlschema-2/#dateTime](http://www.w3.org/TR/xmlschema-2/#dateTime) | Date and time the paper scan ends | 2010-01-02T02:17:21Z | Provenance | Validation by The National Archives | | image_resolution | Integer | Number in pixels per inch of the image with respect to the original object. | 300 600 | QA | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|-------------|----------------------------------|--------------------|---------------|-----------------------------------------------------------------------------------| | image_width | Integer | Dimensions are always in pixels | 4407 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_height | Integer | Dimensions are always in pixels | 3030 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_tonal_resolution | Value from provided enumeration | 24-bit colour | | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_format | A PRONOM unique identifier (PUID) see: nationalarchives.gov.uk/aboutapps/pronom/puid.htm | The code used to uniquely identify a file format | x-fmt/392 | QA | Validation by The National Archives against the image file stored at the file_path provided. | | image_colour_space | Value from provided enumeration | sRGB | | QA | The Authority will validate this against the image file stored at the file_path provided. | | image_split | Lower case text strings "yes" or "no" | Specifies if the image was the result of an image split | yes | QA | Validation by The National Archives | | Field | Data format | Description | Options or example | Justification | Consistency check | |---------------------|----------------------|-----------------------------------------------------------------------------|--------------------|---------------|-------------------| | image_split_ordinal | Only integers allowed| For composites (see previous field), this field is used to confirm the ordering of the images. Numbering is from top left, along the top row of separate images, then from the left of each successive row (there should be overlap between adjacent images) | 1 2 3 4 5 6 7 8 9 | | Validation by The National Archives |
It may be helpful to use the comments field to provide a more human readable version of this e.g. 1=top left, 2=top middle, 3=top right, 4=middle left, 5=middle middle, 6=middle right, 7=bottom left, 8=bottom middle, 9=bottom right or similar. | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------------------|------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------|---------------|----------------------------------------------------------------------------------| | image_split_other_uuid | One or more (separated by a comma) Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: http://www.ietf.org/rfc/rfc4122.txt | If the image was split, this field must contain the UUIDs of the other images that were split from the same original image as this image. If there more than two images as part of a split, this field may contain multiple UUIDs separated by a comma | 0d0b88c6-9a6e-4731-ace3-b50794c1356b,a2915f99-6efa-45d4-a0c9-8fd2555643ec | QA | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes”\
QA will ensure that the other split images exist, and that they also reciprocally point back to this image through their image_split_other_uuid fields | | image_split_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the split software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that the Authority does not hold any personal data | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes” | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|---------------|----------------------------------------------------------------------------------| | image_split_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: | The date and time the file was split | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes” | | image_crop | Lower case text strings "auto", "manual" or "none" | Specifies if the image was cropped and if it was what type of crop was carried out | auto | QA | is("auto") or is("manual") or is("none") else must be blank | | image_crop_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the crop software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data | Field shall be empty if image_crop = “none” or if image_crop = “auto” and populated with valid data if image_crop = “manual” | | image_crop_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: | The date and time the image was cropped | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if image_crop = “none” and populated with valid data if image_crop = “auto” or if image_crop = “manual” | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------------------|-------------|------------------------------------------------------------------------------|--------------------|---------------|-----------------------------------------------------------------------------------| | image_deskew | Lower case text strings "yes" or "no" | Specifies if the image was deskewed | no | QA | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | image_deskew_operator | Up to 12 alphanumeric characters | Code representing the specific operator using the deskew software that produced the image; this is to be an anonymised code that the supplier can decode | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | image_deskew_timestamp| XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the image was deskewed | 2010-01-02T06:17:21Z | Provenance | Field shall be empty if image_deskew = “no” and populated with valid data if image_deskew = “yes” | | process_location | Text | Physical location of image processing procedures | The National Archives, Kew, Richmond, Surrey, TW9 4DU | Provenance and QA | | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------------------|------------------------------|------------------------------------------------------------------------------|--------------------|---------------|-------------------| | jp2_creation_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the JPEG 2000 image was created | 2012-08-09T09:15:37+01:00 | Provenance | | | uuid_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time the UUID was created for file | 2010-08-02T04:17:21+01:00 | Provenance | | | embed_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: www.w3.org/TR/xmlschema-2/#dateTime | The date and time metadata was embedded in the image file | 2010-01-02T05:17:21+0:00 | Provenance | | | image_inversion | Only valid values allowed: lower case text strings "auto", "manual" | Microform or photographic negative projects only Specifies if the image | auto | Provenance and QA. | Contains only valid values | | Field | Data format | Description | Options or example | Justification | Consistency check | |------------------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | image_inversion_operator | Up to 12 alphanumeric characters | **Microform or photographic negative projects only**<br>Code representing the specific operator using the inversion software that produced the image for a manual inversion; this is to be an anonymised code that the supplier can decode. | ABG001 | Provenance and QA. The data is anonymised in order that The National Archives does not hold any personal data. | Field shall be empty if image_crop = “none” or if image_crop = “auto” and populated with valid data if image_crop = “manual” | | image_inversion_timestamp | XML Schema 1.0 dateTime format with a mandatory timezone: <br>http://www.w3.org/TR/xmlschema-2/#dateTime | **Microform or photographic negative projects only**<br>The date and time the image was inverted | 2010-01-02T06:17:21Z | Provenance. | Field shall be empty if image_crop = “none” and populated with valid data if image_crop = “auto” or if image_crop = “manual” | | Field | Data format | Description | Options or example | Justification | Consistency check | |-----------|-------------|-------------|--------------------|---------------|-------------------| | qa_code | | Codes to use to indicate where information is illegible due to damage to the document. Codes are given in the next column, together with their meaning. Only the letter portion is to be used. Additional codes may be defined for other types of original material. | **For paper:** A. Missing Area: Corner or edge B. Missing area: hole in page C. Tears D. Text obscured by tape or other document (can’t be removed/separated) E. Discolouration or staining of paper (text is difficult to read) F. Ink stains or other spill (text is obscured) G. Faint text H. Blurred or smudged text I. Offsetting of ink to facing page, or bleed through of ink from other side of page. J. Burn damage (from fire or metal corrosion) **Notes:** B. Including intentional holes such as tag holes, and holes from pest damage | This records pre-existing damage to the material being digitised. With surrogates, if it appears information has been lost due to damage to the original, the original may be produced to confirm this. For digitised records this option will not be available | Must be either blank or numbers between 01 and 20 (for paper) or 40-47 (for microform) |
For paper: Single alphabetic character in the range A-J, or a comma separated list of such single characters
For microform: Digits from 40 to 44, or a comma separated list of such double digits | Field | Data format | Description | Options or example | Justification | Consistency check | |-------|-------------|-------------|--------------------|---------------|-------------------| | | | | E. Would include staining from mould damage, discolouration, foxing, water damage etc. | | | | | | | **For microform:** 40: microform scratched 41: illegible: image too dark 42: illegible: image too light 43: Microform breakage 44: No foliation | | | | comments | Text | Operator's comments, may be empty | QA | Populated at the supplier's discretion | Appendix B: Technical environment metadata for digitised records
All fields listed below record details of the technical environment used during the scanning process; this environment should be consistent for all scanned images within a batch, and as such needs only be captured once. These fields will be the column headings in the metadata CSV file.
| Field | Data Format | Description | Example | Consistency Check | |------------------------|-------------------|--------------------------------------------------|--------------------|-----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | TestbatchY16B001 | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | company_name | Text | Name of the company undertaking the process | Bob’s Scan Ltd | | | image_deskew_software | Text | Name and version of the software used for deskewing images | GNU GIMP 2.6 | | | image_split_software | Text | Name and version of the software used for splitting images | GNU GIMP 2.6 | | | Field | Data Format | Description | Example | Consistency Check | |------------------------|-------------|-----------------------------------------------------------------------------|--------------------------|-------------------| | image_crop_software | Text | Name and version of the software used for image cropping | GNU GIMP 2.6 | | | jp2_creation_software | Text | Name and version of the software used for creating the JPEG2000 file from the acquired image | ImageMagick 6.8.0-5 | | | uuid_software | Text | Name and version of the software used to generate the UUID. If programmatic, use the software library name and version | Oracle Java JDK 1.6 | | | embed_software | Text | Name and version of the software used to embed the metadata into the image | Luratech Lurawave 11a | |
### Appendix C: Technical acquisition metadata requirements for digital surrogates
All fields listed below record details of every individual image and the processes carried out on it. These fields will be the column headings in the metadata CSV file.
| Field | Data Format | Description | Options or Example | Justification | Consistency Check | |----------------|-------------|-------------------------------|--------------------|-------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | batch_code | Up to 16 alphanumeric characters | An identifier for each batch of records | testbatchY16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |------------|-------------------|----------------------|--------------------|---------------|-------------------| | series | Up to 8 characters| Archival hierarchy | 79 | | | | sub_series | Up to 8 characters| Archival hierarchy | | | May be empty | | sub_sub_series | Up to 8 characters| Archival hierarchy | | | May be empty | | piece | Up to 8 characters| Archival hierarchy | 1 | | | | item | Up to 8 characters| Archival hierarchy | 2 | | May be empty | | ordinal | Integer starting from 1 | Describes the order of a file within an item. Should start at 1 within each item. See the note on ordering images above | 1 | To keep the images in order. | Expected range will usually be checked, along with a uniqueness check on the combination of piece, item and ordinal | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |-----------|------------------------------|------------------------------------------------------------------------------|------------------------------|--------------------------------------------------------------------------------|--------------------------------------------------------| | description | Unstructured text | Catalogue description provided by the Authority for each piece/item. | 2 Infantry Brigade: 2 Battalion King's Royal Rifle Corps. | Required for the Authority's ingest process, and will also support QA as the description and date range shown can be sense checked against the captured images | Must match values supplied by The Authority | | file_uuid | Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: [www.ietf.org/rfc/rfc4122.txt](http://www.ietf.org/rfc/rfc4122.txt) | Universally Unique Identifier for the image embedded in every image | daf49885-e182-4211-80f7-29bb0bb35112 | QA and unique identification of digitised records and digital surrogates for efficient processing | Aim is to ensure all image files are delivered once and only once | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------|-------------|------------------------------------------------------------------------------|--------------------|---------------|-------------------| | file_path | The file path to the image. Must be a valid URI, see www.ietf.org/rfc/rfc3986.txt | Location of file relative to the root of the file system containing the batch | file:///AIR_79/1/2/0001.jp2 | QA | All image files on the file system provided must have a row in this metadata file and all file_path must have a matching file at the location given | | file_checksum | Must adhere to the SHA-256 standard and should be expressed in lower-case hexadecimal characters, see: csrc.nist.gov/publications/fips/fips180-3/fips180-3_final.pdf | A checksum of the image file conformant with the SHA256 standard | e3b0c44298fc1c149afbf4c8996fb92427a4e4649b934ca495991b7852b855 | QA | The National Archives will generate a checksum upon receipt of the image and expect it to match the checksum given here | | resource_uri | The URI that is embedded into the Digital Image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | A unique identifier with a predictable pattern | http://datagov.nationalarchives.gov.uk/66/AIR/79/1/2/daf49885-e182-4211-80f7-29bb0bb35112 | QA | The Authority will check that this URI is the same as the URI embedded in the file stored at the file_path provided | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |-------------------|------------------------------|------------------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|-------------------| | scan_operator | Up to 12 alpha-numeric characters | Code representing the specific operator using the scanner that produced the image; this should be an anonymised code that the supplier can decode | ABG001 | QA - the data is anonymised in order that The National Archives does not hold any personal data | | | scan_id | Up to 12 alpha-numeric characters | An individual identifier of the scanning device used to produce the image | 002A | QA - specific scanner id to trace back problems with an image to a specific machine | | | scan_location | Text | Physical location of scanner | The National Archives, Kew, Richmond, Surrey, TW9 4DU | QA | | | image_resolution | Integer between 1 and 10000 | Number in pixels per inch of the image with respect to the original object | 300 | QA | Validation by The National Archives | | image_width | Integer | Dimensions are always in pixels | 4407 | QA | Validation by The National Archives | | image_height | Integer | Dimensions are always in pixels | 3030 | QA | Validation by The National Archives | | image_tonal_resolution | Value from provided enumeration | | 24-bit colour | QA | Validation by The National Archives | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------------|------------------------------------------------------------------------------|------------------------------------------------------------------------------|--------------------|---------------|----------------------------------------| | image_format | A PRONOM unique identifier (PUID) see: [www.nationalarchives.gov.uk/aboutapps/pronom/puid.htm](http://www.nationalarchives.gov.uk/aboutapps/pronom/puid.htm) | The code used to uniquely identify a file format | x-fmt/392 | QA | Validation by The National Archives | | image_compression | Integer between 1 and 99 | The value of N in the lossy image compression ratio N:1 used to compress the image. Note: 1:1 means no-compression employed | 6 | QA | Validation by The National Archives | | image_colour_space | Value from provided enumeration | | sRGB | QA | The Authority will validate this against the image file stored at the file_path provided | | image_split | Lower case text strings "yes" or "no" | Specifies if the image was the result of an image split | yes | QA | | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |---------------------|----------------------|-----------------------------------------------------------------------------|--------------------|---------------|-------------------| | image_split_ordinal | Only integers allowed| For composites (see previous field), this field is used to confirm the ordering of the images. Numbering is from top left, along the top row of separate images, then from the left of each successive row (there should be overlap between adjacent images) | 1 2 | | Validation by The National Archives | | | | Or | 3 4 | | | | | | Etc. | 1 2 3 | | | | | | | 4 5 6 | | | | | | | 7 8 9 | | | | | | | Etc. | | | | | | | It may be helpful to use the comments field to provide a more human readable version of this e.g. 1=top left, 2=top middle, 3=top right, 4=middle left, 5=middle middle, 6=middle right, 7=bottom left etc. | | | | Field | Data Format | Description | Options or Example | Justification | Consistency Check | |-----------------------|-------------|------------------------------------------------------------------------------|-----------------------------------------------------------------------------------|---------------|-------------------| | image_split_other_uuid| One or more (separated by a comma) Universally Unique Identifier (UUID). Adhering to UUID Version 4 format and expressed in lower-case hexadecimal characters, see: www.ietf.org/rfc/rfc4122.txt | If the image was split, this field must contain the UUIDs of the other images that were split from the same original image as this image. If there are more than two images as part of a split, this field may contain multiple UUIDs separated by a comma. | 0d0b88c6-9a6e-4731-ace3-b50794c1356b,a2915f99-6efa-45d4-a0c9-8fd2555643ec | QA | Field shall be empty if Image_split = “no” and populated with valid data if Image_split = “yes”. TNA QA will ensure that the other split images exist, and that they also reciprocally point back to this image through their image_split_other_uuid fields. | | image_crop | Lower case text strings "auto", "manual" or "none" | Specifies if the image was cropped and if it was what type of crop was carried out | auto | QA | | | image_deskew | Lower case text strings "yes" or "no" | Specifies if the image was deskewed | no | QA | | | comments | Text | Operator’s comments, may be empty | | QA | Populated at the supplier’s discretion |
## Appendix D: An example of the types of fields required in a transcription metadata CSV file
| Field | Data Format | Note | Options or Example | Justification | Consistency Check | |----------------|------------------------------|-------------------------------------------|--------------------|--------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | batch_code | Up to 16 alpha-numeric characters | An identifier for each batch of records. Supplied by the Authority | Testbatch Y16B001 | For consistency and cross checking with other data delivered as part of the batch | The National Archives will cross check this against the batch_code with the naming of the file and the volume label | | department | Up to 8 characters | Archival hierarchy | AIR | | | | division | Up to 8 characters | Archival hierarchy | 6 | | May be empty | | series | Up to 8 characters | Archival hierarchy | 79 | | | | sub_series | Up to 8 characters | Archival hierarchy | | | May be empty | | sub_sub_series | Up to 8 characters | Archival hierarchy | | | May be empty | | piece | Up to 8 characters | Archival hierarchy | 1 | | | | item | Up to 8 characters | Archival hierarchy | 2 | | May be empty | | metadata_type | Up to 12 alpha-numeric characters. Taken from an enumeration | Valid metadata types are provided by The National Archives along with a list of enumerated values | ITWW01 | For enabling us to validate the content of a row based on the data expected in that row | The metadata_type is a code describing which fields must and should be completed in any particular row. Rows will be validated using this code | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|----------------------------------------------------------------------------|----------------------------------------------------------------------|----------------------------------------------------------------------------------|--------------------------------------------------------------------------------|-------------------| | file_path | The file path to the image. Must be a valid URI, see: www.ietf.org/rfc/rfc3986.txt | Location of file relative to the root of the file system containing the batch | file:///AIR_79/content/1/2/1_2_0001.jpg | The file must exist | | | ordinal | Integer starting from 1 | Describes the order of a file within an item or piece. Should start at 1 within each piece or item. See the textual explanation of 'Ordering' above | 1 | | | | uuid | Must adhere to UUID Version 4 format www.ietf.org/rfc/rfc4122.txt | The UUID read from the image | c87fc84a-ee47-47ee-842c-29e969ac5131 | Uniquely identifies each image | | | first_date_day| 2 digits - zero padded as appropriate. ? or ?? are used to indicate where individual digits are illegible in the original. If the original is blank then use a single * character | This field will also need to accept impossible dates such as 30 February or 31 April. The first and last dates are intended to capture the date range of the document and may be supplied as a fixed range | 1? | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |------------------|------------------------------------------------------------------------------|----------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|--------------------| | first_date_month | In full, title-case, no leading or trailing spaces, no punctuation, ? to indicate where characters are illegible. If the original is blank then use a single * character | | February | | | | first_date_year | 4 digits, no leading or trailing spaces, no punctuation, ? to indicate where characters are illegible. ???? to indicate where completely illegible. If the original is blank then use a single * character | For 2 digit years in the original The National Archives will provide advice on a Further Competition basis to establish the century. | ??14 | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|----------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------|---------------|-------------------| | last_date_day | 2 digits zero padded as appropriate.? or ?? are used to indicate where individual digits are illegible in the original. If the original is blank then use a single * character | This field will also need to accept impossible dates such as 30 February or 31 April. The first and last dates are intended to capture the date range of the document and may be supplied as a fixed range | 03 | | | | last_date_month | In full, title-case, no leading or trailing spaces, no punctuation, ? to indicate where characters illegible. If the original is blank then use a single * character | | December | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |---------------|------------------------------------------------------------------------------|----------------------------------------------------------------------|--------------------|--------------------------------------------------------------------------------|-------------------| | last_date_year | 4 digits, no leading or trailing spaces, no punctuation, ? to indicate where characters illegible. ???? to indicate where completely illegible. If the original is blank then use a single * character | For 2 digit years in the original The National Archives will provide advice to establish the century | 1897 | | | | description | | Different for every collection - could be structured in a number of fields or a single field with a short narrative | | | | | language | Three characters representing the ISO 639-3 standard language identification code, see: www.iso.org/iso/catalogue_detail?csnumber=39534 and www.sil.org/iso639-3/default.asp | If all material is in English, this field will not be required. | eng | | | | Field | Data Format | Note | Options or Example | Justification | Consistency Check | |-----------|-------------|-------------------------------------------|--------------------|---------------|----------------------------------------| | comments | Text | For transcription staff’s comments, may be empty | QA | Populated at the supplier’s discretion |
| olmocr | 2025-03-31T00:00:00 | 2025-03-31T00:00:00 | {
"Source-File": "/workspace/input-pdfs/2251-pdf.pdf",
"olmocr-version": "0.1.60",
"pdf-total-pages": 60,
"total-input-tokens": 131641,
"total-output-tokens": 21727,
"total-fallback-pages": 0
} | {
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505162fabc813b73de0056f00244679101842044 | Direct Payments City of York Council Internal Audit Report 2017/18
Business Unit: Adult Social Care Responsible Officer: Assistant Director Adults and Social Care Service Manager: Head of Safeguarding & Mental Health Head of Adult Social Care Head of Customer, Resident & Exchequer Services
Date Issued: 6 April 2018 Status: Final Reference: 11480/007
| Actions | P1 | P2 | P3 | |---------|----|----|----| | Overall Audit Opinion | Reasonable Assurance | Summary and Overall Conclusions
Introduction
Direct Payments are local health and social care payments for people who have been assessed as needing help from social services and who would prefer to arrange and pay for their own care and support rather than to receive services directly from the local authority. The aim of Direct Payments is to allow the service user greater choice and control through the flexibility of being able to purchase their own care package. The Care Act (2014) mandated Direct Payments for the first time in certain circumstances, effective from April 2015. Sections 31 to 33 of the Act set out the duties of local authorities in respect of these payments.
Over £5 million in Direct Payments were made during 2016-17. As of 15 June 2017, the council has 264 Direct Payment customers. Of these 264 customers, 90 have self-managed accounts with 82 receiving payments via prepaid cards and eight receiving payments into a designated bank account. Following the move to a Personal Budget Model in October 2016, the remaining 174 customers have a managed account with a support provider on the council’s approved provider list.
Objectives and Scope of the Audit
The purpose of this audit was to provide assurance to management that procedures and controls within the system ensure that:
- Self-managed, prepaid card accounts;
- Designated personal bank accounts; and
- Accounts managed by third party support providers
are monitored and reconciled appropriately and support plans are reviewed to ensure that they continue to meet the needs of the customer.
The previous audit carried out in 2015-16 received a Limited Assurance opinion. This audit followed up the actions that were agreed to ensure that the issues and control weaknesses had been satisfactorily addressed.
Key Findings
It was found that Direct Payment accounts are not consistently monitored according to council policy. While reconciliations for managed and self-managed prepaid card accounts had been performed, they were not always timely. Reconciliations were largely accurate but some minor errors were observed with contingency items being omitted. The accounts of customers receiving their Direct Payment into a designated bank account are not subject to appropriate levels of monitoring. Just one of the nine accounts reviewed had been reconciled in line with policy and for four accounts there was no evidence available on Mosaic that any reconciliation had been performed.
Some additional weaknesses in the carrying out of monitoring processes were also observed. Newly commissioned Direct Payments are monitored more consistently than was the case at the time of the previous audit but still only half of the accounts tested had been monitored at the intervals required by the Direct Payments policy. Furthermore, account surpluses and deficits are routinely identified but are not always acted upon.
Finally, it was found that customer support plans are not routinely reviewed on an annual basis as is required by council policy with some reviews having been delayed for between four and 13 months.
**Overall Conclusions**
The arrangements for managing risk were satisfactory with a number of weaknesses identified. An acceptable control environment is in operation but there are a number of improvements that could be made. Our overall opinion of the controls within the system at the time of the audit was that they provided Reasonable Assurance. 1 Timeliness of reconciliations for prepaid card accounts
| Issue/Control Weakness | Risk | |------------------------|------| | The accounts of customers with prepaid cards are not monitored in accordance with council policy. | Customers may misuse their Direct Payment or fail to pay their assessed contribution. Budget provision may be affected by the accrual of account surpluses or failure to recover funds. |
Findings
Of the ten managed accounts tested, three had not been reconciled by October 2017 and thus were delayed at the time of audit testing. A further ten self-managed accounts were tested and none of these reconciliations had been completed within 12 months of the period up to which the previous reconciliation had been performed. While reconciliations for five accounts were not significantly delayed, for the remaining five reconciliations delays were significant (more than three months for one recently completed reconciliation) or were overdue at the time of audit testing with no evidence on Mosaic that they had been performed.
Agreed Action 1.1
The scheduling of account reconciliation will be managed by the Income Services Manager. Cases will be allocated to officers one month in advance of the review date.
The working practice within Income Services has been to reconcile all accounts, including managed accounts. However, it is the responsibility of the support provider to undertake the reconciliation and delays in resolving managed account reconciliations has had the effect of delaying the commencement of self-managed account reconciliations. Income Services will no longer reconcile managed accounts.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 2 | Income Services Manager | Implemented |
## 2 Designated bank account reconciliations
| Issue/Control Weakness | Risk | |------------------------|------| | The accounts of customers who receive Direct Payments into a designated bank account are not reconciled in accordance with council policy. | Customers may misuse their Direct Payment or fail to pay their assessed contribution. Budget provision may be affected by the accrual of account surpluses or failure to recover funds. |
### Findings
Based on the data provided there were nine Direct Payment customers who received the payments into a designated bank account at the time of audit testing. For five of these accounts there were no reconciliations available on Mosaic (although one account was opened in April 2017 and so the first reconciliation was not due at the time of audit testing). A further two accounts had been reconciled most recently in 2014 and 2015. Therefore, just one account had been reconciled in accordance with the council’s Direct Payments policy.
### Agreed Action 2.1
The Direct Payments policy will be presented to the Direct Payments Group for review and clarification will be sought regarding roles and responsibilities.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 2 | Head of Service – Adult Safeguarding, DoLS, Mental Health and Learning Disabilities | May 2018 | 3 Allowance for agreed contingencies
| Issue/Control Weakness | Risk | |---------------------------------------------------------------------------------------|----------------------------------------------------------------------| | Agreed contingency items are not routinely accounted for in reconciliations. | Insufficient funds are available in the customer's account to be able to meet employer obligations. |
Findings
Of the 20 Direct Payment accounts tested, six did not employ a personal assistant and so a DP2 reconciliation report had not been submitted. In a further two cases, customers employed a personal assistant but had not submitted a DP2. No reconciliations were on file for one customer. This left a population of 11 accounts for which a DP2 form had been submitted and the full range of contingency costs could be reviewed. Of these 11 accounts, employers' liability insurance had not been factored into the reconciliation on four occasions despite being recorded on the DP2 form (employee holidays provided were also not factored into one of these reconciliations). More generally, support costs and other contingencies were found not to have been included on the DP2s submitted. This issue was observed in the 2015/16 audit but it is the responsibility of the customer, nominated person or support provider to provide this information.
Agreed Action 3.1
DP2s will be checked and returned to the customer, nominated person or support provider if information appears to be missing or where the DP2 and Audit Reconciliation worksheet do not match. An additional seven days will be allowed for the return of this information.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 3 | Income Services Manager | Implemented | 4 Account monitoring
| Issue/Control Weakness | Risk | |------------------------|------| | Newly commissioned Direct Payment accounts are not monitored with the frequency required by council policy. | Financial loss to the council as the Direct Payment is used to pay for items which are not included in the customer's support plan. The customer fails to manage their finances correctly and thus has insufficient funds to meet their care needs. |
Findings
Only one of the 10 accounts initially tested had been monitored at two, four and sixth months after the Direct Payment was commissioned as per the Direct Payments policy. However, all accounts had at least been monitored once within six months from commissioning and nine accounts had been monitored twice within this period. Although not fully compliant with the policy, this represents a marked improvement from the previous audit whereby no new accounts were monitored before six months after commissioning.
During the audit Income Services advised that the Direct Payment Monitoring workstep (the workflow item within the system which schedules account monitoring tasks) had not been configured until May 2017. Re-testing performed showed an increase in the performance of account monitoring from June 2017 onwards but still half of new or amended accounts had not been monitored at the frequency required by the Direct Payments policy.
Agreed Action 4.1
Action undertaken at 1.1 should go some way to improving this issue and a system will be put in place to check, on a weekly basis, that all new Direct Payments are correctly scheduled for monitoring every two months for the first six months. Approval has been obtained from the Assistant Director – Adults and Social Care and the Head of Customer, Resident & Exchequer Services to remove the requirement for intensive monitoring during the first six months where a customer has previously had a successful Direct Payment in place.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 3 | Income Services Operations Manager | Implemented | 5 Surplus reclams
| Issue/Control Weakness | Risk | |------------------------|------| | Failure of Care Management to notify Income Services on a timely basis as to whether or not account surpluses can be reclaimed. | Direct Payment accounts accrue excessive surpluses, affecting the provision of the Direct Payments budget. |
Findings
If a surplus of over £50 after contingencies remains in a Direct Payment account following reconciliation, Income Services is required to notify Care Management as per the Escalation Policy. Care Management are expected to advise Income Services as to whether or not the surplus funds can be reclaimed (and, if not, reasons must be provided) within 28 working days.
Responses to surplus notifications had been received from Care Management in seven instances of the ten identified surpluses tested. Six of these responses had been received within the 28 working day timescale while a response to one notification took 66 working days. A further two notifications had not received a response at the time of audit testing and five months have elapsed for both. In one case, Care Management was not required to send notification to Income Services as the Direct Payment had in fact ended. Therefore, three of nine surplus notifications did not receive a timely response from Care Management and, as such, surpluses have remained in the account for an extended period of time.
Agreed Action 5.1
The Direct Payments policy will be presented to the Direct Payments Group for review and clarification will be sought regarding roles and responsibilities.
| Priority | 2 | |----------|---| | Responsible Officer | Head of Service – Adult Safeguarding, DoLS, Mental Health and Learning Disabilities | | Timescale | May 2018 | 6 Communication around failure to pay customer contribution
| Issue/Control Weakness | Risk | |------------------------|------| | Failure to ensure that all customers pay their assessed contribution. | The care needs of the customer may not be able to be met if insufficient funds are in the account. |
Findings
The Direct Payment Escalation Policy requires that Income Services makes telephone contact with the customer or appointed person and then formal contact via letter where assessed contributions are not being paid. In eight of nine accounts identified as failing to pay the contribution, there was evidence to support the fact that this had been identified and challenged. However, this was not always directly to the customer (for example, a nominated person) as per the Escalation Policy and notifications to Care Management were not always provided or were not timely (after failure to pay the contribution had been confirmed following the most recent reconciliation).
The accounts of seven of the customers had not been brought up to date at the time of audit testing. Identification of non-payment will have been as long ago as November 2016 for two of these accounts. The most recent reconciliations for the five other accounts were performed in February, May and June 2017 so have not been brought up to date for between three and seven months.
Agreed Action 6.1
The Escalation Policy requires that Income Services contact the customer to discuss failure to pay their contribution. If the contribution is not paid the case is then escalated to Care Management. However, Care Management has been unwilling to accept escalated cases unless Income Services has written to the customer. This has caused significant delay in the escalation process and in the resolution of account finances.
The collection of contributions by invoice has been approved by Directorate Management Teams and is to be phased over the 2018/19 financial year to be fully implemented by 31 March 2019. All customer contributions from newly commissioned DPs will be collected by invoice from the start.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 3 | Income Services Manager | Implemented | 7 Annual support plan review
| Issue/Control Weakness | Risk | |------------------------|------| | Support plans are not routinely reviewed every 12 months. | The care needs of the customer change and the support plan is no longer appropriate or proportionate. |
Findings
For three of the 10 Direct Payment accounts tested it was observed that a review of the customer's support plan had not been undertaken on an annual basis and had in fact been significantly delayed by between four and as much as 13 months. Review of case notes and other correspondence on the customers' Mosaic files revealed that scheduling issues had been encountered by the Social Care Manager (e.g. due to customer illness) and that this had contributed to the delay in review. A further three reviews were technically delayed but each by less than one month and so these were considered acceptable. Overall, it appears that annual reviews are not always timely but that this can be complicated by difficulties experienced with scheduling meetings with customers. Nonetheless, some of the delays identified were unreasonable despite the difficulties encountered.
Agreed Action 7.1
It will be ensured that the importance of the annual support plan review is reflected in any review of the Direct Payment policy undertaken by the Direct Payments Group.
| Priority | Responsible Officer | Timescale | |----------|---------------------|-----------| | 2 | Head of Service – Adult Safeguarding, DoLS, Mental Health and Learning Disabilities | May 2018 | Audit Opinions and Priorities for Actions
Audit Opinions
Audit work is based on sampling transactions to test the operation of systems. It cannot guarantee the elimination of fraud or error. Our opinion is based on the risks we identify at the time of the audit.
Our overall audit opinion is based on 5 grades of opinion, as set out below.
| Opinion | Assessment of internal control | |--------------------|------------------------------------------------------------------------------------------------| | High Assurance | Overall, very good management of risk. An effective control environment appears to be in operation. | | Substantial Assurance | Overall, good management of risk with few weaknesses identified. An effective control environment is in operation but there is scope for further improvement in the areas identified. | | Reasonable Assurance | Overall, satisfactory management of risk with a number of weaknesses identified. An acceptable control environment is in operation but there are a number of improvements that could be made. | | Limited Assurance | Overall, poor management of risk with significant control weaknesses in key areas and major improvements required before an effective control environment will be in operation. | | No Assurance | Overall, there is a fundamental failure in control and risks are not being effectively managed. A number of key areas require substantial improvement to protect the system from error and abuse. |
Priorities for Actions
| Priority | Description | |----------|-----------------------------------------------------------------------------| | Priority 1 | A fundamental system weakness, which presents unacceptable risk to the system objectives and requires urgent attention by management. | | Priority 2 | A significant system weakness, whose impact or frequency presents risks to the system objectives, which needs to be addressed by management. | | Priority 3 | The system objectives are not exposed to significant risk, but the issue merits attention by management. | Where information resulting from audit work is made public or is provided to a third party by the client or by Veritau then this must be done on the understanding that any third party will rely on the information at its own risk. Veritau will not owe a duty of care or assume any responsibility towards anyone other than the client in relation to the information supplied. Equally, no third party may assert any rights or bring any claims against Veritau in connection with the information. Where information is provided to a named third party, the third party will keep the information confidential.
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2c46f04144aa9dcc04d507ef40669366e549ab13 | DIRECT LINE INSURANCE GROUP PLC PRIVATE MOTOR INSURANCE MARKET INVESTIGATION RESPONSE TO THE COMPETITION COMMISSION'S STATEMENT OF ISSUES
A. INTRODUCTION AND EXECUTIVE SUMMARY
Direct Line Insurance Group plc (DLG) welcomes the Competition Commission's (the CC) market investigation (the Investigation) into private motor insurance (PMI) and the opportunity to respond to the CC's Statement of Issues published on 12 December 2012 (the Issues Statement).
By way of summary:
- DLG's view is that the separation of cost liability and cost control – the CC's first theory of harm (ToH) – does lead to market dysfunction and can lead to increased costs. DLG believes that this should be the main focus of the CC's Investigation.
- ToH 1 is a complex area involving a mix of statutory provisions and case law precedents. DLG believes it is important that insurers and other industry players do not discriminate between fault and non-fault claims in the repair process. DLG is also conscious that ToH 1 is in part a natural consequence of the third party liability model and so is strongly of the view that any changes to combat this market dysfunction must be carefully considered.
- DLG agrees with the CC that issues relating to bodily injury are best dealt with by the Ministry of Justice but also believes that similar considerations apply to ToH 4; these issues fall within the remit of the Financial Services Authority (the FSA) / Financial Conduct Authority (the FCA). For example, the FSA has announced a study into general insurance products sold as add-ons and is also carrying out a thematic review of Motor Legal Expenses Insurance. DLG therefore suggests that ToH 4 is best dealt with by the FSA/FCA.
- DLG welcomes the CC's consideration of price comparison websites (PCWs), but believes that the use by PCWs of most favoured nation clauses (MFNs) has greater potential to create consumer detriment and to restrict competition (both between PCWs through price harmonisation, but also between insurers through restrictions on pricing between channels) than the CC has indicated in its Issues Statement. DLG believes that these clauses merit further investigation by the CC.
- The PMI market is highly competitive and DLG believes that consumers do and will continue to benefit from this competitive environment. This provides incentives for insurers to invest in their repair network – as DLG has done – in order to minimise the cost and maximise the quality of repairs. Any changes contemplated by the CC should not, therefore, disincentivise insurers from making these investments.
[CONFIDENTIAL]
DLG sets out in Section B below its response to each ToH raised by the CC. B. THE CC'S THEORIES OF HARM
1. Harm arising from the separation of cost liability and cost control (moral hazard)
(a) ToH 1 should be the focus of the CC's Investigation
1.1 DLG agrees that the current structure of the PMI market – whereby in non-fault claims the person receiving a particular service (i.e. the repair of a vehicle or the provision of a replacement vehicle) does not pay for that service, but instead a third party (insurer) covers those costs – can create incentives which can cause market distortions and can generate cost inflation at a market-wide level. DLG believes that ToH 1 should be the focus of the CC's Investigation.
1.2 DLG believes it is important that insurers and other industry players do not discriminate between fault and non-fault claims. DLG does not:
(a) apply differentiated labour rates for fault and non-fault work; nor does it charge different labour rates dependent upon who is ultimately responsible for the payment of that repair cost, i.e. DLG or a third party insurer;
(b) differentiate between fault and non-fault work in the management of repair periods;
(c) differentiate in its specification, quality or supply of parts, paints and consumables for fault and non-fault repairs;
(d) receive referral fees from its network of repairers for referring repair work to them (e.g. through membership fees); or
(e) outsource third party repairs to credit repair agencies.
1.3 DLG notes, however, that this is a highly complicated area and that in assessing this ToH, the CC will need to take into account a number of different factors which DLG sets out below.
(a) The way in which the PMI market currently operates is based on statute and a series of English court decisions. These provide a clear legal precedent as to the rights of:
(i) the non-fault party, for example, who is entitled to receive a replacement vehicle of a similar standard to their own i.e. a like-for-like replacement rather than simply a courtesy car; and
(ii) the accident management companies, credit hire organisations (CHOs), credit repairers and other companies which provide services to non-fault parties. These providers, for example, are entitled – on behalf of the non-fault party – to use credit facilities to fund vehicle repairs and alternative transport.
(b) ToH 1 relates to the underlying cause of the dysfunction in the PMI market and not the symptoms nor the mitigants of this dysfunction. To some extent, this separation of cost liability and cost control is the necessary consequence of a third party liability model. Any material move away from such a model would have profound implications.
(c) A change to a first party model (of which there are a number of potential variants) would raise some important public policy questions, not least with regard to the pricing of PMI, which traditionally has been based on the cost of accidents expected to be caused by each policyholder. A change of this scale would in itself create very significant costs for the industry, which ultimately will be borne by consumers and it may also have unintended consequences for the future pricing of PMI premiums. The CC would therefore need to carry out a full cost/benefit analysis before proposing such a radical form of intervention.
(b) Bilaterals and the GTA are aimed at mitigating costs
1.4 The CC has confirmed that bilateral agreements between insurers and the General Terms of Agreement (the GTA) are measures aimed at mitigating the harm arising from the separation of cost liability and cost control. DLG agrees with this: DLG's bilateral agreements are designed to improve efficiency and control the cost of providing replacement vehicles to non-fault parties, whilst the GTA has provided a helpful check on rates (albeit that rates have continued to increase) and also promotes early and efficient settlement.
1.5 DLG does not, however, agree with the characterisation of these agreements as part of the 'harm' and does not believe that there is any evidence that these act as anything other than a mitigant against cost inflation. Indeed insurers would have no reason to enter into them if they did not believe that they would control costs overall.
1.6 The CC raises a concern that where a fault insurer captures a non-fault party this may result in the non-fault party receiving a lower quality of service than that to which they are entitled and would otherwise choose. DLG disagrees with any suggestion that it offers a lower quality of service to non-fault parties (although it is unable to comment in relation to other market operators). As set out in paragraph 2.4 below, DLG prioritises quality of service and provides the same repair service for fault and non-fault claims alike. For example, DLG offers a guarantee of five years (or DLG will match a manufacturer's guarantee period if longer) for any repairs done by its network of repairers; this applies equally to fault and non-fault claims.
1.7 Equally, DLG's supplier of replacement vehicles, Enterprise-Rent-A-Car (ERAC), must meet clear service specifications including in relation to quality and safety requirements, and detailed performance measures and targets. [CONFIDENTIAL]
(c) Bodily Injury
1.8 With regard to bodily injury, as set out in its initial submission dated 16 October 2012, DLG agrees with the CC that given the reforms in train, the Ministry of Justice are best placed to consider this. Bodily injury should therefore not form part of the CC's Investigation.
2. Harm arising from the beneficiary of post-accident services being different from and possibly less well informed than the procurer of those services
(a) Customers receive significant information from a variety of sources
2.1 There appears to be some conflict between ToH 2 and ToH 1.
(a) The incentives described under ToH 1 mean that in practice the beneficiaries of post-accident services may receive services that if anything are unnecessarily beneficial. For example, a non-fault party is entitled to receive a like-for-like replacement vehicle when they may only require a courtesy car.
(b) ToH 2 suggests that customers are less well informed about the services available to them and may not be fully aware of their rights.
2.2 Post-accident services comprise only a limited set of services: roadside recovery, repair and provision of a replacement vehicle. Even if some customers may not fully understand the intricacies of their legal rights when taking out a policy, DLG's view is that this is much less of an issue by the time customers come to make a claim on their policy. There are a variety of ways in which customers are made aware of their rights and the range of services available to them. When DLG customers contact DLG to make a claim, they are guided through all of their entitlements and the appropriate steps to take for the circumstances they are in. In addition, there is a broad range of different industry players, including insurers, brokers and PCWs, as well as other players such as CHOs, accident management companies, solicitors and garages. Each of these is a potential source of information for customers and each of these actively compete for these customers. Whilst DLG can see the theoretical argument that there is potential for harm, in practice, with this range of providers DLG believes this potential is extremely low.
(b) ToH 2 underplays the importance of providing a good repair service
2.3 DLG is concerned that the CC's description of ToH 2 does not give sufficient weight to the competitive imperative for insurers to provide a good repair service to their customers. As with any business service, DLG needs to seek the right balance between quality and cost, but an inadequate repair service (whether on fault or non-fault claims), and therefore an inadequate customer experience, is likely to lead to customer dissatisfaction, complaints and a loss of brand equity.
2.4 Providing a good repair service is therefore a very important part of DLG's PMI offering to customers. DLG believes that its repair network is a key way in which it achieves this:
(a) approved repairers are selected and assessed on the basis that – amongst others – they achieve certain service levels (e.g. customer satisfaction, cycle times, complaints, etc.) and quality standards (e.g. ability to produce repairs to defined quality standards notably standard PAS 125 which is independently audited by the British Standards Institute);
(b) scheduled and ad-hoc inspections are undertaken by DLG motor engineers of network repairers to check the quality of repairs and action is taken to address any concerns identified during an audit. This quality monitoring is the same for fault and non-fault cases – there is no differentiation between fault and non-fault repairs. Where a customer chooses a garage outside of the network, DLG is not able to carry out this type of quality monitoring and is only able to agree the scope of the repair work to be carried out (a further reason why DLG believes that repairer networks are key to quality of service and control of costs);
(c) DLG ensures that any complaints against network repairers are all logged, investigated and progressed to resolution. Statistics are recorded and incorporated in the network repairer performance reviews, which are undertaken by DLG's Network Performance Management team; and
(d) DLG guarantees repairs made by its approved repair network – for fault and non-fault claims alike – for five years (or if a manufacturer's guarantee period is longer, DLG will match that). DLG offers this as it represents a clear customer benefit.
2.5 Customers of DLG have the option to use their own repairer, but DLG strongly believes that use of its own network is the best way to ensure that repairs are carried out with appropriate control of both quality and cost. Any intervention that led to a material reduction in the proportion of repairs managed by insurers' networks would, DLG believes, lead to consumer detriment through inflation and an overall reduction in quality.
(c) ToH 2 is a secondary issue
2.6 ToH 2 suggests that harm may arise because third parties such as accident management companies, brokers, CHOs, credit repairers, insurers, etc., act on behalf of customers to procure repair and replacement vehicle services. DLG believes that this is a secondary issue (a symptom of the underlying problem), which arises primarily because of the separation of cost liability and cost control (i.e. ToH 1). It is this separation of cost liability and cost control (and the legal rights and duties which underpin this) which DLG believes drives the incentives and behaviour – and in some cases the existence – of these companies. As set out in paragraph 1.1 above, DLG therefore believes that the CC’s Investigation should focus on ToH 1.
3. **Harm due to horizontal effects (market concentration)**
(a) **There is strong competitive rivalry between insurers**
3.1 The provision of insurance is highly competitive and there is strong rivalry between insurers as acknowledged by the CC in its Issues Statement.(^1) There is a wide range of suppliers which have plenty of capacity and access to customers through a range of different distribution channels. Obstacles to customer switching are relatively low (borne out by much higher switching rates in PMI than, for example, in retail banking and utility markets). It is therefore extremely easy for customers to shop around and switch. As illustrated by Chart 1 below, annual switching rates are currently around 30%. It is clear therefore that even the largest insurers in the market do not have significant market power.
**Chart 1: Rates of shopping around and switching by motor insurance consumers, 2005-2012**
Source: © GfK NOP Financial Research Survey(^2) (FRS) based on, an average c.19,381 adults interviewed with a motor insurance policy on a 6 months ending period.
3.2 DLG would be happy to support any detailed analysis the CC chooses to conduct on this subject. DLG is confident that the conclusion will be that there is plentiful competition in all segments of the market. PCW and broker models provide consumers with easy access to a wide range of insurers, ranging from big, well-known brands to small, niche players that focus on specialist needs. Direct insurers also make significant marketing and advertising investments to ensure customers are aware of their portfolio of products.
(b) **PCWs**
3.3 DLG believes that provided that there is free and open price competition between PCWs and other channels, the relative concentration of PCW providers should not present any real detriment to consumers. In addition, given the lack of real differentiation between the websites, the significant investment required from insurers to set them up as sales channels, and the cost inflation they have
______________________________________________________________________
(^1) Issues Statement, para 47.
(^2) The GfK Financial Research Survey covers on average approximately 32,924 motor insurance premium payers per year. It covers main PMI only. The survey is GB-wide. driven in marketing channels (particularly digital), it is not clear that the emergence of additional competitors in the PCW aggregator market would work to the benefit of consumers.
3.4 However, this analysis rests on the assumption that PCWs will not start to exercise undue market power. The four main PCWs currently account for approximately 60% of PMI new business origination (they are therefore the largest distribution channel) and DLG does have some concerns that PCWs may, in the future, acquire increasing market power, giving them the ability to raise commissions and restrict price competition between insurers.
(a) [CONFIDENTIAL] PCWs tend to have panels of 50 or more brands/insurers and so the threat of withdrawal of a particular brand or insurer from a PCW’s panel is not an effective competitive constraint. This lack of reliance on having leading brands is highlighted by the fact that DLG’s brands Churchill and Privilege have only been available on comparethemarket.com since July 2012. Prior to this between October 2010 and April 2012, comparethemarket.com went from being the fourth largest PMI aggregator to being the biggest, with 27% of the PMI aggregator market.
(b) An insurer’s main mechanism for restraining a PCW’s market power is its freedom to distribute and price its PMI products as it sees fit through alternative distribution channels. However, the use of MFNs is undermining insurers’ ability to do this.
(i) Some MFNs require an insurer to match the lowest quote that it offers for a particular brand on a rival PCW. As these are increasingly enforced by PCWs, this will inevitably lead to price harmonisation across PCWs and therefore consumer detriment. Other MFNs require an insurer to match the lowest quote that it offers for a particular brand through alternative distribution channels. This again will lead to consumer detriment as in circumstances where an insurer could afford to offer a lower price through an alternative channel than it would on a PCW it would be unable to do so (the different costs and potential access to market through a PCW may mean that a price reduction which is possible through, for example, the direct online channel may be unsustainable through the PCW channel).
(ii) MFN clauses can also be an inflationary factor because they remove or constrain the ability of an insurer to respond to varying commission levels between channels through differential pricing. For example, if a PCW demanded a commission that was materially higher than their competitors, an insurer in a free and open market would be able to reflect the extra cost in its pricing, which in turn would lead to a competitive disadvantage for the PCW, whose customers would be able to get cheaper quotes through other channels. MFN clauses can prevent insurers from doing this. Furthermore, if an insurer is subject to MFN clauses it may have to raise prices in other channels because of an increase in commission costs for an individual PCW.
(iii) DLG is therefore surprised that the CC is so sanguine about MFN clauses. MFNs are discussed further below, under ToH 5.
(c) Other sectors
3.5 DLG agrees with the CC that the supply of other goods and services in other sectors of PMI does not give rise to scope for harm from horizontal effects.
______________________________________________________________________
3 See [http://www.directlinegroup.com/media/news/company/2012/11-07-2012.aspx](http://www.directlinegroup.com/media/news/company/2012/11-07-2012.aspx). 4 Source: eBenchmarkers. 5 Issues Statement, paras 90 to 95. 4. Harm arising from providers' strategies to soften competition
(a) FSA/FCA is best placed to assess issues raised under ToH 4
4.1 In general, DLG believes that the issues raised under ToH 4 are best addressed by the FSA/FCA in the course of their normal regulatory duties. In December 2012, the FSA announced a study into general insurance products sold as add-ons, which it aims to complete by Q3 2013. The FSA is also carrying out a thematic review of Motor Legal Expenses Insurance, which is expected to be concluded in Q1 2013.
4.2 Moreover, the issues are complex, and providers need to find the appropriate balance between on the one hand enabling consumer understanding and easy comparability across providers, and on the other hand offering consumers choice, quality of cover, and the ability to configure their cover to their needs. The FSA/FCA is therefore best placed to guide and supervise firms in achieving this balance, and DLG is actively working with it on these issues (which are pertinent to the core insurance product as well as add-ons). DLG would therefore suggest that the CC should apply the same arguments for this as it has done with regard to bodily injury and the Ministry of Justice reforms.
(b) Strategic product differentiation of PMI
4.3 DLG does not consider that strategic product differentiation of PMI results in net consumer harm, or that consumer search costs are raised as a result of product differentiation. The CC raises concerns that PMI providers may unnecessarily differentiate products to ensure consumers do not switch away to a rival insurer. DLG is unable to comment on the brand strategy of its competitors, and the extent to which they may or may not engage in this type of practice. However, DLG is confident that its own brand strategy, and the portfolio of brands it holds, increases choice and quality to customers. Furthermore, DLG does not believe there is any merit in the CC's suggestion that the 'complexity' of PMI policies may result in net consumer harm.
4.4 On the contrary, DLG would agree with the CC's alternative hypothesis; namely that product differentiation can yield consumer benefits through offering a policy that will be tailored to fit a consumer's need. This is the exact rationale behind DLG's brand strategy. DLG targets its brands across distinct consumer segments, seeking to offer its customers the combination of brands, channels, product features, prices and services that best address their needs. This is achieved by tailoring the distribution channel mix for each product including over the phone and online via the internet and PCWs, through banks and other partners and brokers.
4.5 DLG offers PMI through the Direct Line, Churchill and Privilege brands, as well as through the brands of a range of partners e.g. Sainsbury's Bank.
(a) Direct Line: was launched in 1985, with the aim of bringing new standards of service and simplicity to the private motor insurance industry. Customers are dealt with directly over the telephone or through the internet channel, cutting out the middle man and offering a faster, more efficient and convenient service. The Direct Line brand is not available through PCWs. The Direct Line brand targets customers who have a lower need for support, but high brand affinity. The focus is on a quick and simple customer experience.
(b) Churchill: is marketed directly to customers through various channels including telephone, the internet and PCWs. The Churchill brand targets customers with a higher need for support and reassurance, as well as high brand affinity. The focus is on a reassuring and supportive customer experience. (c) **Privilege**: is marketed directly to customers through various channels including telephone, the internet and PCWs. The Privilege brand targets customers who have a lower need for support and who buy predominantly through PCWs. The focus is on providing a quick customer experience at the best possible price from a recognisable brand.
4.6 DLG would be strongly opposed to any intervention which had the effect of limiting innovation in the PMI market. The use of different brands by insurers to appeal to different customer segments helps rather than hinders the competitive environment. For example, DLG’s uninsured driver and vandalism promises were introduced to differentiate DLG’s service, but due to their consumer appeal they have now been matched by several competitors. Under DLG’s uninsured driver promise, if a claim is made for an accident by a non-fault driver and the fault driver is not insured, the customer will not lose his or her no claims bonus (NCB) or have to pay any excess. Similarly, the vandalism promise ensures that customers will not lose their NCB if a claim is made for damage that is as a result of vandalism. Competition between insurers over quality of cover therefore drives innovation and acts to the benefit of consumers, who are better protected as a result.
4.7 DLG does not support the CC’s suggestion that PMI customers cannot switch easily or effectively between insurance providers. A clear distinction can be drawn between PMI and markets such as retail energy or personal current accounts where competition authorities and regulators have in the past found low levels of switching to be a concern.
(a) First, there is a clear distinction on levels of switching and shopping around (see Chart 1 above), with annual switching rates for motor insurance currently around 30%, compared to gas and electricity customers at around 15-17% and approximately 6% as quoted by the OFT in relation to personal current accounts.
(b) Second, in markets where switching is limited, there are often clear reasons for the lack of switching. In gas and electricity retailing, there is evidence to suggest that customers are unable to determine whether or not an alternative supplier would actually be cheaper, which limits the incentive to switch. In the case of personal current accounts, the lack of customer switching has in part been driven by the perceived ‘hassle factor’ of arranging for direct debits to be transferred etc., as well as the relatively limited financial gains to be had from switching. By contrast, no significant switching barriers exist in the case of PMI. For example, an NCB can be transferred to new providers; pricing is bespoke and based on the characteristics of the consumer and the product that is chosen, which means that consumers can easily compare premiums of PMI with coverage (excess, etc.) and add-ons of their choice. The price of PMI does not vary with usage, unlike for example, retail energy tariffs, so comparing offers from different providers is straightforward. Consumers are reminded in writing well ahead of policy renewal dates in order to give them sufficient time to shop around. DLG does not impose any surcharge on customers who choose not to renew their policy on expiry and any mid-term cancellation fees are limited by regulation so that they cannot be greater than the costs incurred by the insurer. Further, the financial gains from switching PMI provider can be significant, which adds to the incentive for customers to shop around and switch.
(c) **Drip-in pricing**
4.8 As set out in paragraph 4.1 above, DLG believes that the FSA/FCA is best placed to investigate drip-in pricing for additional products and services (where additional price increments are introduced through the sales process) and related issues. However, in response to the concerns raised by the
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6 It may be that any policy excess will need to be paid, and NCB may be lost temporarily until DLG receives confirmation that the accident was the fault of the uninsured driver.
7 It may be that any policy excess will need to be paid, and NCB may be lost temporarily until DLG is supplied with a relevant crime reference number.
8 See [http://www.oft.gov.uk/shared_oft/reports/financial_products/OFT1005.pdf](http://www.oft.gov.uk/shared_oft/reports/financial_products/OFT1005.pdf). CC,(^9) DLG notes that the points based on insights from behavioural economics, such as drip-in pricing and loss aversion/endowment effects, are unlikely to present a concern in the case of PMI. In particular, the underlying concerns which arose in previous cases relating to drip-in pricing (such as payment protection insurance (PPI), extended warranties on domestic electrical goods, and the payment charge surcharges for airline tickets) which were identified as giving rise to consumer detriment do not apply in relation to PMI.
4.9 Any application of insights from behavioural economics should take into account the specific characteristics of the product and market concerned. The reasons drip-in pricing was found to have caused consumer detriment in the aforementioned markets are not present in the case of PMI. In particular:
(a) Add-on products in the case of PMI will not typically be seen by the consumer to provide 'protection' for the main product, as there should be no perception that PMI will not provide protection without the add-on products (unlike, for example, PPI which provides protection for the loan). PMI add-on products are more akin to a basket of different products purchased from the same supplier, rather than providing protection for the primary product (and therefore raising issues of loss aversion). Instead, some add-ons enhance the coverage of the PMI cover, while others provide protection for additional events or deliver additional benefits, for example, Protected NCB, which protects the NCB in the event that a driver needs to make a claim.
(b) Consumers are in a good position to compare prices of PMI products and selections of products, including add-on products. DLG ensures that each product is itemised separately at point-of-sale. The price of additional products, such as legal expenses cover, can be added to the premiums for the primary product, allowing for easy comparison of price levels. This is in contrast to the findings of the CC investigation into PPI, where comparing the cost of the PPI with the cost of the credit was found to be difficult for most consumers.
(c) PMI customers also typically have available extensive information comparing the cost of add-on products from different insurers, due to the information that is readily available directly from insurers and from PCWs, which typically provide a range of quotes setting out whether each quote includes the main add-on products. For example, moneysupermarket.com provides details on the first results page for the price and coverage of products for the excess, windscreen cover, courtesy car, breakdown insurance, personal accident cover and legal cover. Directline.com uses an alternative approach of allowing the customer to alter the range of products and recalculate the quote instantly, allowing the customer easily to determine the cost of different selections of products.
4.10 This assessment would suggest that the concerns regarding drip-in pricing raised by the CC under ToH 4 have a much lower level of relevance for PMI than in the cases described above.
(d) Transparency and complexity of add-on products and services
4.11 DLG believes this falls under the remit of FSA investigations into PMI and the sale of related add-ons.
(e) Obstacles to consumers switching PMI provider
4.12 As described above in paragraphs 3.1 and 4.7, the high levels of switching (and high levels of midterm cancellation) illustrate clearly that there are no material barriers to switching in PMI in the UK. Indeed the process used by insurers is set up specifically to make switching straightforward. Customers receive a renewal notice at least three weeks before renewal, and they have a wide range
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(^9) Issues Statement, paras 59 to 65. of options for shopping around for an alternative cheaper rate. If customers want to shop for a cheaper rate, they will do so. If they find a better deal, they can cancel the renewal on their existing policy with a single phone call. This is highlighted by Chart 1 above.
4.13 Automatic renewal represents a critical consumer protection, as driving without insurance amounts to a criminal offence. The detriment that would be caused by limiting or removing automatic renewals would dramatically outweigh the very mild inconvenience associated with the customer having to make a phone call to cancel their renewal.
4.14 Mid-term cancellation fees also fall under the remit of the FSA and so DLG believes that the FSA is best placed to consider this. Insurers are required under the Insurance Conduct of Business Source Book and Treating Customers Fairly principles (a) to charge fees that only reflect the cost of cancellation; and (b) not to create barriers to switching. Although mid-term cancellation fees vary across the market, [CONFIDENTIAL].
4.15 The NCB model is an imperfect mechanism for establishing the claims history of a customer, for the reasons outlined in the Issues Statement. [CONFIDENTIAL] As such, it actually facilitates switching in the market, by making customers aware that their claims history is not the exclusive property of their existing insurer. Far from acting as a barrier to switching, NCB encourages competition.
5. Harm arising from vertical relationships (vertical integration)
(a) Ownership of PCWs by insurers - undercutting rivals' prices or manipulating quotes
5.1 DLG agrees that in practice the risk of PCW-integrated insurers using their PCW to try to gain a better understanding of rival's pricing models is likely to be limited. DLG also does not believe it likely that PCWs will limit access by insurers.
5.2 DLG's view is that – apart from the issues of future market power and MFNs, which are dealt with in paragraphs 5.6 to 5.9 below – the most relevant ToH relates to undercutting of prices and manipulation of quotes. DLG considers that the CC should carry out a more thorough, evidence based investigation before it can conclude with any confidence that the potential for harm is limited. For example, it is not clear whether sufficient systems and controls are in place that would prevent any manipulation from happening.
5.3 The CC seems to rely significantly on the ability of insurers to withdraw from a PCW; this is cited as a mitigant against the risk of customer detriment.10 The extent to which insurers see each of the main PCWs as 'must have' is a question that the CC should investigate further. As explained in paragraph 3.4 above, the threat of withdrawal is likely to be a limited competitive constraint because of the number of alternative brands/insurers available to PCWs. In addition, as highlighted by the OFT in its report on PCWs (referred to in the Issues Statement by the CC) "PCWs are a key choice tool for consumers. … PCWs are also often seen by suppliers as a cost-effective way to reach large numbers of consumers." 11 There are therefore significant commercial disadvantages for an insurer in withdrawing from such a powerful distribution channel.
5.4 PCWs control an increasing share of the PMI market and as more business moves online in the future, their existing market power may be further strengthened. Furthermore, the scope for manipulation is likely to increase as technological sophistication develops and as PCWs develop their role as providers of data analytical services to insurers. As such, the structural risk to fair competition is material and high, and the risk of market distortions and customer detriment far
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10 Issues Statement, para 83. 11 See http://www.oft.gov.uk/shared_oft/706728/Tool-landing-pages/consumer-protection/pcw-items-banners/PCWs-report.pdf and Issues Statement, para 51. higher than under ToH 2, 3 or 4. On a related point, the CC should investigate further the ability and incentives of PCW-integrated insurers to increase their rivals’ costs. It is possible that by increasing cost per acquisition (CPA) for rival insurers, PCW-integrated insurers may benefit from higher fees and also from less competitive prices offered by rivals — assuming that part of the increased CPA is passed on by rival insurers in the form of higher premiums. Insurers may find it difficult to negotiate lower CPAs since their only credible alternative, delisting themselves from the PCW, would result in their foregoing the sales they would otherwise achieve through the PCW. A proper evidenced based assessment is required in order to draw meaningful conclusions on this issue.
5.5 The CC raises the issue of whether PCW-integrated insurers could use their position to undercut rivals or manipulate prices to their advantage. DLG does not have visibility of the commercial arrangements between integrated insurers and their PCWs. However, if there are arrangements which are particularly favourable to PCW-integrated insurers, these could potentially have distortive effects. Again this is a question that the CC would be able to answer relatively easily by requesting relevant evidence from PCWs and undertaking an empirical analysis. For example, if the CC were to find that non-PCW-integrated insurers perform less well on integrated PCW sites than on fully independent PCWs, this may suggest that integrated PCW websites do not offer a level playing field.
(b) Ownership of PCWs by insurers – MFN clauses
5.6 As set out in paragraph 3.4 above, there are two principal types of MFN clauses: the first (which is potentially more restrictive) requires an insurer to match the lowest quote that it offers for a particular brand on a rival PCW; the second requires an insurer to match the lowest quote that it offers for a particular brand through certain alternative distribution channels (DLG has had to agree to the second type of clause with certain PCWs). DLG believes that both types of MFN clauses may lead to consumer detriment (for the reasons described in paragraph 3.4 above) and are an unfair mechanism through which PCWs may gain market power and distort competition. The power of the insurer in this instance is based solely on its willingness to sacrifice market share by withdrawing from the channel altogether. But this threat is of limited potency, as a PCW with a reasonably broad panel can happily live without a selection of an individual brand. Furthermore, the CC’s arguments that restrictive clauses are acceptable in order to enable PCWs to generate returns are not at all convincing, and are not consistent with the standards applied elsewhere in the Issues Statement.
5.7 The CC suggests that that MFN clauses strengthen PCWs’ incentives to invest in their websites, and that PCWs’ investments would benefit competition and consumers in the online market. However, the CC does not present any evidence to support this point. The CC’s argument rests on MFN clauses increasing the certainty of PCWs’ recouping their investment costs, as, once attracted to their website, consumers will be captured: because as consumers are aware of ‘you won’t find it cheaper elsewhere online’ advertising, they lack incentives to switch to other online sales platforms.
5.8 In order to substantiate the CC’s claim it would have to be demonstrated that MFN clauses strengthen PCWs’ incentives to invest. This should not simply be taken for granted. For example, it could be argued that in the absence of MFN clauses, PCWs would compete with each other more fiercely and this competition would force PCWs to invest in making their websites attractive for insurers and consumers alike. It may also lead to innovation, as PCWs (and insurers’ own websites) would be able to compete on the basis of exclusive low price offers, which MFN clauses currently prevent them from doing. Overall, a more thorough assessment of PCWs’ incentives to invest is needed to reach any conclusion concerning the impact of MFN clauses on market outcomes.
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12 Issues Statement, paras 81 – 84. 13 By way of example, as set out in paragraph 3.4 above, comparethemarket.com grew substantial share of the PMI market while DLG’s multi-channel brands were not available on it. 14 Issues Statement, para 93. 15 Issues Statement, para 93. 5.9 The CC also suggests that the continued use of call centres by consumers provides a constraint on the competition dampening effect of MFN clauses. However, this will only be the case if consumers actually shop around by telephone, which is a declining channel for obtaining PMI.
(c) Insurer – broker relationships
5.10 DLG agrees with the CC that insurer-broker vertical relationships are unlikely to give rise to competition concerns. DLG no longer uses brokers within its PMI business, having ceased writing new personal lines broker business in Q4 2010.
(d) Repairer – insurer relationships
5.11 Overall, the repairer market is a highly fragmented market and has a large number of potential suppliers. DLG believes this is likely to be reflected in the vast majority of local areas in the UK. In any event, as far as DLG is aware they typically have capacity to work for other insurers.
5.12 The CC notes that it is currently unclear as to how repairers compete for work from insurers. DLG cannot comment on other insurers' practices. Rather as set out in paragraph 2.4 above, DLG selects its repairers on the basis of specific criteria relating to total repair costs, service levels and quality standards.
5.13 DLG believes that consumers do and will continue to benefit from the competitive environment. This provides incentives for insurers to invest in their repair network – as DLG has done – in order to minimise the cost and maximise the quality of repairs. If rival insurers face higher repair costs because they have chosen not to make this investment, there is nothing to stop them from addressing the issue by making more investment in the future. That is simply a function of a competitive market at work.
(e) Insurer – paints/parts/distributor relationships
5.14 The CC indicate that contracts between insurers and suppliers may worsen terms of supply to smaller insurers and customers. DLG refutes this. The buying efficiencies that DLG achieves through economies of scale produce economic benefits:
(a) DLG’s Tier A and Tier B (third party) repairers obtain discounts which they are highly unlikely to be able to achieve on their own, due to DLG’s scale;
(b) by reaching agreement with particular suppliers of well known good quality products (such as paint) this ensures that DLG’s repairers are using high quality products in their repairs; and
(c) DLG does not require its repairers to purchase from particular suppliers other than for paint; and, for example, with paint, repairers are able to use any additional paint they purchase for non-DLG work.
5.15 There are a wide range of suppliers of paints and parts to insurers and repairers. Suppliers of paint and parts will naturally seek to obtain the highest prices they can from all their customers. Moreover, DLG believes that it is important for insurers such as DLG to be encouraged to invest in their repair network in order to reduce costs.
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16 Issues Statement, para 94. 17 Issues Statement, para 102. and maximise quality; this is pro-competitive and provides significant customer benefits. [CONFIDENTIAL]
5.16 The CC also suggest that suppliers of paints and parts may suffer harm as a result of customer foreclosure. Again DLG refutes this. As set out in relation to ToH 3 above, the PMI market is fragmented and highly competitive. DLG does not believe that any single insurer’s repair network (or individual approved repairers) could be regarded as a sufficiently significant portion of a supplier’s customer base for this concern to be anything other than theoretical.
6. Possible countervailing effects: entry and barriers to entry - insurers
6.1 The CC hypothesises that a potential barrier to entry is the economies of scale that existing players in the market benefit from and argues that having a large number of customers from a particular segment could enable an insurer to understand the risk of drivers in that segment and price the risk more profitably. However, data-sharing by insurers through the Association of British Insurers (ABI) on a number of risk factors facilitates new entry and mitigates the gain that incumbents could enjoy from scale. Furthermore, certain types of price data broken down by risk factor are also shared within the insurance industry, which further facilitates new entry, as pointed out in a recent investigation by the OFT into information sharing in the insurance industry.
6.2 DLG agrees with the CC’s observation that barriers to moving from one market segment into another are likely to be quite low. Online-only insurance provider easyMoney (underwritten by Zurich) entered the market in 2005 to offer products to the low-cost motor insurance segment. Zurich had no presence in this segment prior to underwriting the easyMoney venture, so the partnership enabled it to expand and diversify its motor insurance product range.
6.3 More generally, the supply of PMI is highly competitive and does not feature substantial barriers to entry or expansion either for new entrants or existing players wishing to enter particular segments. There are many examples of brands that have successfully entered and/or expanded.
6.4 For example, Zenith Insurance has rapidly expanded its presence in motor insurance, increasing its range of products from one to fifteen between 2008 and 2012. The entry of More Than (underwritten by RSA) in 2001 shows the ability of an existing provider of other insurance products to enter the UK motor insurance market, attract business and grow its market share.
6.5 The widespread and increasing use of PCWs by consumers enables a brand quickly to gain market share if it is listed on a PCW. Swiftcover and eCar are examples of internet-only brands that have successfully entered the market in the last decade; both were noted by the OFT in its market study.
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18 Issues Statement, para 109. 19 See http://www.oft.gov.uk/shared_oft/market-studies/private-motor-insurance/OFT1422.pdf 20 Issues Statement, para 110.
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59bdd28ead70de5959bf0fd8f0dd7cd6f44f392a | Permanent Secretary - Martin Donnelly
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|------------------------------|--------------------|--------|-------------------------------------|--------------| | | | | Air | Rail | | | 26.07.2013 | London | Business visit | 33.10 | | 33.10 | | 01 – 17.08.2013 | Australia & New Zealand | Business visit | 4932.37| 288.77 | 5221.14 | | 27.08.2013 | London | Business dinner | | 74.40 | 74.40 | | 30.08.2013 | Coventry | Business visit | 50.50 | 6.05 | 56.55 | | 04.09.2013 | London | Business dinner | | 14.50 | 14.50 | | 09.09.2013 | London | Business visit | 6.50 | | 6.50 | | 10.09.2013 | Coventry | Business visit | 45.40 | 21.00 | 75.63 |
Permanent Secretary - Martin Donnelly
Hospitality Received
| Date | Organisation Name | Type of Hospitality Received | |------------|--------------------------------------------|------------------------------| | 10.07.2013 | Barclays | Lunch | | 11.07.2013 | The City UK | Lunch – Speaking engagement | | 06.08.2013 | Trans-Tasman Business Circle | Dinner | | 07.08.2013 | Asia Society Australia | Lunch | | 09.08.2013 | Committee for Economic Development of Australia | Lunch – speaking engagement | | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|----------------------|------------------|--------|-------------------------------------|--------------| | | | | Air | Rail | Taxi/Car | Accommodation /Meals | | | 01.07.2013 | London | Meetings | 55.17 | | | | 55.17 | | 02.07.2013 | London | Meetings | 57.00 | | | | 57.00 | | 03.07.2013 | London | Meetings | 25.50 | | | | 25.50 | | 04.07.2013 | London | Meetings | 31.75 | | | | 31.75 | | 08.07.2013 | London | Meetings | 51.00 | | | | 51.00 | | 09.07.2013 | London | Meetings | 51.00 | | | | 51.00 | | 11.07.2013 | London | Meetings | 20.50 | | | | 20.50 | | 15.07.2013 | London | Meetings | 40.75 | | | | 40.75 | | 17-19.07.2013 | London & Washington | Meetings | 5475.45 | 39.15 | 239.00 | | 5753.60 | | 22.07.2013 | London | Meetings | 78.87 | | | | 78.87 | | 23.07.2013 | London, Oxford & Cambridge | Meetings & visit | 28.70 | 23.55 | | | 52.25 | | 24.07.2013 | Rothamsted | Visit | 12.00 | | | | 12.00 | | Date | Location | Event Details | Cost 1 | Cost 2 | Total | |------------|-------------------|--------------------------------|--------|--------|--------| | 25.07.2013 | London | Meetings | 25.50 | | 25.50 | | 26.07.2013 | London | Meetings | 58.80 | | 58.80 | | 29.07.2013 | London & Derby | Meetings & visit | 68.00 | 25.50 | 93.50 | | 31.07.2013 | London | Meetings | 51.00 | | 51.00 | | 07.08.2013 | London | Meetings | 57.25 | | 57.25 | | 27.08.2013 | London | Meetings | 51.00 | | 51.00 | | 28.08.2013 | London | Meetings | 51.00 | | 51.00 | | 29.08.2013 | London | Meetings | 58.80 | | 58.80 | | 02.09.2013 | London & Newcastle| Meetings & visit | 178.50 | 41.25 | 287.75 | | 03.09.2013 | London | Meetings | 31.35 | | 31.35 | | 04.09.2013 | London | Meetings | 82.65 | | 82.65 | | 05.09.2013 | London & Southampton| Meetings & visit | 40.80 | 45.15 | 85.95 | | 06.09.2013 | London | Meetings | 51.00 | | 51.00 | | 09.09.2013 | London & Penrith | Meetings & visit | 95.00 | 41.25 | 227.75 | | 11.09.2013 | London | Meetings | 51.00 | | 51.00 | | 12.09.2013 | London | Meetings | 33.45 | | 33.45 | | 13.09.2013 | London & Birmingham| Meetings & visit | 158.00 | 68.95 | 226.95 | | 16.09.2013 | London | Meetings | 57.65 | | 57.65 | | 17.09.2013 | London | Meetings | 86.82 | | 86.82 | | 18.09.2013 | London | Meetings | 51.00 | | 51.00 | | 19.09.2013 | London | Meetings | 25.50 | | 25.50 | | 20.09.2013 | London | Meetings | 25.50 | | 25.50 | | 23.09.2013 | London & Loughborough| Meetings & visit | 85.00 | 51.40 | 136.40 | | 24.09.2013 | London | Meetings | 53.60 | | 53.60 | | 25.09.2013 | London & | Meetings & | 28.70 | 39.30 | 68.00 | | Date | Organisation Name | Type of Hospitality Received | |------------|-----------------------------------------------------------------------------------|------------------------------| | 02.07.2013 | Association of Independent Research & Technology Organisation (AIRTO) | Dinner | | 08.07.2013 | Centre for Science & Policy | Dinner | | 17-19.07.2013 | Presidents Council of Advisers on Science & Technology (PCAST) USA | Lunches & dinners | | 22.07.2013 | The Royal Society | Dinner | | 23.07.2013 | Ordnance Survey | Dinner & accommodation | | 29.07.2013 | Rolls-Royce | Dinner & accommodation | | 23.09.2013 | Energy Technology Institute (ETI) | Dinner & accommodation | | 25.09.2013 | University of Oxford – Oxford Martin School | Dinner |
**Sir Mark Walport - Government Chief Scientific Adviser**
**Hospitality Received**
| Date | Organisation Name | Type of Hospitality Received | |------------|-----------------------------------------------------------------------------------|------------------------------| | 02.07.2013 | Association of Independent Research & Technology Organisation (AIRTO) | Dinner | | 08.07.2013 | Centre for Science & Policy | Dinner | | 17-19.07.2013 | Presidents Council of Advisers on Science & Technology (PCAST) USA | Lunches & dinners | | 22.07.2013 | The Royal Society | Dinner | | 23.07.2013 | Ordnance Survey | Dinner & accommodation | | 29.07.2013 | Rolls-Royce | Dinner & accommodation | | 23.09.2013 | Energy Technology Institute (ETI) | Dinner & accommodation | | 25.09.2013 | University of Oxford – Oxford Martin School | Dinner |
**Philippa Lloyd - Director General, People, Communications and Corporate Effectiveness**
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------|-------------|---------|--------|-------------------------------------|--------------| | | | | | | | | Date | Organisation Name | Type of Hospitality Received | |------------|-------------------|------------------------------| | 18.09.2013 | Maxxim Consulting | Lunch |
**Philippa Lloyd - Director General, People, Communications and Corporate Effectiveness**
**Hospitality Received**
| Date | Organisation Name | Type of Hospitality Received | |------------|-------------------|------------------------------| | 18.09.2013 | Maxxim Consulting | Lunch |
**Nick Baird - Chief Executive, UK Trade & Investment**
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|-------------------|--------------------|-----------------|-------------------------------------|--------------| | 09 - 10.07.2013 | Glasgow | Quarterly meeting | Air 257.29, Rail 42.60, Taxi/Car 91.00 | 390.89 | | | 23.07.2013 | Birmingham | Speech | Air 72.00, Rail 12.00 | 84.00 | | | 25.07.2013 | Didcot | Meeting | Air 23.50, Rail 12.00 | 23.50 | | | 15.08.2013 | Teddington | Visit | Air 9.90, Rail 12.00 | 9.90 | | | 16 - 20.09.2013 | Tripoli, Casablanca, Rabat | Official visits | Air 1556.65, Rail 38.80, Taxi/Car 219.56 | 1815.01 | | Nick Baird - Chief Executive, UK Trade & Investment Hospitality Received
| Date | Organisation Name | Type of Hospitality Received | |------------|--------------------------------------------------------|------------------------------| | 04.07.2013 | Battersea Power Station Development Company | Lunch | | 08.07.2013 | Louis Vuitton Moet Hennessy | Lunch | | 16.07.2013 | GSK | Reception | | 17.07.2013 | British MENA Council | Dinner | | 15.08.2013 | Institute of Directors | Lunch | | 12.09.2013 | British American Business | Dinner |
Bernadette Kelly - Director General, Markets & Local Growth
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|--------------|---------|--------|-------------------------------------|--------------| | 09 - 10.07.2013 | Leeds | Meeting | Air 115.50 | Rail 13.00 | Taxi/Car 90.50 | 219.00 | | 11.07.2013 | Wokingham | Meeting | Air 9.60 | Rail 10.00 | Taxi/Car 74.78 | 19.60 | | 18 - 19.07.2013 | Dublin | Meeting | Air 350.83 | Rail 10.50 | Taxi/Car 74.78 | 436.11 |
Bernadette Kelly - Director General, Markets & Local Growth Hospitality Received - NIL
Sir John O'Reilly - Director General, Knowledge and Innovation
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|-------------|------------------|--------|-------------------------------------|--------------| | | | | Air | Rail | Taxi/Car | Accommodation /Meals | | | | 03.07.2013 | London | Meeting | | | 11.90 | | 11.90 | | 11.07.2013 | Swindon | Meeting | 117.00 | 13.90| | | 130.90 | | 17.07.2013 | London | Meeting/Dinner | 33.00 | | 202.80 | | 235.80 | | 25.07.2013 | London | Dinner | 207.00 | | 95.94 | | 302.94 | | 26.07.2013 | Swansea | Meeting | 9.90 | | | | 9.90 | | 31.07.2013 | Edinburgh | Meeting | 100.97 | 6.00 | 83.00 | | 189.97 | | 01.08.2013 | London | Meeting | 25.00 | | | | 25.00 | | 14.08.2013 | Sheffield | Meeting | 199.00 | | | | 199.00 | | 19.09.2013 | Brussels | Meeting | 134.00 | | | | 134.00 | | 26.09.2013 | Sheffield | Meeting | 199.00 | | | | 199.00 |
Sir John O'Reilly - Director General, Knowledge and Innovation Hospitality Received
| Date | Organisation Name | Type of Hospitality Received | |------------|-------------------|------------------------------| | 04.07.2013 | Royal Society | Soiree | | 11.07.2013 | French Embassy | Reception | | 18.07.2013 | British Academy | Dinner | | 22.07.2013 | Royal Society | Dinner | | 13.09.2013 | BSI | Lunch | | 24.09.2013 | BBSRC | Dinner |
### Mark Russell - Chief Executive, Shareholder Executive
#### DATES DESTINATION PURPOSE TRAVEL OTHER (including Hospitality Given) Total Cost £
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-----------|-------------|------------------|--------|-------------------------------------|--------------| | 01.07.2013| London | Meeting | 2.10 | | 2.10 | | 05.07.2013| | Reimbursement of telephone costs | | 20.52 | 20.52 | | 10.07.2013| London | | 2.10 | | 2.10 | | 05.08.2013| | Reimbursement of telephone costs | | 262.60 | 262.60 | | 08.08.2013| London | Meeting | 35.98 | | 35.98 | | 13.08.2013| Berlin | Meeting | 168.00 | 13.00 | 16.34 | | 15.08.2013| London | Meeting | 25.67 | | 25.67 |
### Mark Russell - Chief Executive, Shareholder Executive
#### Hospitality Received
| Date | Organisation Name | Type of Hospitality Received | |------------|-------------------|------------------------------| | 02.07.2013 | Alix Partners | Lunch | | 03.07.2013 | Henderson | Breakfast | | 03.07.2013 | Apax | Lunch | | 09.07.2013 | Steel Fleet | Lunch | | 09.08.2013 | UBS | Lunch | | 21.08.2013 | Ernst & Young | Lunch | | DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |------------|-------------------|----------------------------------------------|--------|-------------------------------------|--------------| | | | | Air | Rail | Taxi/Car | Accommodation /Meals | | | 15 - 19.07.2013 | Said Business School | Attend residential course | 63.00 | | | | 63.00 | | 22.07.2013 | London | Meeting | 2.80 | | | | 2.80 | | 25.07.2013 | Swindon | Board Meeting | 117.00 | | | | 117.00 | | 29.07.2013 | London | BIS Financial Management Awards | 2.10 | | | | 2.10 | | 02.08.2013 | Glasgow | Meeting | 6.80 | 22.50 | 4.80 | | 34.10 | | 08.08.2013 | London | Meeting | 2.80 | | | | 2.80 | | 05.09.2013 | London | Working Group | 2.80 | | | | 2.80 | | 06.09.2013 | London | Meeting | 2.10 | | | | 2.10 | | 12.09.2013 | London | Reception | 5.90 | | | | 5.90 | | 17.09.2013 | London | Meeting | 4.20 | | | | 4.20 | | 19.09.2013 | Swindon | Board Meeting | 117.00 | | | | 117.00 |
Howard Orme - Director General, Finance and Commercial
Hospitality Received | Date | Organisation Name | Type of Hospitality Received | |------------|-------------------|------------------------------| | 25.07.2013 | UK SBS Ltd | Lunch | | 29.07.2013 | CIMA | Canapes & wines | | 02.08.2013 | SLC | Lunch | | 06.09.2013 | Deloittes | Lunch | | 12.09.2013 | DESi | Reception | | 19.09.2013 | UK SBS Ltd | Lunch |
Rachel Sandby-Thomas - Director General, Legal, Business and Skills
| DATES | DESTINATION | PURPOSE | TRAVEL | OTHER (including Hospitality Given) | Total Cost £ | |-------------|------------------------------|-----------------------|--------|-------------------------------------|--------------| | 01.07.2013 | Leeds | Business Meeting | Air 85.43 | | 85.43 | | 04-05.07.2013| Farnborough & Preston | Business Meeting | Rail 25.10, Taxi/Car 8.00, Accommodation 79.00 | 112.10 | | 08-09.07.2013| Cardiff | Business Meeting | Air 146.00, Taxi/Car 24.00 | | 170.00 | | 19.07.2013 | Teddington | Business Meeting | Air 39.20 | | 39.20 | | 14.08.2013 | Leicester | Business Meeting | Air 40.00 | | 40.00 | | 06.09.2013 | Birmingham | Business Meeting | Air 59.00, Taxi/Car 5.40 | | 64.40 | | 10-11.09.2013| Sheffield, Birmingham & Coventry | Business Meeting | Air 132.00 | | 132.00 | | 25-26.09.2013| London | Business Meeting | Air 230.00 | | 230.00 |
### Rachel Sandby-Thomas - Director General, Legal, Business & Skills
**Hospitality Received**
| Date | Organisation Name | Type of Hospitality Received | |------------|------------------------------------|-----------------------------------------------| | 04.07.2013 | BAE Shuttle Plane | Flight from Farnborough to Warton | | 05.07.2013 | BAE Systems | Lunch | | 09.07.2013 | Lafarge Tarmac Plant | Lunch | | 19.07.2013 | National Physical Laboratory | Lunch |
### Amanda Rowlatt - Acting Director General, Strategy, Analysis and Better Regulation (SABR) - NIL
**Hospitality Received**
| Date | Organisation Name | Type of Hospitality Received | |------------|------------------------------------|-----------------------------------------------| | 18.09.2013 | Engineering and Employers | Drinks |
1. Does not normally include meetings with Government bodies such as other Government Departments and Agencies, non-departmental public bodies, Government reviewers, and representatives of devolved or foreign governments.
Note – Air, rail and accommodation costs may not include certain transactional charges
### Non Executive Board Members
**Sir Andrew Witty** - NIL
**Dale Murray** - NIL Dalton Philips - NIL Alan Aubrey - NIL Wendy Purcell - NIL
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a8200bd76f2a920bd27663853c6dbbdeba8cac07 | The salary, pension entitlements and the value of any taxable benefits in kind of the Chief Executive and Keeper, Executive Directors, Associate Director, Non-executive Directors and Non-executive Board Members of The National Archives, were as follows (audited):(^1) (^2)
| Name | 2017-18 | 2016-17 | |-------------------------------------------|---------|---------| | | Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | | Jeff James, Chief Executive and Keeper | 115-120 | - | - | 46 | 165-170 | 115-120 | 5-10 | - | 47 | 175-180 | | Neil Curtis, Finance and Commercial Director (from 21 November 2016) | 95-100 | - | - | 37 | 130-135 | 30-35 (95-100) | - | - | 13 | 45-50 | | Paul Davies, Operations Director (from 1 June 2016) Disclosure relates to current role. | 85-90 | - | - | 14 | 100-105 | 70-75 (85-90) | - | - | 19 | 90-95 | | Lucy Fletcher, Associate Director – Government Audience. Disclosure relates to current role | 25-30 (55-60) | - | - | 11 | 35-40 | N/A | N/A | N/A | N/A | N/A | | Dr Valerie Johnson, Director of Research and Collections | 80-85 | - | - | 40 | 120-125 | 80-85 | - | - | 40 | 120-125 |
(^1) Salary and full year equivalent (FYE) are presented to the nearest £1,000. FYE is shown in brackets. Benefits in kind are presented to the nearest £100, pension benefits and total remuneration to the nearest £1,000.
(^2) The value of pension benefits accrued during the year is calculated as (the real increase in pension multiplied by 20) plus (the real increase in any lump sum) less (the contributions made by the individual). The real increases exclude increases due to inflation or any increase or decreases due to a transfer of pension rights. | Name | Position | 2017-18 | 2016-17 | |-------------------------------------------|-----------------------------------------------|---------|---------| | Caroline Ottaway-Searle | Director, Public Engagement | 85-90 | 85-90 | | | | 5-10 | 0-5 | | | | - | - | | | | 34 | 34 | | | | 130-135 | 130-135 | | John Sheridan | Digital Director | 80-85 | 80-85 | | | | - | - | | | | - | - | | | | 26 | 26 | | | | 105-110 | 105-110 | | Carol Tullo (until 30 June 2017) | Director, Information Policy and Services | 20-25 | 95-100 | | | | (95-100)| | | | | - | 5-10 | | | | - | - | | | | 3 | 25-30 | | | | 95-100 | 95-100 | | | | 5-10 | 5-10 | | | | - | - | | | | 20 | 20 | | | | 120-125 | 120-125 | | Peter Phippen | Non-executive Director/Board Member | 5-10 | 5-10 | | | | N/A | N/A | | | | 100 | 100 | | | | N/A | N/A | | | | 5-10 | 5-10 | | Lesley Cowley OBE | Lead Non-executive Board Member (from 1 January 2016) | 15-20 | 15-20 | | | | N/A | N/A | | | | 200 | 200 | | | | N/A | N/A | | | | 15-20 | 15-20 | | Dr Claire Feehily | Non-executive Board Member (from 1 January 2016) | 10-15 | 10-15 | | | | N/A | N/A | | | | 300 | 300 | | | | N/A | N/A | | | | 10-15 | 10-15 | | Brian Gambles MBE | Non-executive Board Member (from 1 January 2016 to 31 December 2017) | 5-10 | 10-15 | | | | N/A | N/A | | | | - | N/A | | | | N/A | N/A | | | | 5-10 | 5-10 | | | | 10-15 | 10-15 | | | | N/A | N/A | | | | - | N/A | | | | N/A | N/A | | Maurice Goddard | Independent member of the Audit and Risk committee (to 18 November 2016) | N/A | 0 - 5 | | | | N/A | (5 – 10)| | | | N/A | N/A | | | | N/A | N/A | | | | 0 - 5 | 0 - 5 | | | | N/A | N/A | | | | N/A | N/A | | | | N/A | N/A | | Robert Milburn | Independent member of the Audit and Risk Committee (from 16 May 2017) | 0-5 | 0-5 | | | | N/A | N/A | | | | - | N/A | | | | N/A | N/A | | | | 0-5 | 0-5 | | | | N/A | N/A | | | | N/A | N/A | | | | N/A | N/A | Pay multiples (audited)
| | 2017-18 | 2016-17 | |--------------------------|----------|----------| | Band of highest paid | 120-125 | 125-130 | | Director’s remuneration (£)| | | | Median total remuneration (£) | 30,126 | 28,593 | | Ratio | 4.1 | 4.5 |
Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation and the median remuneration of the organisation’s workforce.
The banded remuneration of the highest-paid Executive Director in The National Archives in the financial year 2017-18 was £120k-£125k (2016-17: £125-£130k). This was 3.9 times the median remuneration of the workforce, which was £30,126, a decrease of 0.4. The decrease can be attributed to a decrease in staff numbers combined with higher level vacancies at the lower grade posts compared to prior year, together with impact of a bonus received in the prior year by the highest paid Director.
In both 2017-18 and 2016-17, no employees received remuneration in excess of the highest-paid director. Remuneration ranged from £18,000-£120,000 (2016-17: £15,000 - £129,000).
Total remuneration includes salary, non-consolidated performance-related pay and benefits-in-kind. It does not include severance payments, employer pension contributions and the cash equivalent transfer of pensions.
## Pension benefits (audited)
| Name | Accrued pension at pension age as at 31/03/18 and related lump sum | Real increase/(decrease) in pension and related lump sum at pension age | CETV at 31/03/18 | CETV at 31/03/17 | Real increase in CETV | |-------------------------------------------|---------------------------------------------------------------------|------------------------------------------------------------------------|------------------|------------------|----------------------| | **£000 in bands of £5,000** | **£000 in bands of £2,500** | **£000 to nearest £000** | **£000 to nearest £000** | **£000 to nearest £000** | | Jeff James, Chief Executive and Keeper | 5-10 | 2.5-5 | 113 | 80 | 21 | | Neil Curtis, Finance and Commercial Director (from 21 November 2016) | 0-5 | 0-2.5 | 29 | 7 | 14 | | Paul Davies, Operations Director (from 1 June 2016) Disclosure relates to current role. | 20-25 | 0-2.5 | 435 | 393 | 12 | | Lucy Fletcher, Associate Director – Government Audience. | 5-10 | 0-2.5 | 43 | 38 | 3 | | Valerie Johnson, Director of Research and Collections | 15-20 | 2.5-5 | 262 | 219 | 18 | | Caroline Ottaway-Searle, Director, Public Engagement | 20-25 | 0-2.5 | 310 | 268 | 25 | | John Sheridan, Digital Director | 15-20 | 0-2.5 | 244 | 218 | 9 | | Carol Tullo (until 30 June 2017), Director, Information Policy and Services | 20-25 plus a lump sum of 70-75 | 0-2.5 plus a lump sum of 0-2.5 | 530 | 522 | 2 |
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80a15cd00b7083f9fafbc4540f2612540e2aeeec | Salaries and Bonuses – 2018-19 The following sections provide details of the remuneration and pension interests of the most senior staff and officials (i.e. Board members) of the department.
The salary, pension entitlements and the value of any taxable benefits in kind of the Chief Executive and Keeper, Executive Directors, Associate Director, Non-executive Directors and Non-executive Board members of The National Archives, were as follows (audited) 1 2:
| Name | Position | 2018-19 Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | 2017-18 Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | |-------------------------------------------|-----------------------------------------------|---------------------------------------------------------------|-------------|-------------------|------------------------|------------|---------------------------------------------------------------|-------------|-------------------|------------------------|------------| | Jeff James | Chief Executive and Keeper | 120-125 | - | - | 47 | 165-170 | 120-125 | - | - | 46 | 165-170 | | Neil Curtis | Finance and Commercial Director | 95-100 | - | - | 38 | 135-140 | 95-100 | - | - | 37 | 130-135 | | Paul Davies | Operations Director | 85-90 | - | - | 21 | 105-110 | 85-90 | - | - | 14 | 100-105 | | Lucy Fletcher Director for Government³ | | 65-70 | - | - | 15 | 80-85 | 25-30 (55-60) | - | - | 11 | 35-40 | | Dr Valerie Johnson | Director of Research and Collections | 80-85 | - | - | 40 | 120-125 | 80-85 | - | - | 40 | 120-125 | | Caroline Ottaway-Searle | Director, Public Engagement | 90-95 | - | - | 35 | 125-130 | 85-90 | 5-10 | - | 34 | 130-135 | | John Sheridan | Digital Director | 80-85 | - | - | 31 | 110-115 | 80-85 | - | - | 26 | 105-110 |
1 Salary and full year equivalent (FYE) are presented to the nearest £1,000. FYE is shown in brackets. Benefits in kind are presented to the nearest £100, pension benefits and total remuneration to the nearest £1,000. 2 The value of pension benefits accrued during the year is calculated as (the real increase in pension multiplied by 20) less (the contributions made by the individual). The real increases exclude increases due to inflation or any increase or decreases due to a transfer of pension rights. 3 Associate Director from 2 October 2017, Director for Government from 15 October 2018 | Name | Position | Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | Salary and FYE (full-year, full-time equivalent) £'000 | Bonus £'000 | Benefit in kind £ | Pension benefits £'000 | Total £'000 | |-------------------------------------------|-----------------------------------------------|-------------------------------------------------------|-------------|------------------|------------------------|-------------|-------------------------------------------------------|-------------|------------------|------------------------|-------------| | Carol Tullo (until 30 June 2017) | Director, Information Policy and Services | N/A | N/A | N/A | N/A | 20-25 | (95-100) | - | - | 3 | 25-30 | | Lesley Cowley OBE | Lead Non-executive Board member | 15-20 | N/A | 2,300 | N/A | 15-20 | N/A | 2,300 | N/A | 15-20 | | | Dr Claire Feehily | Non-executive Board member | 15-20 | N/A | 2,600 | N/A | 20-25 | 10-15 | N/A | 3,600 | N/A | 15-20 | | Brian Gambles MBE | Non-executive Board member (until 31 December 2017) | N/A | N/A | - | N/A | N/A | 5-10 | N/A | 500 | N/A | 5-10 | | Robert Milburn | Independent member of the Audit and Risk Committee | 0-5 | N/A | - | N/A | 0-5 | 0-5 | N/A | - | N/A | 0-5 |
Pay multiples (audited)
| | 2018-19 | 2017-18 | |--------------------------------------|---------|---------| | Band of highest paid Director’s remuneration (£) | 120-125 | 120-125 | | Median total remuneration (£) | 30,216 | 30,126 | | Ratio | 4.1 | 4.1 |
Reporting bodies are required to disclose the relationship between the remuneration of the highest-paid director in their organisation and the median remuneration of the organisation’s workforce.
The banded remuneration of the highest-paid Executive Director in The National Archives in the financial year 2018-19 was £120k-£125k (2017-18: £120k-£125k). This was 4.0 times the median remuneration of the workforce, which was £30,216. The small increase in the median from the previous year is due to a decrease in staff numbers combined with an increase in lower graded staff undertaking apprenticeships, offset by new posts in the digital directorate commanding higher salaries than the average.
In both 2018-19 and 2017-18, no employees received remuneration in excess of the highest-paid director. Remuneration ranged from £16,000-£125,000 (2017-18: £18,000-£125,000).
Total remuneration includes salary, non-consolidated performance-related pay and benefits-in-kind (travel and subsistence). It does not include severance payments, employer pension contributions and the cash equivalent transfer of pensions.
Pension benefits (audited)
| Name | Accrued pension at pension age as at 31/03/19 and related lump sum | Real increase / (decrease) in pension and related lump sum at pension age | CETV at 31/03/19 | CETV at 31/03/18 | Real increase in CETV £000 to nearest £000 | |-------------------------------------------|---------------------------------------------------------------------|--------------------------------------------------------------------------|------------------|------------------|-------------------------------------------| | Jeff James, Chief Executive and Keeper | 10-15 | 2.5-5 | 163 | 113 | 25 | | Neil Curtis, Finance and Commercial Director | 5-10 | 0-2.5 | 58 | 29 | 17 | | Paul Davies, Operations | 25-30 | 0-2.5 | 507 | 435 | 21 | | Lucy Fletcher, Director for Government | 5-10 | 0-2.5 | 65 | 51 | 5 | | Valerie Johnson, Director of Research and Collections | 20-25 | 2.5-5 | 330 | 262 | 21 | | Caroline Ottaway-Searle, Director, Public Engagement | 20-25 | 0-2.5 | 370 | 310 | 26 | | John Sheridan, Digital Director | 20-25 | 0-2.5 | 302 | 244 | 14 | | Carol Tullo (until 30 June 2017), Director, Information Policy and Services | N/A | N/A | N/A | 530 | N/A |
There were no employer contributions to partnership pension accounts in respect of any of the above.
______________________________________________________________________
4 Associate Director from 2 October 2017, Director for Government from 15 October 2018
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2b3e6c47981e615545f95d537001733aebca316b | Northampton Borough Council
Disability Equality Scheme 2006 – 2009
If you would like a copy of this document in large print, Braille, audiotape or in a different language please contact 01604 837752 or 01604 837507 | Contents | Page | |-------------------------------------------------------------------------|------| | Foreword | 3 | | What is a Disability Equality Scheme | 4 | | Statutory Duties | 5 | | Social Model of Disability | 5 | | Achievements to Date | 6 | | Involvement of Disabled People | 7 | | Northampton Disabled Demography | 8 | | Working with Partners | 9 | | Corporate Priorities | 9 | | Monitoring, reviewing & publishing results | 10 | | Equality Standard for Local Government | 11 | | Implementation of the Disability Equality Scheme | 12 | | Action Plan | 13 |
1. **Foreword**
1.1. Under the Disability Discrimination Act 2005, there is a specific requirement for Northampton Borough Council to publish a Disability Equality Scheme. This scheme sets out a 3-year plan that Northampton Borough Council will be taking to make sure that disabled people have the same opportunities as everyone else.
1.2. We welcome Northampton Borough Council’s first Disability Equality Scheme and are committed to ensuring that we achieve disability equality in our service provision and in our responsibilities as an employer. This Scheme is in line with our total commitment to actively support and promote diversity and equality throughout the organisation and to work with our partners to promote diversity and equality across Northampton. This will be closely monitored, reviewed and adapted to ensure that we meet the needs of disabled people who have contact with Northampton Borough Council.
1.3. This document focuses on the actions that Northampton Borough Council is taking to make the environment more accessible, where possible removing physical barriers and making ‘reasonable adjustments’ in terms of buildings, service delivery and employment.
1.4. The Scheme outlines the key objectives how we intend to reinforce this commitment by achieving key objectives. It will be supported by the development of local service plans, which will be implemented from 2007 ensuring that everyone is fairly and equally treated with regard to race, gender, religion, colour, creed, sexuality, disability or any other determining aspects of peoples lives.
1.5. In recognition of the importance of effective inter cultural communication, which includes consideration of cultural practices, beliefs, lifestyles and appearance and the way in which all of these impact on the fairness of the system, the focus of Northampton Borough Council will be on Equality and Diversity.
1.6. Northampton Borough Council will shape its services to ensure that everyone connected with Northampton Borough Council in any capacity will be free from discrimination, prejudice and harassment. We will shape our services and organisation to focus on outcomes, rather than processes, putting the individual/s at the core of our functions.
1.7. The Disability Equality Scheme will be embedded into the day-to-day delivery of our services throughout the organisation. Northampton Borough Council is committed to Equality and Diversity and this scheme will be led by the Deputy Leader of the Council and Chief Executive who will be responsible for ensuring that it is implemented throughout the whole of the organisation.
Cllr David Palethorpe\
Deputy Leader of the Council
Mairi McLean\
Chief Executive 2. **What is a Disability Equality Scheme?**
2.1. A Disability Equality Scheme is a flexible framework that we can follow in order to meet our Disability Equality Duties. We are required to show the way in which disabled people have been involved in it’s development, the actions we will be taking to meet the Disability Equality Duty and where possible methods for assessing the impact of our policies and practices on equity for disabled, as well as arrangements for gathering information about performance in relation to disability equality.
2.2. Northampton Borough Council’s Disability Equality Scheme meets these requirements and contributes toward our aim of promoting good equalities practices across the Borough and ensures that we will strive to meet the needs of our disabled customers and employees. This Scheme sets out the framework within which Northampton Borough Council will promote equality for, and prevent discrimination against, disabled people as users of our services, as our employees and members of the community. It will enable Northampton Borough Council to:
- Meet the requirements of the Disability Discrimination Act and set out our plans to improve disability access to employment and services
- Make sure that we are taking the needs and views of disabled people into account when we design or deliver services, make access improvements or develop policies
- Continuously monitor and improve the ways in which we deliver services to disabled people
- Meet the principles of the Social Model of Disability
- Work in partnership with other organisations to promote disability equality and reduce discrimination in the wider community.
3. **Statutory Duties**
3.1. The Disability Discrimination Act 2005 imposes a number of specific statutory duties on the Council. These duties mean that we must, in carrying out all our functions, have due regard to the need to:
a) Eliminate unlawful discrimination
b) Eliminate unlawful harassment
c) Promote equality of opportunity between disabled people and other people
d) Take steps to take account of disabled people’s disabilities, even where that involves treating disabled people more favourably than other people.
e) Promote positive attitudes towards disabled people
f) Encourage disabled people to participate in public life
3.2. A core requirement of these duties is for Northampton Borough Council to:
- Prepare, publish and implement a Disability Equality Scheme
- Report annually on progress
4. **The social model of disability**
4.1. The Council acknowledges that disability is a consequence of barriers that prevent many people from full participation in society. This Scheme has been produced with regard to the *Social Model of Disability*.
4.2. Disability equality can mean different things to different people. Many disabled people consider that ‘disability’ arises from the interaction of people with impairments with excluding social, material and organisational barriers.
4.3. Without the social, material or organisational barriers, the impairment would still exist but the disability would not. The problem is not with the individual but the way that society reacts. 4.4. This is the social model of disability and is defined as:
“The recognition that primarily it is the loss or limitation of opportunities due to environmental and social barriers, that prevents people who have impairments from participating in society on an equal level with others.”
4.5. This model was developed in the early 1970s by disabled people, who used their personal experiences of discrimination to demonstrate that it is society’s failure to understand, rather than the actual impairment or disability that led to them, being socially excluded.
4.6. This Disability Equality Scheme clarifies Northampton Borough Council’s approach to eliminating disability discrimination. It is important that all employees across the Council implement the same approach and form a common understanding of this social model of disability. This Scheme outlines the work that will be needed to develop this common understanding and our approach to customer care and service provision.
4.7. We will ensure that all employees across the Council implement the same approach to form a common understanding of the Social Model. This Scheme and Action Plan outline the work that will be needed to develop this common understanding and our approach to customer care and service provision.
4.8. This Scheme also anticipates future disability legislation and recognises that our duties in this area are likely to expand.
5. Our Achievements to date
5.1. Northampton Borough Council has a positive track record of working with disabled people and representatives to improve service delivery and outcomes. Some of the key achievements are highlighted below:
a) Disabled people are consulted through Northampton Borough Council’s Disabled People’s Forum.
b) Northampton Borough Council has an Access Group. A key role of this group is to view Planning Applications; act as a group of consultees for involvement regarding issues of access for disabled people in the town.
c) Access Audit and access improvements to all our public buildings have been conducted. The Best Value Performance Indicator for this (BVPI 156) is 93% which is in the top quartile of performance.
d) Northampton Borough Council provides an advisory service with regard to Access issues internally as well as to external service providers. e) Northampton Borough Council Leisure Services were the first Authority in the East Midlands region to acquire Inclusive Fitness Initiative accreditation at Danes Camp Leisure Centre.
f) The refurbishment of the One Stop Shop in the Guildhall incorporated a number of access improvements including automatic doors, lowered counters and hearing loops.
6. Involvement of Disabled People
6.1. In developing this Scheme we have followed the guidance documents produced by the Disability Rights Commission in the Statutory Code of Practice on the Duty to Promote Disability Equality (www.drc-gb.org)
6.2. It is recognised that the involvement and participation of disabled people and employees is critical to the success of this Disability Equality Scheme and, therefore, this will be an ongoing activity.
6.3. In developing the Disability Equalities Scheme disabled people have been involved by:
- Steering group of disabled people who are members of Northampton Borough Council’s Disabled Peoples Forum and Access Group.
- Northampton Borough Council employees with disabilities have been meeting to progress the development of this Scheme.
- Steering group attended a meeting with representatives from Ability Northants (formerly Northamptonshire Council for the Disabled) and colleagues from Kettering and Wellingborough Borough Council to discuss shared issues and good practice in the development of the Action Plans.
- The draft scheme has been forwarded to all members of Disabled People’s Forum, Northampton Borough Council Access Group, Equalities Steering Group, Disability Equality Team, all Councillors, Senior Management Team, Managers and Team Leaders for comments.
6.4. It is intended that this process of involvement of disabled people will continue through any existing mechanisms and that we will also look at the ways in which we currently involve members of our community and assess whether there are ways in which we can engage disabled people more effectively. 7. Northampton Disability Demography
7.1. Department of Work & Pensions (DWP) advise that there is no standard measure or estimate of the numbers of disabled people. Equalities monitoring is not widely carried out in practice, therefore the data that is available should be viewed as indicative data only.
7.2. A key challenge for Northampton Borough Council is to establish the diverse needs of people who have different types and levels of disability. There is currently a lack of clarity in defining disability, which affects both the presentation and interpretation of statistical information. It is essential that Northampton Borough Council work with other agencies to develop a clearer and accurate picture of its local community. This will allow a baseline position to be established, whilst developing local performance targets.
7.2. The following national disability demographic information is available:
- Estimated 11 million disabled adults in the United Kingdom (1 in 5 of the total adult population) and 770,000 disabled children.
- Estimated spending capacity of £40 billion.
- 1 in 4 households have regular contact with a disabled person.
- 92% of disabled people live in their own homes.
- 8% born with a disability.
- More disabled women than men
- People often have more than one disability
7.3. Statistics from the Office of the Deputy Prime Minister (ODPM), or Department of Communities & Local Government (DCLG) suggest that it is widely accepted that 20% of the population have some form of disability as defined by the Disability Discrimination Act (2005). An assumption based on these figures would indicate that there are approximately 40,000 disabled people living in Northampton Borough:
| Type of disability | Number (millions) | |-----------------------------|-------------------| | Lifting and carrying | 7 | | Mobility | 6 | | Physical co-ordination | 5.6 | | Learning and understanding | 3.9 | | Seeing and hearing | 3.9 |
Source: OPDM
7.4. Northamptonshire Association for the Blind confirm that there are approximately 3,000 Registered Blind people within Northamptonshire. It is known that only 1 in 4 people register, therefore a projected figure of between 10,000 – 12,000 is more accurate. There are a total of 51 people with guide dogs in Northampton. 7.5. The Sensory Impairment Unit of Northamptonshire County Council indicate that within the postcode areas of NN1 –NN5 there are 635 Registered Blind people and 369 are partially sighted. The highest incidence of both of these are located in the postcode NN3.
7.6. The Sensory Impairment Unit of Northampton County Council indicate that there are approximately 90,000 people registered as having a hearing impairment in Northamptonshire although figures are estimated to be as high as 270,000. There are 14 people in Northamptonshire with hearing dogs.
8. Working with our Partners
8.1. We have been working in partnership with many organisations for a number of years and recognise the added value that this creates. We will ensure that disability equality remains a central element of future joint working arrangements. A training and development programme will underpin this Disability Equality Scheme.
9. Northampton Borough Council’s priorities
9.1. Northampton Borough Council has developed a draft Corporate Plan for 2007-2011. The Council’s 6 priorities are identified as:
1. Making Northampton a cleaner, safer and greener place to live
2. Investing in the planning and regeneration of the Town, providing economic development and growth. Listening to local people and providing the services they need
3. Delivering better basic services
4. Being an accessible and responsive council by listening to local people and providing the services they need
5. An increased community leadership role alongside our partners
6. Improving our performance as a council and to be fit for purpose by delivering our priorities for improvements:
- Improve our weakest services
- Improve our interaction with the public
- Improve partnerships to deliver better outcomes
- Ensure clear, decisive political leadership
- Strengthen our financial management
- Build management capacity to drive cultural change 9.2. Each priority will have its own aims, objectives, targets and outcomes. Departments will plan how they will meet their targets and deliver services to meet these identified priorities. The Borough Council’s approach is to mainstream activities across all services in order to ensure that people with any kind of disability are able to access and use services, and are not discriminated against, directly or indirectly, as a result of their disability.
9.3. We aim, in partnership with others, to deliver public services of consistently high quality and improve the quality of life and life chances of all our communities.
9.4. This Disability Equality Scheme will be delivered through all the Council’s priorities and will assist us to adopt and develop characteristics that will enable us to become an excellent provider of services and an employer of choice.
10. Monitoring, reviewing and publishing the results
10.1. Monitoring of the Disability Equalities Scheme will be achieved through a Steering group. The membership will be:
a) Disabled service users b) Disabled employees c) Disabled people d) Portfolio Holder e) Councillors f) Senior Management representative
10.2. This group will meet quarterly to review progress against the action plan. Performance monitoring will also occur at a service level, and reported on at Quarterly Performance Review meetings where a panel of Councillors and Managers challenge and review progress and performance of services.
10.3. Northampton Borough Council will monitor and analyse policies, services, procedures and functions for any adverse impact on disability equality. This will be achieved through:
• Statistical analysis of monitoring data • Satisfaction surveys • Random or targeted surveys • Meetings, focus groups or other reference or consultation groups • Monitoring of Customer Feedback (comments, compliments and complaints) 10.4. We will use the findings of this monitoring to make any necessary changes to proposed policies, procedures or services.
10.5. Monitoring will be in keeping with Best Values Performance standards and arrangements will be developed and introduced to ensure that we effectively co-ordinate our monitoring role in line with our responsibilities under the Disability Equality Duty, and these are detailed in the Action Plan.
10.6. The Action Plan will be regularly reviewed and the results published on an annual basis in appropriate formats. The Scheme will undergo a full review in 2009.
10.7. The results of this monitoring will be published internally and externally. The way we publish the results may vary, for example some results will be published periodically within reports provided by individual services, others will be published on an annual basis.
10.8. The annual report will include an update on the Action Plan, and will also show what has changed as a result of involving disabled people.
10.9. We will inform the public and employees about this information through:
- The Council’s newsletter which is delivered to all homes in the Borough
- ‘Nb’ the Council’s briefing paper for employees
- Existing and new forums and groups
- Relevant voluntary organisations, community groups and representatives
- The Council’s website and intranet
11. **Equality Standard for Local Government**
11.1. In order to deliver our overall commitments on equality and diversity, the Council has adopted the Equality Standard for Local Government. The Equality Standard is not a legal requirement but is a framework through which local authorities can meet their legal obligations under anti-discrimination legislation.
11.2. The Equality Standard for Local Government sets out a generic ‘equality framework’ for local authorities to mainstream and audit equality of opportunity across all areas of the organisation and through which their statutory obligations in respect of anti-discrimination laws can be met. 11.3. It was developed through the joint co-operation of the Employers’ Organisation for Local Government, the Commission for Racial Equality, the Equal Opportunities Commission, the Disability Rights Commission and the Audit Commission. The level of achievement reached under that standard is a Best Value Performance Indicator in connection with the Audit Commissions’ CPA programme.
11.3. Through a five-level framework of performance the Equality Standard for Local Government acts as a guide towards achieving continuous improvement of the equalities field. Targets applicable to each level need to be achieved before an authority can move onto the next level.
11.4. Northampton Borough Council has achieved Level One. This means that a commitment has been made to developing a comprehensive equality policy, covering employment and pay, service planning and delivery, and procurement.
11.5. Northampton Borough Council is currently working to achieve Level Two. To achieve this Standard the Council must engage in a process of assessment and consultation around the impact of services on local groups, the findings of which must be made public. In addition to this it is required to develop employment and procurement strategies. The target date for achieving this Standard is March 2007.
12. Implementation of the Disability Equality Scheme
12.1. This Disability Equality Scheme is based on the six core areas, which form the basis of the Disability Equality Duty. The six areas are:
1. Eliminate unlawful discrimination
2. Eliminate unlawful harassment
3. Promote equality of opportunity between disabled people and non-disabled people
4. Take steps to take account of disabled people’s disabilities, even where that involves treating disabled people more favourably than non-disabled people.
5. Promote positive attitudes towards disabled people
6. Encourage disabled people to participate in public life
12.2. The attached Action Plan details the steps we are taking to implement this Scheme. The detail and progress will be reviewed and amended accordingly through existing performance monitoring on a quarterly basis in each service area and the Disability Equality Steering Group.
## Disability Equality Scheme Action Plan 2006 – 2009
| Objective | Action(s) | Outcome/PI | Action By | Projected Timescale | |-----------|-----------|------------|-----------|--------------------| | 1. Eliminate discrimination that is unlawful under the Disability Discrimination Act | | | | | | 1.1 Encourage disabled people to apply for jobs at all levels | Advertise in publications relevant to disabled people | Review current practice and improve where necessary and appropriate | Corporate Manager (Human Resources) | March 2007 | | | State on job advertisements that applications are welcomed from disabled people | Increase in number of disabled people applying for jobs | | January 2007 | | | Interviews guaranteed to disabled people who meet minimum requirements required for position applied for | | | | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 1.2 | Raise awareness regarding disabled people’s needs for attendance at interviews and at meetings | More accessible meetings will encourage disabled people to engage with NBC | Corporate Manager (Human Resources) | Reasonable adjustments at interview already requested and implemented. | | | Ensure regular maintenance and replacement programme for facilities | Accessible meetings checklist developed and ready for circulation | Health Wellbeing and Access Team Leader | Accessible Meetings document circulated to all employees and published on Intranet by March 2007 | | | Develop facilities available list and raise awareness with employees | | Facilities Management | Facilities list to be produced by March 2008 | | 1.3 | Monitor our Complaints, Compliments and Comments Procedure with reference to disability. | Complaints monitored to identify and eradicate discriminatory behaviour | Corporate Manager (Human Resources) | By December 2008 | | | Monitor Grievance and Disciplinary cases with reference to disability | Non-discriminatory Employment practices | | | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 1.4 Ensure Council employees and Councillors have adequate knowledge of what constitutes unlawful discrimination | Review, strengthen and develop disability equality and awareness training for members and employees. Evaluate equality-training programme on an annual basis and make necessary changes. | Increased staff and member awareness of the Council’s commitment to eliminate discrimination. Training takes account of new developments in the field of discrimination. | Corporate Manager (Human Resources) Corporate Manager (Governance) | By March 2007. |
2. Eliminate harassment of disabled people that is related to their disability
| 2.1 Raise awareness of what constitutes harassment of disabled people | Communicate with employees of the Council via the intranet, core brief, workshops, bulletins etc. Develop training programme for front line officers and managers. Develop publicity material and make information available in the Customer Service Centre and all Council-owned premises. | Increased awareness and understanding by employees. Key staff fully trained to recognise harassment. Increased awareness and understanding by the general public | Corporate Manager (Human Resources) Customer Access Manager Team Leaders | By June 2007 By June 2007 By June 2007 | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 2.3 | Encourage specific use of facilities for disabled people such as parking spaces/giving up seats etc | NBC to set a good example by raising awareness of the importance and use of such facilities and to work with partners to enforce use of facilities | Increased awareness and use of facilities | All Managers and Team Leaders | January 2007 | | 2.4 | Review internal harassment Policies | Carry out equality impact assessment on existing policy | A robust policy supporting disabled people and dealing with harassment on the grounds of disability | Corporate Manager (Human Resources) | December 2006 | | 2.5 | Develop awards scheme for external service providers to reward good practice | Work with partners to develop and implement a good practice award scheme. | Awards scheme implemented and first awards made | Corporate Manager (Customer Services) | June 2008 | | | | | | Health Wellbeing and Access Team Leader | | | | | | | Kettering & Wellingborough Borough Councils | | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 3. Promote equality of opportunity between disabled people and other people | | | | | | 3.1 Raise awareness of disability issues and discrimination experienced by disabled people and their families and friends | Publicise scheme etc | Raise awareness | Health Wellbeing and Access Team Leader and Communications Manager | Ongoing from December 2006 | | | Training and education to minimise poor attitudes | Reductions in complaints relating to disability discrimination | People Development Manager | All front line staff trained by December 2007 | | | In-house disability awareness/equalities training for all employees and Councillors | Well informed employees able to provide a better service to our customers | Corporate Manager (Customer Services) | All staff trained by December 2008 | | 3.2 Encourage and promote diversity within our workforce and the democratic process | Councillors can be encouraged to disclose their disability through Political Group Leaders and Councillor training | Increased awareness within the political parties of disability issues | Leader of the Council Group Leaders Councillors with disabilities | Following 2007 Elections | | | HR report monthly on Disability statistics | An inclusive environmental culture and increase in the number of employees who feel safe and comfortable | Corporate Manager (Human Resources) | Continuing monthly monitoring of statistics relating to disability | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 3.4 Involve disabled people more | Customer Panel | Increase in the number of disabled employees and customers being involved and willing to participate in consultation exercises | All Corporate Managers | As per Consultation Strategy | | | Forum Meetings | | | From April 2007 | | | Customer Research | | | | | | Exit Surveys | | | | | | Customer Satisfaction Surveys | | | | | | Customer Feedback | | | | | | • Listening | | | | | | • Action | | | | | | • Service Improvements | | | | | | Service Plans | | | | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 3.5 Ensure we have accessible services and Public buildings. | Continue to comply with all appropriate legislative requirements for building accessibility for all NBC buildings to which the public have access. Ensure public facing services are aware of disabled peoples needs and can respond accordingly. Re-circulate Accessible Information leaflet to all employees and ensure publication on Intranet by March 2007. Explore purchase and implementation of Textbox and Video Interpreting. Ensure resources are available to continue access improvements and reviews. | A more inclusive environment BVPI 156 (Disabled Access to Public Buildings) Ensure employees are aware of the barriers faced by disabled people and can act to remove those barriers e.g. Textbox, Video Interpreting. | Health Wellbeing and Access Team Leader Corporate Manager (Customer Services) | Commenced 2001 – ongoing Currently 90% | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 3.7 Review Disability Equality Scheme | To update scheme in line with any change to legislation or other key criteria. Quarterly monitoring | New scheme produced by December 2009 | Health Wellbeing and Access Team Leader Corporate Manager (Customer Services) | By Dec 2009 |
4. Take steps to meet disabled people’s needs, even if this requires more favourable treatment
| 4.1 Monitor performance – BVPI’s | Publish performance statistics Action taken to improve performance | Relevant BVPI’s KPI’s etc | Corporate Manager (Performance and Improvement) | January 2007 | | 4.2 Identify and promote specific facilities and services which are provided for disabled people | Use communication channels to promote specific facilities to disabled people and disability organisations | Improved customer satisfaction of disabled people | All Managers and Team Leaders | December 2007 | | 4.3 To demonstrate commitment to the disability symbol | Maintain the employment ‘two ticks’ ‘Positive about Disabled People’ disability | To retain the use of the symbol and to carry out improvements where | Corporate Manager (Human Resources) | March 2007 | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 5. Promote positive attitudes towards disabled people | | | | | | 5.1 Promote disability awareness through our use of the media both internally and externally | Promoting special articles regarding disability and access awareness e.g. A Boards as well as promoting examples of good practice | Quarterly articles promoting positive images of disability and raising awareness of disability related and access issues | Communications Manager | Some articles/issues already promoted. Repeat article regarding Christmas Shopping displays Dec 2006, thereafter quarterly. | | 5.2 Raise staff awareness and ensure commitment throughout the organisation of the duty and requirements of the Act | Production, publication and dissemination (including Intranet) of DDA 2005 information sheet | As employee awareness increases complaints regarding direct and indirect discrimination should decrease. Disabled customers should feel greater customer satisfaction. | Corporate Manager Customer Services Health Wellbeing and Access Team Leader | March 2007 | | 5.3 Carry out equality impact assessments on policies and services | As part of the Corporate Equalities Plan to begin to prioritise and carry out impact assessments on policies (and then services) | Increased number of policies that have been assessed. Reviewed, updated and robust policies which | Corporate Manager Performance and Improvement Policy Team Leader | December 2008 | | Objective | Action(s) | Outcome/PI | Action By | Timescale | |-----------|-----------|------------|-----------|-----------| | 6. Encourage participation by disabled people in public life | 6.1 Raise awareness of opportunities available to disabled people e.g. positions such as school governors, councillors etc. | Work with disability organisations and partners to promote opportunities for participation in public life | Increased awareness and monitoring of take up of opportunities by disabled people | Communications Manager, Corporate Manager (Customer Services) | December 2009 |
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42f09331733edc4966ff5a9c5f95eaca1950799b | HATE CRIME
Public statement on prosecuting disability hate crime and other crimes against disabled people
Crown Prosecution Service cps.gov.uk Hate crimes often have a disproportionate impact on the victim because they are being targeted for a personal characteristic. We recognise that hate crime not only impacts the individual victim but also the wider community. Hate incidents as one-offs or a related series of events can send reverberations through communities, just as they can reinforce established patterns of prejudice and discrimination. This is why it is so important for hate crime to be prosecuted effectively.
Our policy is to:
- Identify disability hate crimes and other offences targeted at disabled people as early as possible
- Build strong cases with our partners that satisfy the tests within the Code for Crown Prosecutors
- Remind the court of its powers to increase a sentence under s.146 Criminal Justice Act 2003 where there is evidence of disability hate crime i.e. hostility based on disability or presumed disability, including minor offending
- Apply for an increased sentence in all other cases where disability is an aggravating factor in the case
- Support disabled victims and witnesses to give their best evidence
- Work closely with the police, criminal justice agencies, academics, community stakeholders and other bodies to continuously refresh our understanding of disability hate crime and crimes against disabled people and to improve our response to it
- Improve awareness of disability hate crime and public confidence to report it
- Monitor the implementation of this policy.
When presented with cases that involve disabled people, we will be aware that:
- Disability hate crime and other crimes against disabled people may be underpinned by disablism or prejudice against disabled people
- The stereotype based belief that disabled people as a group are somehow inherently vulnerable, weak and easy targets is an attitude that motivates some crimes against disabled people
- The prejudice, discrimination and social exclusion experienced by many disabled people is not the inevitable result of their impairments or medical conditions, but rather stems from specific barriers they experience on a daily basis: this is known as the social model of disability.
When deciding whether it is in the public interest to prosecute disability hate crime or crimes against disabled people, our prosecutors must have regard to the Code for Crown Prosecutors. The Code states that where the offence was motivated by any form of discrimination, including the victim’s disability or whether the suspect demonstrated hostility towards the victim based on disability, the presence of any such motivation or hostility will mean that it is more likely that prosecution is required. Monitored disability hate crime
In order to identify cases involving disability hate crime, we have agreed with the police a shared definition. This definition is wider than the legal definition of a hate crime within the CJA 2003 to ensure we capture all relevant cases:
“Any incident/crime which is perceived by the victim or any other person, to be motivated by hostility or prejudice based on a person’s disability or perceived disability.”
It is important that relevant incidents are identified as hate crimes as early as possible. This will assist the police to obtain the best available evidence in order to support the aggravating factor at court and at sentence.
Once a case has been flagged as a hate crime and received by the CPS, it is CPS policy not to remove the flag for any reason other than administrative error. This signals the CPS commitment to treat all such crimes seriously and to accept the victim’s perspective, even where we are unable to identify sufficient evidence to prosecute the case as a hate crime.
The legal framework for disability hate crime
1. Sentence uplift under s.146
S.146 CJA 2003 gives the court the power to increase the sentence of any offence that is aggravated by hostility on the grounds of disability. An offence will be a disability hate crime if:
- At the time of committing the offence, or immediately before or after doing so, the offender demonstrated towards the victim of the offence hostility based on a disability (or presumed disability) of the victim; or
- The offence is motivated (wholly or partly) by hostility towards persons who have a disability or a particular disability.
Both the CJA 2003 and the police/CPS definition refer to hostility, not hatred. There is no statutory definition of hostility and the everyday or dictionary definition is applied, encompassing a broad spectrum of behaviour.
For more information about the nature of disability hate crime, see the CPS legal guidance.
Crimes against disabled people
It’s important to make a distinction between a disability hate crime and a crime committed against a disabled person because of his or her perceived disability. A disability hate crime is any crime committed in any of the circumstances explained in the section on s.146 CJA 2003 above. Some crimes are committed because the offender perceives the disabled person to be vulnerable and not because the offender dislikes or hates the person or disabled people. Our overriding aim is to protect disabled persons when they are targeted, even if the offence does not meet the legal definition of a disability hate crime. We will therefore put before the court any evidence that a disabled person is targeted for this reason, so that the sentence reflects the gravity of such offending.
In this policy, we define crimes against disabled people as:
“Any crime in which disability is a factor, including the impact on the victim and where the perpetrator’s perception that the victim was disabled was a determining factor in his or her decision to offend against the specific victim.”
We define disability as any physical or mental impairment, which is the definition used in the Criminal Justice Act 2003. This definition fully incorporates the definition of disability for the purposes of the Equality Act 2010.
Examples of types of crimes committed against disabled people are:
- “Mate crime” or “befriending crime”: the victim is groomed or befriended and subjected to financial or sexual exploitation; or made to commit minor criminal offences such as shoplifting; or the victim’s accommodation is taken over to commit further offences, such as taking/selling drugs, handling stolen goods, encouraging under-age drinking and sexual behaviour
- Criminal assault, abuse or neglect of a disabled person where there is an existing relationship and an expectation of trust: for example, where the perpetrator is a paid carer, family member, friend, support worker or volunteer.
For more detailed information on the types of crimes committed against disabled people see the hate crime page on the CPS website.
Offending behaviour
Hate crime can take many forms, ranging from verbal abuse to physical and sexual assault and can include threats, criminal damage, harassment, stalking and anti-social behaviour. Incidents can be one-off events or form part of a series of repeated and targeted offending. The hostility may be targeted at individuals, groups, those associated with such groups, or property e.g. homes, places of work or worship, and community venues. Hate crime can occur anywhere.
Hostility and hatred might be based on misconceptions about the individual’s characteristics. However, there is no need to confirm a victim’s personal characteristics in order to prosecute a hate crime. Evidence of hostility based on the perpetrator’s presumption of the victim’s disability is sufficient.
We recognise that the victims of hate crime can be repeatedly targeted. We will encourage the police to investigate any previous incidents or allegations. We will bring charges that reflect the overall picture of offending or if possible make a bad character application to the court to present evidence of previous conduct towards the victim or others. We recognise that people can be targeted for a combination of reasons, including sexual orientation and transgender identity, race and religion in addition to their disability. Prosecutors will consider the most appropriate charges and apply to courts for an appropriate increase in sentence, based upon all relevant aggravating features.
**The social model of disability**
We understand the social model of disability to mean that the prejudice, discrimination and social exclusion experienced by many disabled people is not the inevitable result of their impairments or medical conditions, but rather stems from specific barriers they experience on a daily basis. These barriers can be environmental (inaccessible buildings and services), attitudinal (stereotyping, prejudice and discrimination), and organisational (inflexible policies, practices and procedures). Using the social model helps us to dismantle or reduce the effects of those barriers that are within our power, and improve the safety and security of disabled people.
Reporting a crime, giving a statement and being called to give evidence in court can be very daunting experiences for anyone. We recognise that disabled people can experience specific barriers in this regard. These can include a failure by criminal justice agencies to identify an incident as a potential disability hate crime, inaccessible courtrooms, witness waiting areas or an absence of sign language interpreters.
We are concerned to avoid incorrect judgments being made about disabled people’s reliability or credibility as a witness giving evidence in court. Such judgments may lead to an incorrect charging decision or could undermine the potential success of a prosecution.
Thus we will:
- Not make assumptions about a disabled victim’s reliability or credibility, and challenge others who do so
- Ensure that disabled people are aware of the support that is available to them to give their best evidence
- Be more likely to prosecute cases where disability is a factor, including disability hate crimes where there is sufficient evidence to do so.
- Be mindful that language is important and only use the term ‘vulnerable’ in relation to disabled people when it is appropriate in the context of the law and facts of the case
- Recognise that the stereotype based belief that a disabled person is ‘vulnerable’ forms the backdrop of disability hate crime and crimes against disabled people and can even be a motivating factor in crimes committed against them.
**Situational risk and ‘vulnerable victims’**
We are aware that disabled people are regularly labelled as “vulnerable”.
This labelling has been repeatedly criticised by disabled people and others and is not in line with the social model of disability. We understand that use of this label can give the message that disabled people are inherently “weak” or “dependent” as individuals and as a group, when in fact it is physical barriers and social attitudes that create inaccessible, unsafe and therefore vulnerable situations for disabled people.
Moreover, the belief that disabled people are vulnerable may be disabling in itself and can lead to decisions and actions that adversely affect disabled people’s independence, safety and security. Crucially, in the context of the criminal justice system, this attitude can undermine their perceived competence, credibility and reliability as a witness, and, therefore, their access to justice.
We recognise that it is therefore preferable to refer to a ‘situational risk’, or an ‘at risk situation’ that a disabled person may find themselves in, due to particular circumstances, as opposed to referring to the disabled person as ‘vulnerable’. Like many people, those who are disabled experience situational risks, which may be taken advantage of by an offender, or provide the opportunity for the offender to act on their hostility towards disabled people. These risks can be connected to a person’s gender, job, disability or other factors and characteristics.
We will avoid the use of the term “vulnerable” where possible and we will always avoid any use of the term which may suggest disabled people are inherently weak or dependent.
However, the term is unfortunately sometimes unavoidable in the context of criminal proceedings, due to the wording of the law and relevant Sentencing Guidelines. For example, if prosecutors do not use the term in court, they may be unable to properly explain that an offence is aggravated because of a victim’s “vulnerability”, and should attract an increased sentence. This would in turn disadvantage the disabled victim, as the perpetrator may receive a more lenient sentence than is appropriate.
Our legal guidance on Prosecuting cases of Disability Hate Crime also sometimes refers to a “vulnerable” victim or person. But it does so only where necessary. This will be in the context of the person being in an ‘at risk situation’ in relation to a particular criminal offence, in particular circumstances, for the purposes of a Sentencing Guideline, or an application for special measures for a “vulnerable witness”.
**Reporting hate crime**
It is important that all hate crime incidents are reported to the police. It is also invaluable for the police to be made aware of any previous behaviour or patterns of behaviour which relate to the same victim or perpetrator, so that all circumstances can be appropriately taken into account. It is for the police to investigate the incident and to decide whether to refer the case to the CPS for a decision on whether to charge the suspect and, if so, with what offence.
**Internet and social media**
Hate crime can be perpetrated online or offline, or there can be a pattern of behaviour that includes both. The internet and social media in particular have provided new platforms for offending behaviour and our revised guidance on the prosecution of social media cases provides more detail. In approaching online hate crime, we will:
- Recognise that modern communications technology provides opportunities for hate crime
- Understand internet and social media platforms as well as their community standards and policies for taking down material
- Be familiar with the relevant law and referral systems
- Be alert to the need to identify originators as well as amplifiers or disseminators
- Prosecute complaints of hate crime online with the same robust and proactive approach used with offline offending, whilst recognising that children may not appreciate the potential harm and seriousness of their communications
- Consider the potential impact on a targeted individual or community
- Treat online complaints as seriously as offline complaints and encourage all to be reported to the police.
As with all hate crime offences the police will be required to seek a charging decision from us.
**Criminal investigation**
We adopt a proactive approach and will seek further evidence where necessary from the police, to assist in the identification of evidence of hostility to support a sentence uplift application. In some cases, we may advise the police to follow up other possible lines of enquiry. This may include looking at previous reported incidents involving the same victim, or the same suspect. It may also involve seeking information or evidence from other agencies such as Social Services, NHS, specialist support groups and community groups working with disabled people.
**Charging decisions**
When making charging decisions in cases of disability hate crime and other crimes against disabled people, as in all cases, prosecutors must apply the [Code for Crown Prosecutors](#).
**Bail**
If there is a risk of danger or threats or repeat offences, we will seek to protect victims and witnesses by applying to the court to remand the defendant in custody where appropriate, or by asking the court to impose conditions on bail where possible (for example, not to approach any named person or to keep away from a certain area).
**Prosecution and sentencing**
In prosecutions involving disability hate crime, we will build cases to enable us to present evidence of hostility based on disability where possible.
We will remind the court of its powers to increase the sentence under s.146. [The Sentencing Council Guidelines](#) provide an offence by offence basis on the way in which the s.146 uplift is determined. Where there is insufficient evidence of disability hostility for the purposes of s.146, but disability was a factor in the case in some other way, we will present evidence of statutory and other aggravating factors that may increase the seriousness of the case and the sentence.
For example, in some cases the victim’s disability is not a factor in the offender’s decision to target him or her. However the impact of the crime on the victim is significant because of his or her disability. This evidence of harm caused to the victim will be brought to the court’s attention as a factor that increases the seriousness of the offence.
We shall draw the court’s attention to a Victim Personal Statement (VPS), which gives victims an opportunity to describe the effects of the crime upon them, express their concerns and indicate whether or not they require any support. Making a VPS is entirely optional. Victims are entitled to choose whether they would like to read their VPS aloud in court, whether they would like someone else to read it aloud or whether it should be played back, if recorded, for them. A Community Impact Statement may also be made to show the impact of offending on the wider community, including the disabled community.
We have a responsibility to assist the court in sentencing. Prosecutors will apply for appropriate additional or ancillary orders, including restraining orders and compensation for loss, injury or damage. We will always have regard to the victim’s needs, including the question of their future protection.
The court has a duty to give reasons for, and explain the effect of, the sentence that it imposes.
Withdrawal
Sometimes a victim will ask the police not to proceed any further with the case or will ask to withdraw the complaint. We will consider the impact on the victim of not proceeding, including the risk of further harm to the victim, however this does not necessarily mean that the case will automatically be stopped. Applying the Code for Crown Prosecutors, we will prosecute all cases where there is sufficient evidence; it is in the public interest to do so and there are no factors that prevent us from doing so.
Case progress - information for victims
Information on how victims of crime are kept informed of case progress can be found in the Code of Practice for Victims of Crime.
Victims’ Right to Review
For qualifying decisions, if a victim requests a review of our decision not to bring proceedings, or to end all proceedings, we will look again at the decision to establish if it was correct. For information on how to ask for a review of a decision see The Victims’ Right to Review Guidance. Support
It is important to note that the majority of disability hate crime prosecutions result in a guilty plea from defendants, reducing the need for victims and witnesses to give evidence in court. However where victims and witnesses are required to give evidence, we are committed to supporting them to give their best evidence.
Victims of hate crime are entitled to enhanced support services. Victims who are intimidated can be supported by applications to the court for Special Measures. Special Measures are a series of provisions that help ‘vulnerable’ and ‘intimidated’ witnesses give their best evidence in court and help to relieve some of the stress associated with giving evidence. Special measures can include the use of screens in court so the victim or witness does not have to see the defendant, or giving evidence from a separate courtroom via a video link. These measures can help reduce stress and anxiety. Automatic reporting restrictions apply to persons under the age of 18 in cases in the Youth Court and to victims of rape and other serious sexual offences, irrespective of age. Reporting restrictions can also be applied for in other circumstances, if specific criteria are satisfied, to protect the identity of the victim.
We have published a specific Support Guide for disabled victims and witnesses of crime, to accompany this Public Statement. The Support Guide sets out the range of support available to disabled victims of crime, from the CPS, the police and other criminal justice agencies. The aim of the Guide is to support victims and witnesses to give their best evidence.
More information can be found on the Victims and Witnesses section of the CPS website.
Equality duty
We are a public authority for the purposes of equality legislation. This policy and our related legal guidance, and our new Support Guide form a key part of our efforts to meet our obligations under the Public Sector Equality Duty to eliminate unlawful discrimination, harassment and victimisation of disabled people and to promote equality and good relations.
Working with stakeholders
We work locally and nationally with the police and other partners who have a role in addressing hate crime, as well as with individuals, community groups and academics with experience and expertise in relation to hate crime. This ensures that we are able to continuously refresh our understanding of the nature of disability hate crime and can improve our response to it.
Monitoring and Implementation
We will monitor our performance through our Hate Crime Assurance Scheme, under the oversight of our hate crime governance structures. We will also receive feedback on our performance through our local and national panels that provide scrutiny of CPS cases, decisions and policies. Our Hate Crime Annual Report provides transparent accountability in respect to our performance.
It should be noted that the CPS can only monitor the work of the CPS.
**Hate Crime Webpage**
We have created a [hate crime page on the CPS website](#), to provide more detail on the CPS approach to hate crime. The webpage includes the following information on disability hate crime and crimes against disabled people:
- The legal context of disability hate crime
- Witnesses’ competence, reliability and credibility
- Behaviours and related offences, including “mate crime”
- What happens if a victim withdraws or no longer wishes to give evidence
- Sentencing
- Implementation of the CPS Policy About the Crown Prosecution Service
The CPS is responsible for prosecuting most cases heard in the criminal courts in England and Wales. It is led by the Director of Public Prosecutions and acts independently on criminal cases investigated by the police and other agencies. The CPS is responsible for deciding the appropriate charge in more serious or complex cases and provides information, assistance and support to victims and witnesses.
cps.gov.uk
@cpsuk
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2a18fd62ba62a8345b10ed7c5c5287335d076694 | Dear Ms Doll,
**Condition 5 of the passenger and station licences - Disabled People’s Protection Policy (DPPP)**
I write regarding Govia Thameslink Railway Limited’s (GTR) compliance with condition 5 of its passenger and station licences.
In previous correspondence, we said that we were placing GTR under enhanced monitoring of performance regarding condition 5. This period has come to an end and we consider that GTR has provided assurance that it has systems and processes in place to provide the necessary assistance to passengers as required under its Disabled People’s Protection Policy. We summarise below the information we have taken into account in our assessment.
**Background**
Under its passenger and station licences GTR is required to establish and comply with a Disabled People’s Protection Policy (DPPP), setting out how it will protect the interests of people who are disabled in their use of trains operated by GTR and facilitate such use. ORR approved GTR’s current DPPP in May 2016.
Our expectation is that all licence holders comply with their approved DPPP, as well as with wider equalities legislation, which ORR does not have the power to enforce but which remains relevant in this context. We take these matters seriously and would be concerned to identify any practices that prevented passengers who require assistance from making journeys by rail with confidence.
In late summer 2016 concerns were raised with us by members of the public, passengers with disabilities, MPs, and the RMT union about the planned changes in staffing on Southern services. Between August 2016 and June 2017 we met and corresponded with you on a number of occasions in order to clarify the effect that the proposed changes might have on passengers with disabilities and how any potential impacts would be mitigated.
Following the introduction of GTR’s staffing changes in January 2017, we decided to initiate enhanced monitoring arrangements to ensure that GTR remained in compliance. with its approved DPPP on Southern services (noting that the proposed changes did not require amendment of the approved DPPP).
**Summary of assurances provided by GTR**
The specific concern relating to accessibility was around the role of conductor changing to that of ‘On Board Supervisor’ (OBS). Whilst a conductor was required on a train before it could depart from a platform, due to a change in the way train doors are controlled, trains can now run without an OBS on board in ‘exceptional circumstances’.
In summary, we understand from the conversations and written communications with you that the following measures and guarantees are now in place.
**Staffing:**
- You have guaranteed that every train previously operated with a conductor will continue to have either a conductor or an OBS rostered;
- In addition, you have recruited approximately 100 extra staff to work as OBSs and provide further resilience to your services;
- Trains will run without an OBS on board in ‘exceptional circumstances’ only. You originally informed us that you had estimated that this could equate to approximately 0.06% of all trains (see further below);
- The OBS is able to walk through the train and provide assistance to passengers, is provided with disability awareness training, as well as training in safety and ramp deployment; and
- Station staff are also trained to provide assistance to passengers where required.
**Assistance processes and options for passengers:**
Where a train runs without an OBS on board GTR will discuss with any affected passenger the best way to assist him/her to their destination. There are a number of options available to passengers in such circumstances. These include:
- Waiting for the next service with an OBS (where this is scheduled to arrive within a reasonable period of time); or
- The provision of alternative accessible transport, such as an accessible taxi, to the end destination (this service is provided free of charge to the passenger); or
- Choosing to join a service at a staffed station and alighting at a staffed station (that is accessible to the passenger), with the provision of free alternative accessible transport to their final destination if this is then required.
You have also told us that station teams are fully briefed on the process to ensure that the OBS on the service is informed that a passenger requiring assistance has boarded the train, the physical location of the passenger and their destination. This is a face-to-face handover between the station staff and the OBS. This process also identifies to station staff where an OBS is not on board the train. The process is critical to ensure that passengers are provided with assistance to disembark the train, especially when their destination is a station which is not staffed from first to last train. **Assistance team:**
For those Southern services which have moved from a conductor to an OBS a new assistance team has been established in the Southern control centre. The team are available from 05:00 until 23:00. The role of the team is to:
- Provide assistance to passengers who contact them via help points at stations or through a new dedicated freephone helpline number, and to liaise with the OBS team to make sure that passenger assistance is provided;
- Provide a single point of contact for the OBS team to notify if they are unable to join their rostered service; and
- Proactively contact those passengers who have pre-booked assistance in order to make suitable alternative arrangements with the passenger, where it is known sufficiently well in advance that an OBS will not be available for a particular service.
**Communication:**
For those Southern services which have moved from a conductor to an OBS:
- Help points have been re-labelled to make clear that they can be used to contact the passenger assistance team in the Southern control centre for help;
- Station posters have been updated (and in some cases re-sited) to make it clear how to get assistance at unstaffed stations;
- Posters include the new freephone helpline number established to ensure that passengers are able to make contact with a member of staff; and
- When an OBS is unable to join a service at the last minute, information is provided to passengers at stations on both customer information screens and as audible announcements made by the assistance team.
**Enhanced monitoring**
In March 2017 we confirmed that the above processes and procedures were potentially capable of delivering the requirements to provide assistance to passengers, including in situations where an OBS was not available. For that reason, no amendment to GTR’s DPPP was considered necessary. We advised, however, that we would be putting the company on a period of enhanced monitoring until the end of May 2017 to ensure that the processes and procedures described were working effectively in practice.
As part of that enhanced monitoring, we requested that you provided us with the following data:
- The number of passengers who had booked assistance who were affected by an OBS not being available, and details of the alternative assistance provided; and
- The number of passengers who contacted the assistance team established in Southern’s control centre as a result of the OBS not being available, and details of the alternative assistance provided. You informed us that in total over a period of four months, 48 passengers were affected, and that all of these were able to complete their journeys. The information provided is set out in the table below.
| Month | Trains fully covered | Passenger assistance affected | Actions taken | |-------|----------------------|------------------------------|---------------| | February | 96.5% | 6 booked 1 unbooked | • 3 taxis provided\
• 1 member of staff travelled with the passenger\
• 3 alternative train journeys arranged | | March | 96.3% | 2 booked 6 unbooked | • 2 taxis provided\
• 6 alternative train journeys arranged | | April | 97.5% | 5 booked 6 unbooked | • 4 staff members sent to platforms to assist passengers off train\
• 4 alternative train journeys arranged\
• 3 taxis provided | | May | 97.2% | 6 booked 16 unbooked | • 13 station staff assisted\
• 4 alternative train journeys arranged\
• 3 taxis provided\
• 2 on board supervisors(^2) assisted passengers (un-booked assistance) |
**Analysis of enhanced monitoring data**
The figures provided by GTR show that between 2.5% and 3.7% of services did not have an OBS available. That is significantly in excess of the initial estimate GTR provided us with of 0.06% of train services, which you had explained in a letter dated 8 November 2016 had been calculated using historic train performance relating to periods before the first RMT strike on 26 April 2016.
______________________________________________________________________
(^1) Note: ‘Fully covered’ means trains with a second member of staff from origin to destination.\
(^2) OBS’s working trains have also been asked to notify whenever they provide assistance that is not booked. This is logged and enables GTR to maintain a complete picture for monitoring and review. On 24 April 2017 (following provision of data by GTR) we sent an email to GTR noting that a significantly higher number of services had run without an OBS than the original estimate of 0.06%. We asked whether:
- The higher than anticipated figures had led GTR to make any changes to the processes you had in place to provide assistance to passengers when there is no OBS on board; and
- If changes had been made, for GTR to confirm what they were, and if not, to set out why no changes have been necessary.
You said industrial action in February, March and April 2017 had impacted on OBS coverage as you consider that disruption creates the highest risk of an OBS being unable to join their rostered service. You confirmed that in light of these actual, rather than estimated figures, you had not made changes to the assistance processes set out above. You advised that this is because of the relative impact on train services and the relatively low numbers of passengers using the help points or freephone number to request assistance.
In parallel, we also note that an email from GTR dated 25 April 2017 explained that it had come to light that the original 0.06% figure was an error and should have been stated at 0.6%. However, we note that despite the higher than estimated incidence of non-availability of an OBS, GTR appears to have established appropriate systems and processes to assist passengers.
You also provided details of your own specific monitoring and evaluation processes that include mystery shopping, call backs to customers and analysis of individual complaints. You detailed the changes to your operating practices made on the basis of this information. These changes included:
- The introduction of an OBS shift co-ordinator at the Southern control centre at Three Bridges to ensure robust OBS coverage, particularly during times of disruption;
- The briefing of staff on OBS handover procedures; and
- The review of agency staff training requirements to ensure that staff at key locations had completed ramp deployment training.
This demonstrates that there are feedback mechanisms in place to change processes in the light of feedback from passengers and operational experience in this area.
**Analysis of other data available to ORR**
We compared the evidence above provided by GTR to other data available to us via our core data monitoring in the areas of accessibility and complaints handling. This allowed us to set the context, compare GTR’s performance to the national average and cross-check to see if GTR was a significant outlier on any of the measures. This data is provided for GTR and is not available at the Southern brand level.
On accessibility, GTR as a whole (including Southern) received 44,615 booked assistance requests in 2016-17, which accounts for 3.7% of all booked assists made nationally. Therefore, the 19 passengers (19 of the 48) who had booked assistance that were impacted by non-availability of an OBS equates to 0.04% of all GTR’s booked assistance requests.
In respect of complaints data, in 2016-17, 1.2% of GTR’s complaints were about accessibility issues (1,119 in total), down from 1.5% the year before. When normalised by journeys this shows GTR received 0.3 complaints about accessibility per 100,000 passenger journeys in 2016-17, the same as the national rate. The total number of accessibility complaints increased this year. However, as GTR experienced an increase in all complaint types, the proportion of complaints about accessibility issues has fallen slightly, and when normalised by the volume of passenger journeys remains in line with the national rate.
Finally, we also considered if data from our new research (which became available over the summer) was consistent with these overall findings, which it is.
**Conclusion**
The period of enhanced monitoring ended in May 2017 with final data received by us at the end of June. Our review and analysis of the evidence and information available during that period and since - including the findings from our recent research into the passenger assistance services operated by each train operator - has satisfied us that there is no need to extend it. We consider GTR has provided assurance that it has systems and processes in place to deliver passenger assistance in the context of its workforce restructuring on some Southern routes.
Our engagement in this area has prompted GTR to consider in detail how to make changes and clarifications to its processes to ensure passengers with disabilities continue to be able to access its services. Of particular note in this context is the establishment of an accessibility team within the Southern control centre to deal with assistance requests and liaise with OBSs.
We also note that over the summer period of peak annual leave and including incidents disrupting normal service (which included 3 strike dates: 10 July and 1st and 4th September) 98.79% of Southern trains on relevant routes were fully covered by an OBS in July, 98.18% in August and 98.55% in September.
We continue to expect GTR, in common with all licence holders, to comply with its approved DPPP. In line with our published economic enforcement policy we will intervene should we identify serious or systemic failings in this area. We will continue to monitor assistance provision through our ‘business as usual’ monitoring as we do for Network Rail and all train operators, including via core data, complaints and our wide-ranging research programme.
We will shortly publish research into how the rail industry as a whole is delivering assistance to passengers including those that have pre-booked using the Passenger Assist reservation system as well as where that travel is spontaneous and not booked in advance. At the same time we will also publish a consultation paper to seek views on potential areas where there may be scope to deliver improvement for passengers. As part of that we will consider the lessons learned here and how these may be relevant to the services provided by other train operators.
If it would be helpful to discuss any of the above further at this time please do not hesitate to contact me.
Yours sincerely
Stephanie Tobyn
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7cb66acc64fc382cbc6bf972aac802b9054beea4 | Discipline policy
May 2018
Policy principles
All employees are responsible for ensuring their behaviour meets the standards expected of them. The Civil Service Code, our conduct policy and our values outline the key principles of behaviour expected from all employees.
Separate policies and procedures cover attendance, performance management and other capability issues.
All cases of misconduct should be dealt with promptly, transparently, fairly and consistently.
Everyone involved in the discipline process is expected to:
a) show respect for others b) work together to resolve the issue and c) Maintain confidentiality.
Scope of the policy
This policy and its related procedures apply to all employees, including those on probation and fixed term appointments.
Policy summary
Misconduct may have occurred where it is suspected or alleged that an employee has failed to meet acceptable standards of behaviour or conduct in any way. Where misconduct is proven, a range of penalties may be imposed, up to and including dismissal.
Key areas covered by this policy include:
a) initial assessment, including levels of seriousness of misconduct b) informal and formal action c) investigations and meetings d) Decision-making (including penalties). Discipline procedure
Contents
Contents ..................................................................................................................... 1 Process Overview ...................................................................................................... 2 Introduction ................................................................................................................ 3 Following the Procedure ............................................................................................. 3 Initial Assessment ...................................................................................................... 4 Deciding the level of seriousness of misconduct ......................................................... 4 Deciding whether to remove/suspend an employee .................................................... 4 Informal Action ........................................................................................................... 5 Formal Action ............................................................................................................. 5 Fast Track Process ..................................................................................................... 5 Investigations ............................................................................................................. 6 Informing and meeting with the employee ................................................................. 7 Deciding the outcome ................................................................................................. 7 Mitigation .................................................................................................................... 8 Deciding an appropriate penalty .................................................................................. 8 Informing the Employee of the Decision .................................................................... 9 Appeals ...................................................................................................................... 9 Employee’s actions ................................................................................................... 10 Appeal Manager's Actions ......................................................................................... 10 Record keeping ......................................................................................................... 10 Process overview – text version .............................................................................. 11 Process Overview
A text of this flowchart version is available on page 12
Note: An appeal is available to the employee after the formal stage is concluded. Introduction
1. This document sets out the procedure to use when it is suspected or alleged that any employee has failed to meet acceptable standards of behaviour or conduct in any way. It should be read with the Discipline policy.
2. This procedure must be followed to ensure the statutory code of practice laid down by the Advisory, Conciliation and Arbitration Service (ACAS) is adhered to.
3. The Discipline Advice contains tips and templates for use throughout the process, including a Decision Manager's checklist. Additional support is also available through the ‘Discipline Advice for Employees’ and the following ‘How to’ guides:
- Hold a formal discipline or grievance meeting
- Investigate discipline and grievance cases
- Assess the level of misconduct
- Decide a discipline penalty.
4. All actions in this procedure should normally be taken within the set times. However, it is recognised that this is not always possible due to the complexity of the case or circumstances such as working patterns, shift working, annual leave, public holidays and/or employee absence or disability, in which case all actions should be carried out as soon as reasonably possible. The reasons for any delay should be recorded.
5. If the employee requires any reasonable adjustments to enable them to attend meetings or read correspondence they should inform the manager accordingly. Managers will need to put these adjustments in place before taking action.
6. A summary of the procedure is in the flowchart: Process overview.
Following the Procedure
7. In simple terms, alleged or suspected misconduct involves managers making a series of decisions according to the individual circumstances of the case. The manager must:
| Decide the level of seriousness of misconduct | | Decide whether removal from the workplace/suspension is appropriate | | Decide whether matters can be dealt with informally or that formal action should proceed (including fast-track) | | Have the matter investigated or gather facts | | Inform the employee of the decision in writing and meet with the employee to discuss the allegations ensuring: |
- the right to be accompanied |
- the opportunity to put forward mitigation |
8. The Decision Manager must always be at least one grade higher than the employee concerned. In most cases the employee’s line manager will take on the role of Decision Manager.
**Initial Assessment**
9. There are two key initial decisions for the manager to make when misconduct is alleged or suspected: a) the likely level of seriousness b) Whether the action warrants removal or suspension.
**Deciding the level of seriousness of misconduct**
10. The manager should decide what the seriousness of the misconduct is likely to be: a) minor misconduct b) serious misconduct c) Gross misconduct.
11. Examples of each are given in ‘How to: Assess the level of the misconduct’.
12. As soon as the manager is clear about the likely level of misconduct, they should advise the employee of: a) the likely penalty if misconduct is proven and b) The investigation that needs to be carried out.
**Deciding whether to remove/suspend an employee**
13. In serious cases of misconduct, suspension may be appropriate whilst the alleged misconduct is investigated. Managers should not use suspension as a penalty. It should be made clear to the employee that the suspension is not disciplinary action and does not assume any guilt on behalf of the employee being suspended. The suspension period should be as brief as possible and kept under regular review by the manager.
14. As suspension is a serious decision, their HR Business Partner should be consulted before any suspension action is taken. Circumstances when suspension may be appropriate could include where:
- there has been a serious breakdown in the relationship between the employee and the department
- there is a risk to other employees, property or customers • There is a risk that the employee may tamper with evidence required for the investigation and/or influence witnesses.
15. Suspension may be appropriate immediately following an incident or later in the process; for example, at a point during or after the fact-gathering or investigation when evidence comes to light.
16. Suspension will normally be with full pay. However managers need to take HR and legal advice on each individual case where it is proposed to suspend without pay as this is likely to constitute a breach of contract.
17. Suspension should not be confused with management action to remove the employee from their current place of work; this removal may be required immediately following an incident in order to diffuse a conflict situation. An example of this type of management action might be instructing people to work in a separate area of the office or sending the employee(s) home for the rest of the day/shift to allow for a cooling-off period. The manager must be very clear with the employee that they are not being suspended and will be expected to return to work as normal the next working day/shift.
Informal Action
18. Instances where minor misconduct is identified may not require the manager to take formal action and the matter can be addressed quickly and informally through for example, a discussion about expectations and standards of behaviour or through counselling, training, coaching or mentoring.
19. However, managers should also advise employees that further misconduct may lead to formal action being taken in future. A record of all management action should be kept securely electronically and a copy given to the employee, and kept in line with the Records Retention Policy, after the matter has been concluded.
Formal Action
20. In certain instances of minor misconduct, or where informal action has not prevented further minor misconduct from taking place, it may be necessary for the manager to proceed to the formal process. In all cases of alleged serious or gross misconduct the formal procedure must be followed.
21. At this stage, the manager should decide whether using the fast-track process is appropriate.
22. When the formal process has started, the Decision Manager should inform their HR business Partner that the process is underway. If the disciplinary case is then not resolved after 40 working days it is advisable for the case to be reviewed by their HR business partner. The purpose of the review is to ensure that everything is being done to progress the case, that the correct process is being followed and that there are no unnecessary delays.
Fast Track Process
23. A fast-track process may be appropriate in straightforward cases where the facts of the case are not in dispute.
24. In these cases a lengthy investigation and interviewing of witnesses is not necessary but a simple fact-gathering exercise should take place, with only the following discipline procedure steps required:
a) A meeting with the manager who will take the role of Decision Manager, where evidence will be presented and the employee will have an opportunity to present their case and any mitigation. At this meeting the employee has the right to be accompanied by a trade union representative or work colleague
b) The Decision Manager will advise the employee of the decision and follow this up in writing, including an opportunity to appeal.
25. The fast track process can be stopped by the Decision Manager at any time if it is evident that the scope of the misconduct is broader than initially thought or that other employees may have been implicated in the alleged misconduct. The Decision Manager would then proceed to a full investigation.
**Investigations**
26. Some misconduct cases will need a formal investigation rather than just the simple fact-gathering that is suitable for the fast track process. This is likely to be the case where other parties must be involved, for instance security or fraud teams. The aim of the investigation is to collect the facts necessary to decide whether there is a case to answer or not. Managers may find the ‘How to investigate’ and ‘How to hold a formal meeting’ guides helpful.
27. Wherever practicable, different people should carry out the investigation and act as Decision Manager. Where the circumstances and complexity of the case are relatively straightforward and evidence is readily available, the manager may conduct the investigation. In such cases, the manager may exceptionally retain the role of the Decision Manager. The two processes must be kept separate and the manager should not make a decision until they have held the decision meeting. Where the case is more complex, for instance involving a bullying, harassment or discrimination claim, an independent Investigation Manager may be appointed. Advice should be sort from HR on this decision.
28. An independent Investigation Manager will:
a) not decide if a case is proven or whether a penalty should be imposed but
b) Compile a written report for the Decision Manager, indicating whether they believe there is a case to answer or not.
29. The Decision Manager should check the report is reasonable and meets the terms of reference for the investigation. If not, the Decision Manager should specify in writing what they have found unsatisfactory and request further information they believe is required.
30. Where a manager conducts an investigation themselves, they will need to decide whether there is a case to answer or not. Informing and meeting with the employee
31. If there is **no case to answer**, the Decision Manager must write to the employee to confirm the decision and that no meeting is necessary, enclosing a copy of the report and witness statements.
32. If there is **a case to answer**, the Decision Manager will need to take further formal action and should write to the employee who has been investigated within five working days of receiving the report, enclosing the report and witness statements, inviting them to a formal meeting to discuss the findings of the investigation.
33. The Decision Manager should: a) give the employee at least five working days’ notice of the meeting b) Tell the employee they have the right to be accompanied by a trade union representative or work colleague. If the employee or their companion cannot reasonably attend the meeting, the employee should propose several new dates to the manager to allow the meeting to take place within five working days of the original meeting date. If the employee fails to engage or cooperate with meeting arrangements and/or fails to attend the scheduled or re-scheduled meeting, consideration of the discipline case will go ahead in their absence based on the available information c) ask the employee if any specific requirements or adjustments need to be made to enable them to attend the meeting d) Enclose the investigation report.
34. The Decision Manager should then meet with the employee to hear the case, arranging for a note-taker to be present at the meeting.
35. If an investigation shows clearly that the Decision Manager is implicated in the original allegation of misconduct the case must be referred to the next senior manager in the Decision Manager’s management chain or to a suitable alternative manager, consulting your HR Business Partner as necessary.
Deciding the outcome
36. The Decision Manager must decide whether the alleged misconduct is: a) proven or b) Not proven.
37. The Decision Manager must notify the security and/or fraud team for any proven cases involving breaches of security, fraud or criminal matters. Where it is suspected that a criminal offence has been committed the advice of the security team should be sought in relation to notifying the police.
38. If someone is the victim of a criminal offence whilst at work (for example, they are assaulted by another employee at work or their personal belongings are stolen at work) then they have the right to contact the police, but should also inform the Associate Director of HR that this is what they intend to do as this may impact on any subsequent disciplinary action taken against an ORR employee as a result.
39. There is a distinction between major disciplinary offences that may be dealt with by ORR and those that may be criminal – if a case has been reported to the police as a criminal offence then ORR will apply this discipline policy if the alleged offender is an ORR employee, but will ensure that any internal investigation and subsequent action does not prejudice the outcome of any criminal proceedings.
40. You are required to inform HR if you are arrested or convicted of a criminal offence. Failure to do so will result in disciplinary action.
41. If the Decision Manager finds that a case of misconduct is not proven they must notify the employee and confirm that no further action will be taken. This should be confirmed in writing within five working days from the meeting. If suspended, the employee must return to work.
Mitigation
42. The Decision Manager should decide whether the case has been proven or not before taking mitigation into account.
43. If the case is proven, penalties should be decided after the individual has been given the opportunity to put forward any mitigating circumstances and providing evidence where available.
Deciding an appropriate penalty
44. Decision managers must ensure that penalties are appropriate to the level of seriousness of the offence, whether minor, serious or gross misconduct. The previous discipline record of the employee should be taken into account and consistency maintained with previous decisions wherever possible. Decision Managers may wish to consult HR on these issues.
45. Instances of minor misconduct do not necessarily merit a penalty.
46. Informal action is not a discipline penalty.
47. Penalties could be the following:
a) First written warning. Appropriate in some instances of minor misconduct, or when informal action has not stopped further instances of similar minor misconduct. Valid for a minimum of 12 months from notification.
b) Final written warning. Usually appropriate when another incident of minor misconduct occurs during the live period of a first written warning or when the misconduct is serious. Normally valid for a minimum of 12 months from notification, which could be extended exceptionally.
c) Dismissal. For gross misconduct or when another incident of misconduct occurs during the currency of a final written warning.
48. Alternatively the Decision manager is able to impose the following for any level of penalty depending on the level of seriousness of the offence;
• Removal of benefits, including flexitime and working remotely. • Restrictions on employment or additional management checks. • Downgrading. • Reduction in pay. • Issue another final formal warning which can be ‘live’ for up to 24 months. • Dismissal with or without notice. • Any other remedial action to correct the situation.
49. The decision manager must hold the correct level of authority to impose the appropriate penalty
a) First written warning: The manager b) Final written warning: A senior manager (grade C or above) in the employee’s management chain c) Dismissal: A senior manager (grade A or above) in the employee’s management chain
50. For repeated misconduct, penalties will normally follow in the above order, listed in paragraph 45. However the process is not sequential and, depending on the seriousness of the misconduct, a final written warning or dismissal may be an appropriate first penalty. The same type of offence may warrant a different penalty depending on its nature and impact; for instance, where an employee has failed to follow ORR procedure.
51. All penalties attract a right of appeal.
**Informing the Employee of the Decision**
52. The Decision Manager should normally make a decision within five working days of the meeting and immediately communicate this in writing to the employee.
**Appeals**
53. There is one right of appeal in this procedure. The employee must set out the grounds for appeal in writing and whether they are appealing against:
a) procedural errors and/or b) the decision c) If new information/evidence is available.
54. Appeals on discipline matters must be heard, where this is possible, by someone senior to the person making the decision being appealed. If this is not possible due to operational circumstances or for some other reason, the appeal for warnings, but not dismissals, may be heard by a manager at the same level as the Decision Manager. The Appeal Manager should be impartial and independent of the original case wherever possible. Employee’s actions
55. Employees have five working days, from the date of receipt of the decision in which to send their written appeal to the Appeal Manager. The employee must then provide the following within 10 days of the decision date:
a) make clear whether the appeal is against a procedural error and/or the decision b) Clearly state their desired outcome.
Appeal Manager’s Actions
56. The Appeal Manager will write to the employee, normally within five working days of receiving the appeal to confirm its receipt and to invite them to a meeting. They should write to the employee:
a) giving at least five working days’ notice of the meeting b) Confirming the right to be accompanied by a trade union representative or work colleague.
57. At the meeting, the Appeal Manager should examine the decision-making process and the penalty given and decide whether these were reasonable. They should not reconsider the case in detail.
58. If new evidence is made available the Appeal Manager should consider the impact this may have on the final decision.
59. Normally within five working days of the appeal meeting, the Appeal Manager should decide and inform the employee whether their appeal has been upheld or rejected. The Appeal Manager should consult with HR before notifying the employee of the decision on the appeal.
60. The Appeal Manager’s decision is final.
Record keeping
61. It is important that a written record is kept at all stages within the discipline process including any correspondence. Following conclusion of the process the Decision Manager should send electronic copies of the documents to HR. These will be kept on a confidential ORR discipline file, and will be stored separately from personal files, within the current document management system. The confidential ORR discipline file will be kept for 6 years after the end of the person's contract of employment with ORR.
62. Records must be marked official - Sensitive, kept securely and handled in line with ORR's record management policy. Please find more advice on the Information security pages and Record Retention Policy.
63. At all stages documentation should be managed in compliance with the requirements of the General Data Protection Regulation and Data Protection Act 2018. Process overview – text version
Step 1. Manager conducts initial fact-finding and decides likely level of misconduct [minor/serious/gross]
Step 2. Manager decides whether suspension appropriate
Step 3. Manager decides whether alleged misconduct can be dealt with informally
Yes: go to step 4
No: go to step 6
Step 4. Informal action
Step 5. The matter is concluded
Step 6. Manager decides whether alleged misconduct can be dealt with using fast track process
Yes: go to step 7
No: go to step 9
Step 7. Fast track process
Step 8. The matter is concluded
Step 9. Manager seeks appointment of independent Investigation Manager
Step 10. Investigation Manager investigates and decides if there is a case to answer
Step 11. Case to answer?
Yes: go to step 13
No: go to step 12
Step 12. The matter is concluded
Step 13. Manager holds formal meeting with employee
Step 14. Manager makes decision on case and if appropriate, applies penalty
Step 15. The matter is concluded
Note: An appeal is available to the employee after the formal stage is concluded How to investigate discipline and grievance cases
Introduction
1. It is in the best interests of all parties for matters to be fairly and fully investigated and resolved quickly. This guide aims to help managers and Investigating Managers to conduct an effective fact-finding exercise. It should be read in conjunction with the Discipline and Grievance Policy and Procedure.
Deciding who is the best person to investigate
2. The role of the Investigation Manager is to establish facts and gather evidence including witness statements, where appropriate.
3. Where it is not appropriate for a case to be dealt with using the fast track process, the line manager should seek the appointment of an independent Investigation Manager from their HR Business Partner. The independent Investigation Manager can be from the same line management chain but they will need to be impartial, and have no prior knowledge of the details of the case.
4. Points to consider when deciding if an independent Investigation Manager needs to be appointed:
- Has the bullying, harassment or discrimination complaint been sent directly to the HR team [If so, an independent Investigation Manager is likely to be needed].
- Is the manager somehow implicated in the circumstances of the case? If so, the manager should speak to their manager and/or contact HR team who could advise if an independent Investigation Manager should be appointed.
- Does the line manager have a personal interest in any particular outcome of the case?
- Is the manager aware of others being involved? If so, the manager may need to speak to another line manager and/or contact their HR Team who could advise if it may be better to appoint an independent Investigation Manager.
- Are there any relevant wider issues, such as related misconduct by another team member? If so, the manager may need to speak to another manager and/or contact HR who could advise if it may be better to appoint an independent Investigation Manager. Other points to consider
For discipline cases:
- Is the allegation of minor, serious or gross misconduct?
- Will witnesses need to be interviewed? If so, who?
- Did the line manager witness the misconduct? If not, who might need to be interviewed?
- Is the manager fully aware of the circumstances? If not, what would they like the investigation to clarify?
- Has an attempt been made to resolve this or similar misconduct before; either through formal or informal processes? If so, what was the outcome?
For grievances
- Has the same or similar grievances been raised before?
- Are there any other similar grievances raised at the moment?
- Does the grievance include any discrimination issues such as, for example, failure to provide reasonable adjustments?
5. During the course of the grievance investigation, it may become apparent that there is a discipline case to answer. If the grievance procedure investigation has established that there is a discipline case to answer, there is no need to start the discipline procedure investigation from the beginning. However, further investigation as part of the discipline procedure may be necessary.
If unsure about any of those points, the line manager may want to discuss with their countersigning manager or HR who will be able to advise.
How to investigate
6. The Investigation Manager will need to interview the employee concerned, appropriate witnesses (who are required to attend a meeting when called upon by an Investigation Manager) and obtain any other required evidence such as relevant correspondence.
7. The employee concerned has the right to be accompanied by a work colleague or a trade union representative. Witnesses have no right to be accompanied when giving statements but Investigation Managers will have discretion to decide when this would be appropriate, depending on the circumstances of each case.
8. The Investigation Manager should remind employees that:
- It is a formal investigation.
- Their statements will be recorded in writing and used in making a decision on whether there is a case to answer or not.
- They need to give a full and true account of the matter, which they will be asked to sign to confirm (although a signature is not required to proceed with the case). • What they say will help you to draw conclusions from the investigation.
9. You should complete a report which includes the following information:
• The original reason for conducting the investigation. • A record of all information obtained from the employee and witnesses. • An account of the facts and/or relevant information signed and dated by the person being interviewed and countersigned by the Investigation Manager. • Any doubts about the evidence obtained or credibility of statements. • If proposed witnesses were not deemed necessary or relevant, reasons for this decision. • A copy of all of the evidence, statements and relevant documents. • A fully reasoned decision as to whether or not there is a case to answer (for discipline cases).
10. It is important to remember that the investigation report is a formal document and may be used at an Employment Tribunal as evidence. The report should be comprehensive, accurate and be an objective and fair assessment. For consistency it might be helpful to use the model Investigation Manager note template.
Who will see the investigation report?
11. In grievance cases, the employee who raised the grievance will see the grievance investigation report, including witness statements, where appropriate. Companions will also see the report, as will those managers included in the investigation or disciplinary meeting.
12. However, if there is a further investigation under the discipline procedure, the employee who raised the original grievance will not be informed about any details of the process, will not see the discipline investigation report or know the decision - this is personal and confidential to the person undergoing the discipline process.
13. The employee who is the subject of the discipline procedure will see the discipline investigation report including the witness statements, where appropriate.
14. Employees and managers need to be aware that:
• any confidential information in the report (such as names, dates of birth and addresses) will be redacted. • sharing the report with any person other than those with a legitimate reason, such as for example companions, would be viewed as serious misconduct.
# Investigation Manager Note Template
| Note of investigation | |-----------------------| | Employee name: | | Grade/Competency: | | Role: | | Date investigation commenced: |
| Investigation Manager | |-----------------------| | Decision manager |
## SUMMARY OF INVESTIGATION
| Details of allegation/complaint | |---------------------------------| | Evidence considered | | Witnesses interviewed and questions answered or statements obtained |
## INVESTIGATION MEETING
| Meeting date | |--------------| | Start time/Finish time | | Note taker | | All others attending | | |----------------------|---| | Facts Discussed: | | | **DETAILS OF CONSIDERATION** | | | For discipline cases: Is there a case to answer? YES/NO | | | Investigation Manager's signature | | | Date: | | How to assess the level of the misconduct
Introduction
1. This ‘How To’ guide will help to steer managers through the early handling stages when deciding what level of action is appropriate to deal with a disciplinary matter. It should be read in conjunction with the Discipline Policy and Procedure.
2. Taking prompt and decisive action as soon as you become aware that a disciplinary matter needs addressing is in the best interests of ORR, the employee and where others are involved, the wider team.
3. Managers are reminded that not dealing with misconduct issues as soon as they occur, or you are made aware of them, is not acceptable in terms of your own performance as a manager and may imply an endorsement of unacceptable behaviour.
Assessing the appropriate level of action to take
4. It is important to be clear from the start what the likely level of action in cases of misconduct is to be. This will depend on a number of factors and individual circumstances and should not pre-empt the decision.
5. However you may find that, as an investigation proceeds, the level may change. You should then consider the case under the appropriate level.
6. Factors to consider when deciding the level of seriousness of misconduct: a) The degree of the misconduct (e.g. physical violence towards others will be considered gross misconduct) b) The impact on others c) Damage to property (value may be a factor in deciding whether the misconduct is minor or gross) d) Culpability e) Intent f) Breach of the Civil Service Code
7. You must be able to justify your decision for the course of action taken – whether or not the decision was reasonable in the given circumstances. If you are unsure about this, seek HR advice.
8. The following examples are intended to help you decide how best to deal with a case. It should be noted that examples listed are neither exhaustive nor mutually exclusive.
**Minor Misconduct**
9. Minor misconduct is defined as a minor breach of rules, for example:
a) Poor time keeping. b) Minor safety violations. c) Failure to follow departmental policy/procedure e.g. failure to follow a reasonable instruction. d) Minor misuse of departmental assets such as phone/email.
**Informal action**
10. Most cases of misconduct that are first offences and minor in nature, such as the ones listed above, are often best dealt with informally. An off the record discussion is often all that is required to improve an employee's behaviour. Managers should:
• talk to the employee about the situation and ask them to explain their actions • invite the employee to provide information about any relevant personal issues or health reasons that may have affected their behaviour • remind the employee about the Employee Assistance Service.
**Formal action**
11. However, some instances of minor misconduct should be dealt with formally from the outset and may warrant a first formal warning, for example:
• breaches of information security that are accidental, genuine errors where reasonable care was taken and where there is no criminal act; no known harm or distress caused and no reputational damage or cost to the department • minor breaches of the Civil Service Code such as inappropriate behaviour on social media sites or in public where the department may be identified.
**Serious Misconduct**
12. Serious misconduct will require formal management action, but is not of itself serious enough to amount to gross misconduct in the case of a first offence; for example:
• Repetition of minor misconduct which the employee has already been warned about either formally or informally. • Failure to follow departmental policy/procedure e.g. serious insubordination. • Serious misuse of departmental assets such as phone/email. • Serious breach of ORR’s IT acceptable use policy. • Certain instances of bringing the department into disrepute, e.g. being drunk and disorderly in a situation where your employer may be identified. • Unauthorised disclosure of official information such as press leaks (with low impact). • Smoking in buildings. • Failure to follow reasonable instructions. • Exceeding level of authority with negative impact on the business. • Offensive personal behaviour e.g. verbal abuse to colleague. • Failure to secure sensitively marked documents (with low impact). • Vexatious or malicious grievances.
**Gross Misconduct**
13. Gross misconduct is serious enough to destroy the working relationship between the employee and employer and its likely sanction is dismissal. The following are examples but this list is not exhaustive.
• Serious incapability whilst on duty brought on by alcohol or illegal drugs. Please refer to the ORR Health & Safety, Conduct and Capability Policy. • Significant or continued theft, corruption or fraud. • Physical violence or threatening behaviour including more serious cases of bullying, harassment and discrimination. • Significant breach of security. • Leaks of confidential information to the media or social networking sites. • Significant breach of health and safety rules. • Certain instances of bringing the department into disrepute e.g. posting defamatory statements about the department/colleagues/customers/ministers on social networking sites. • Unauthorised disclosure of official information such as press leaks (with high impact). • Failure to secure protectively marked documents (with high impact). • Falsification of records. • Gross negligence. • Insubordination resulting in significant impact – e.g. reputational damage. • Causing major loss, damage, or injury through serious negligence. • Deliberate and gross misuse or damage to departmental property. • Repeated or persistent failure to follow reasonable instructions. • Significant or repeated breach of the Civil Service Code. • Very offensive behaviour. How to hold a formal discipline or grievance meeting
Introduction
This guide is to help Decision Managers conduct meetings with employees. It explains the difference between informal and formal meetings and gives practical guidance on what to do. The guide can be used for both discipline and grievance matters, although some specific issues relating to each are identified.
The differences between informal and formal meetings
| Informal | Formal | |-------------------------------------------------------------------------|------------------------------------------------------------------------| | • It applies to minor misconduct or grievance matters. | • Must be organised for all serious and gross misconduct matters, normally including cases of repeated misconduct | | • It is part of day-to-day management action. | • Must be organised for all serious grievance matters, including cases of bullying, harassment and discrimination | | • An informal note must be kept by the manager. | • Does not need to be preceded by informal action. | | • Does not allow the employee the right to be accompanied. | • It is fully documented and is formally recorded by a note taker. | | • Outcomes must be communicated to the employee, in writing but informally i.e. by email rather than a formal letter. | • Allows the employee the right to be accompanied by a colleague or trade union representative. | | | • Employee always informed in writing about the outcome. |
## Formal meetings (including appeal meetings)
### Before the meeting: preparation
| Step 1 | Write to the employee using **Model Letter 3** from *Section 2 in Discipline Advice*.\
Attach a copy of the Investigation Report, ensuring that any confidential information (such as names, dates of birth and addresses) has been redacted.\
Note: You should make it clear in writing to the employee that sharing the report with any person other than those with a legitimate reason would be viewed as serious misconduct.\
Clarify that the attendance of any witnesses should be agreed with you in advance and will only be accepted in exceptional circumstances i.e. where it is relevant for fair consideration of all evidence. | |---|---| | Step 2 | Arrange for a note-taker to attend the meeting (who should be reminded of the need for confidentiality). | | Step 3 | Ask the employee if they require any reasonable adjustments to enable them to attend the meeting and/or read correspondence; and inform them of their right to be accompanied.\
Note: If the employee or their companion cannot attend, the employee will need to suggest another date within a further five working days, on which they are both available. | | Step 4 | Make sure you have all of the statements, evidence and facts ahead of the meeting. This should also include:
- relevant personal information
- the employee’s discipline or grievance record including current warnings. You may need to contact HR to access this.
- other relevant documents. | | Step 5 | Consider the structure of the meeting and what kind of questions you will need to ask. Avoid using closed questions requiring a Yes or No answer unless this will help you get specific information you need. |
### At the meeting: conducting the meeting
| Step 1 | Introduce all present and explain that the meeting is to discuss a discipline/grievance matter and will be conducted with a written record being kept. Explain that the meeting will be used to establish the facts of the case and determine if any further action will be taken. Inform everybody when a | A decision is likely to be given - the same day after the adjournment or within the five working days from the meeting.
Remind every one of the need to respect confidentiality and that any breaches of confidentiality could result in disciplinary action.
| Step 2 | Explain the alleged misconduct/grievance, cover the relevant evidence and summarise the Investigation Report. | |--------|----------------------------------------------------------------------------------------------------------| | Step 3 | a) Allow the employee to ask questions and present evidence;\
| | b) Establish facts wherever possible;\
| | c) Clarify points to ensure everything is understood;\
| | d) Use open questions to encourage more information;\
| | e) Use precise, closed questions where specific information is needed;\
| | f) Avoid leading questions, e.g. Were you provoked?\
| | g) For discipline cases:\
| | h) Establish whether the member of staff accepts that they have done something wrong or not;\
| | i) Ask if there is any factual explanation for the alleged misconduct. | | Step 4 | At any point during the meeting an adjournment can be requested. If doing so, go to a separate room from the employee and their companion. Meetings should normally reconvene on the same day where possible.\
| | Reasons to adjourn may include (this is not exhaustive):\
| | a) the employee would like to consult with their companion\
| | b) the employee is distressed and cannot continue\
| | c) for comfort breaks\
| | d) in exceptional circumstances, you deem further enquiries are necessary (normally it will be better in such cases to adjourn at the end of the meeting with a continuation at a later date). | | Step 6 | After the questioning and discussion\
| | a) summarise the main points of the case;\
| | b) allow the employee to say anything else they would like to add;\
| | c) inform the employee when you will make your decision; and\
| | d) make sure that you have all the relevant facts and information before you adjourn. | After the meeting: making a decision and informing the employee
### Discipline Appeal Meetings
#### Before the appeal meeting: Preparation
| Step 1 | Adjourn the meeting to allow consideration before making a decision. Although it is important to let the employee know of your decision as soon as possible, it is also important to take time to consider your decision. Writing down your reasons and justifying the decision will help to make sure your decision is the correct one. Note: Even in a case with a clear outcome, where adjournment is not required to make a decision, you should adjourn for a period to ensure proper consideration has been given. When reaching a decision in discipline cases, if the decision is that the employee is guilty, you must hold a genuine belief on reasonable grounds that the employee has committed misconduct. You will need to be satisfied, having considered all the evidence that the misconduct has occurred. You should give full consideration to the employee’s answers to your questions and any mitigation. | |---|---| | Step 2 | Inform the employee of the decision (where this is possible) and/or confirm when the employee can expect to receive the decision in writing (usually within five working days) enclosing the notes of the meeting using the appropriate letter from Model Letters 4-7 from Discipline Advice. The decision letter will include: a) a note of the meeting b) the decision taken c) Information about the right to appeal and where to send it. |
### Discipline Appeal Meetings
#### Before the appeal meeting: Preparation
| Step 1 | Write to the employee using Model Letter 10 from Section 2 of the Discipline Advice. You should also: check that you have all relevant documentation read the grounds for appeal carefully review the investigation report obtain and carefully review notes of the disciplinary/grievance meeting and the decision letter and the reasons given for the decision consider whether the procedure has been properly followed | | Step 2 | Arrange for a note-taker to attend the meeting (who should be reminded of the need for confidentiality). | |--------|--------------------------------------------------------------------------------------------------| | Step 3 | Ask the employee if they require any reasonable adjustments to enable them to attend the meeting and/or read correspondence; and inform them of their right to be accompanied.\
If the employee or their companion cannot attend, the employee will need to suggest another date within a further five working days, on which they are both available. | | Step 4 | Consider the structure of the meeting and what kind of questions you will need to ask. Avoid using closed questions requiring a Yes or No answer, unless this will help you to get the specific information you need. |
### At the appeal meeting: conducting the meeting
| Step 1 | Introduce all present and explain that the purpose of the appeal meeting is to examine the decision-making process and the penalty given/proposed solution, depending on whether it is a discipline or grievance case appeal. Explain that the purpose of the meeting is not to re-consider the case in detail.\
Explain that you will inform the employee about your decision in writing, within five working days from the meeting. Make it clear that your decision is final and that there is no further right of appeal.\
Remind everyone of the need to respect confidentiality and that any breaches of confidentiality could result in disciplinary action. | |--------|--------------------------------------------------------------------------------------------------| | Step 2 | Summarise the reasons for the appeal. | | Step 3 | During the meeting:\
• ask the employee to explain their appeal\
• ask for clarification on any points that are unclear\
• highlight any new evidence which has come to light as a result of the appeal\
• explore the issues\
• ask the employee if they have anything they wish to say, including any mitigation they want you to take into account. | | Step 4 | At the end of the meeting:\
• explain that you will make a decision based on all the available After the Appeal meeting: making a decision and informing the employee
| Step 1 | Although it is important to let the employee know of your decision as soon as possible, it is also important to take time to consider your decision. Writing down your reasons and justifying the decision will help to make sure your decision is the correct one. You may need to seek HR advice, if you feel you need help with the process or decision-making. | | Step 2 | Inform the employee of the decision whenever possible within five working days from the appeal meeting, enclosing the notes of the meeting using the appropriate letter: Model Letter 11 from Discipline Advice. The decision letter will include your decision and the reasons for it. |
Conduct of employees and their representatives at formal meetings
1. At the start of the meeting you should remind everyone of the need to maintain confidentiality and it should be made clear that unauthorised disclosure of information is likely to be regarded as serious misconduct.
2. Employees need to ensure that they behave in the way that is expected of them. Employees have the right to invite a trade union representative or work colleague to attend meetings with them but not to be otherwise represented, e.g. by a friend, relative or legal representative.
3. When invited by an employee, colleagues and trade union representatives may fully participate in meetings, provided they do not answer the manager's questions on behalf of the employee.
4. Witnesses will not normally attend discipline or grievance meetings but managers will have discretion to decide if this would be appropriate, depending on the circumstances of each case.
5. Where the conduct of any participants in the meeting is disruptive or inappropriate you should adjourn the meeting and reconvene after a reasonable interval.
6. The Employee has a right to appeal against this decision as long as they do so in writing within 10 working days. Any appeal should be addressed to the appeal manager. A copy of the meeting notes should be enclosed as part of the decision letter for misconduct. If the employee has any comments on these notes they must provide these to the Appeal Manager in writing, together with the appeal. If there is no response from the employee within 10 days the record will be taken to be agreed.
How to deal with an employee’s failure to attend a meeting
7. Employees are required to attend the meeting that they are invited to and should take all reasonable steps to attend the meeting. If an employee fails to attend a meeting:
- You should consider the reasonableness of the circumstances for the employee failing to attend the meeting;
- Other than in exceptional circumstances, for example, a genuine emergency, only one rearrangement should be granted. This should be within 5 working days of the time originally proposed. The employee should propose new dates based on their own and their companion’s availability.
- Where there is a second failure to attend a meeting, a decision can be made on the available evidence in the absence of the employee, and the employee informed of the decision in writing.
- This will apply equally where the employee’s companion is unable to attend a meeting and the employee decides not to attend on their own. Discipline Frequently Asked Questions
Q1. How will cases be monitored to ensure that they are resolved as soon as possible?
It is advisable that each case is reviewed by a senior manager if it is not resolved after 40 working days. This is to ensure that everything is being done to progress the case, the correct process is being followed and that there are no unnecessary delays. To ensure that this review is carried out within the prescribed timeframe, managers should inform HR as soon as they start the formal discipline process.
Q2. What happens if the manager handling the discipline case unexpectedly becomes absent from/leaves work?
Short absences are part of the everyday working environment. If the absence becomes long-term or is permanent, the countersigning manager may arrange for another manager to take over handling the discipline case.
Q3. How should managers treat other personal issues?
Managers should consider any known temporary or permanent outside factors, such as personal issues that may have affected the employee and which the employee is prepared to share. Managers should remind the employee about available support such as Employee Assistance service (EAS).
Q4. Who can be an Independent Investigation Manager?
The independent Investigation Manager can be from the same line management chain but they will need to be impartial, and have no prior knowledge of the details of the case, or have any personal interest in the outcome. The Investigation Manager should act impartially and independently throughout the investigation. However in circumstances where impartiality is not possible then a manager outside of the management chain should be the Investigation Manager.
Q5. In what circumstances is it appropriate to use the fast track process and how should it be conducted?
A fast track process may be appropriate in straightforward cases where the evidence is readily available and the facts of the case are not likely to be in dispute, for example in cases where:
- a number of people have witnessed alleged misconduct, so accounts of events are likely to be similar • facts are easily documented, for example unacceptable behaviour that is recorded in writing such as abusive emails or flexi-time abuse.
Line managers will conduct fact gathering, compile the evidence and consider the facts of the case.
It is not appropriate to use the fast track process where:
• the manager could be reasonably perceived to be somehow implicated in the original decision or the circumstances of the case • the manager could be reasonably perceived as having a personal interest in any particular outcome of the case or being biased • other parties, such as customers, are involved in the discipline case • other internal parties are involved in the discipline case, such as security or fraud teams • there is an allegation of bullying, harassment or discrimination • the allegation involves media interest and could negatively impact on the department’s reputation.
In such cases the manager should seek the appointment of an independent Investigation Manager.
The fast track process may be appropriate to use in most cases of minor misconduct and some cases of serious misconduct. It should not be used where there is alleged gross misconduct which may result in dismissal.
Q6. What happens if the manager dealing with the case moves to another job during the discipline process?
Wherever possible, the process will continue with the manager who started it as they know the facts of the case best.
If this is not possible, the manager must ensure a thorough handover of the case to the new manager, including all notes and other relevant documentation. Once the handover is complete, the new manager should arrange to meet with the employee quickly to make sure that the discipline process is not disrupted.
If the new manager is not in place at the time, the employee’s countersigning manager may appoint somebody else to take over the case.
Q7. How do managers ensure employees receive important written communications?
Managers are advised to retain proof that written communications have been sent to, and where appropriate, received by, the employee. Email communications often provide this facility as standard. In the case of communications by post, the use of mail tracking services is recommended. Q8. How do managers treat unlawful behaviour outside the workplace?
The employee must inform their line manager if they are arrested and refused bail or convicted of any criminal offence. If the offence committed relates specifically to the Civil Service Code, ORR Values or the Equality and Diversity policy, the line manager will need to consider formal discipline action.
The following should be considered:
- the bearing on the employee's suitability to continue to undertake their job in the Civil Service or their relationship with their colleagues, the department or customers; not whether they are guilty under criminal law
- whether the conduct is serious enough to warrant disciplinary action
- that a decision will be made on the evidence available if the employee is unable or refuses to cooperate with the investigation, in cases where the discipline procedure has been instigated an employee who is required to drive as part of their duties are convicted by the police for a driving offence, it is likely that the misconduct will be considered as serious, due to the impact on their role.
- where an employee is detained or imprisoned, managers may wish to consider whether in the light of the needs of the department, continuation of employment is possible and/or appropriate
- Where the employee is unable to continue in their current role, for example due to the loss of a driving licence, whether an alternative role is available and/or appropriate.
Managers may consult HR for advice, for instance to establish whether the detention has resulted in a breach of the employment contract. Legal advice should be sought on individual cases.
Q9. What about inappropriate behaviour outside the workplace?
If behaviour, including misuse of social media, is likely to bring ORR into disrepute, then it can be considered as a potential act of gross misconduct. An example might be employees seen to be ridiculing customers of the ORR.
Q10. What are the implications for cases involving security breaches, fraud or criminal matters?
Any alleged misconduct involving breaches of security, loss or other compromise (including ‘leaks’) of official and/or personal information or criminal matters should be reported immediately to the ORRs security team. Fraud, corruption and irregularity should be reported to the Information Manager, in Corporate Operations.
An internal security investigation may need to be completed before the misconduct process can be implemented in order to establish the full circumstances. Under these circumstances, it is possible that the security investigation report will inform the misconduct process. In such cases, it may not always be necessary to carry out a further investigation.
Q11. How do managers deal with repeated or persistent misconduct?
Repeated or persistent misconduct may result in a higher penalty than that given before e.g. what merited a first warning is likely to merit a final warning if repeated. However, where the repeated or persistent misconduct is of a minor nature Decision Managers should be careful when considering dismissal and seek HR advice.
Q12. What if an employee is on loan or secondment?
Employees on loan or secondment will normally be dealt with under ORR Discipline policy. However, it is important to check the loan/secondment agreement as other arrangements may apply.
Q13. What happens if an employee resigns before the disciplinary process is concluded?
Where an employee resigns during the course of a disciplinary process, the process should be continued to conclusion while the employee is serving their notice. The Decision Manager should hold the decision meeting, make the decision and send copies of the documents to HR to be placed on the employee’s personal HR file. The record will state that the employee resigned but the disciplinary decision will be recorded for future reference.
If the process cannot be concluded before the employee’s departure, the employee will be informed that the process will continue in their absence and invited to attend the disciplinary meetings, if they wish.
If there is enough evidence to conclude the process in the employee’s absence, it should be concluded in a normal way, as described above. If a disciplinary penalty is imposed, it will be recorded on the employee’s personal HR file for reference and they will be notified in writing, including their right to appeal.
If there isn’t enough evidence to conclude the process, the process will be stopped due to lack of evidence. This should be recorded by the Decision Manager and the appropriate information put on the employee’s personal HR file explaining that they were subject to a discipline process which could not be concluded due to the lack of evidence, owing to the employee’s departure.
Q14. How are investigations carried out by external consultants to be managed?
In some cases an external consultant may be asked to conduct an investigation. Any such investigation will be overseen by representatives of line management and follow ORR procedure.
Q15. How can shift worker’s attendance at meetings be managed?
Where the working patterns of the parties involved in a discipline meeting make it difficult to hold the meeting during standard working hours, arrangements should be made with management to facilitate the individual's attendance.
Q16. What happens if the employee becomes absent from work?
If for example a person is unfit to attend work this does not necessarily mean that the discipline case cannot progress. This will depend on the nature of the employee's absence. An Occupational Health Service (OHS) referral may be of benefit; but, where the OHS report proves difficult to obtain, managers should consider other ways to progress the discipline case, for example communicating by telephone, meeting at a neutral place or location near the employee's home, or inviting the employee to submit a written statement. However, wherever possible and appropriate, cases should be progressed and resolved quickly. It would normally not be necessary to wait for the OHS report. The manager should speak to HR if a referral is required. Where either a disability or long term health condition is a factor, managers should allow for reasonable adjustments to be put in place, and to take effect, before reassessing the position.
**Q17. What happens when an employee is suspended?**
Suspended employees may need to be escorted from the premises and asked to surrender security passes or any other means of entry to official property. It is important to remember however that suspension is not a penalty. In most cases suspension will be with full pay.
Suspended employees must ensure they are contactable during normal working hours and will be required to attend meetings and interviews which are part of the discipline process. They must respond to any reasonable management instruction and follow normal attendance/sick procedures if unfit to attend work. They must also seek line manager permission before taking any annual leave.
Employees are reminded of the availability of the Employee Assistance Service (EAS).
**Q18. Who can accompany an employee to a formal meeting?**
Employees have a statutory right to be accompanied by a companion where the discipline meeting could result in disciplinary action. A chosen companion may be a work colleague, a trade union representative or an official employed by a trade union. A trade union representative who is not an employed official must have been certified by their trade union as being competent to accompany an employee.
The companion cannot be a friend or relative unless they are also a colleague. Neither can they be a legal representative.
If there is a reasonable adjustment in place that includes the employee being supported in meetings, this must be extended to discipline meetings.
To exercise the statutory right to be accompanied employees must make a reasonable request. It would not normally be reasonable for an employee to insist on being accompanied by a companion whose presence would prejudice the discipline meeting.
**Q19. What is the companion’s role?**
The companion is allowed to:
a) put forward and sum up the employee’s case
b) respond on behalf of the employee to any views expressed at the meeting
c) confer with the employee.
The companion does not have a right to:
a) answer questions posed by management on the employee’s behalf
b) address the meeting if the employee does not wish it c) prevent the employee from explaining their case.
Q20. What are the responsibilities of a witness?
A witness is responsible for:
a) maintaining confidentiality b) providing truthful and comprehensive statements and answers c) attending meetings with the manager conducting the investigation d) volunteering information which they feel may be relevant to the investigation e) reporting any attempts to influence their statement to the manager conducting the investigation f) informing their line manager of their role and possible impact on work and/or attendance.
Q21. Can the identity of a witness be withheld?
In the interests of fairness it is important that witnesses identify themselves. However, in exceptional circumstances the identities of individuals can be withheld; for instance, where there is a genuine fear of serious risk to personal safety.
The fact that a member of staff making an allegation, or a witness, simply does not wish to be identified will not be sufficient cause to withhold identity.
Even where it is agreed that identity can be withheld it is not possible to guarantee anonymity should the case progress to Employment Tribunal.
Q22. Who will be able to see a witness statement?
A witness statement will be attached to the investigation report and will be provided to the employee who is the subject of the discipline procedure. This is to ensure openness and transparency in the investigation process. Companions will also see the report, as will those managers included in the investigation or disciplinary meeting.
Q23. Can witnesses attend the discipline meeting?
Witnesses would not normally attend discipline meetings.
Q24. Do witnesses have the right to be accompanied at the discipline meeting?
There is no right for witnesses to be accompanied when giving statements. However, managers will have the discretion to decide when this would be appropriate based on the merits of the case. It is important to consider all relevant evidence.
Q25. If a witness feels intimidated what can they do?
The witness should speak to the Investigation Manager. Any attempt to intimidate or interfere with witnesses to an investigation will normally be regarded as serious misconduct, whoever the alleged perpetrator is. If any report of this is made to the Investigation Manager during the course of an investigation they will inform the line manager of the allegations immediately.
Q26. What if an employee is serving overseas?
All employees based overseas will ultimately be under the authority of the Head of Post at the Mission in which they serve. The ORR reserves the right to withdraw any employee if it has reasonable grounds for considering that the employee and/or any member of their family assigned with them is putting the security, efficiency or reputation of the Post at risk.
Q27. Can an employee facing a discipline procedure seek advice from the Employee Assistance Service?
Yes, if stress or anxiety is affecting them during the process, they may contact the Employee Assistance Service.
Q28. What happens if the discipline procedure is started as a result of a grievance raised against another employee or manager? Who gets to see the investigation report including witness statements?
If the grievance procedure investigation has established that there is a discipline case to answer, there is no need to start the discipline procedure investigation from the beginning. However, further investigation as part of the discipline procedure may be necessary.
The employee who raised the grievance will see the grievance investigation report, including witness statements, where appropriate. Companions will also see the report, as will those managers included in the investigation or disciplinary meeting.
However, if there is a further investigation under the discipline procedure, the employee who raised the original grievance will not be informed about any details of the process, will not see the discipline investigation report or know the decision - this is personal and confidential to the person undergoing the discipline process.
The employee who is the subject of the discipline procedure will see the discipline investigation report including the witness statements, where appropriate.
Employees and managers need to be aware that:
- any confidential information in the report (such as names, dates of birth and addresses) will be redacted.
- sharing the report with any person other than those with a legitimate reason, such as for example companions, would be viewed as serious misconduct.
Q29. How should cases involving disciplinary allegations against an employee who is a trade union representative be treated?
Where disciplinary action is being considered against an employee who is a trade union representative the normal disciplinary procedure should be followed. Depending on the circumstances, however, it is advisable to discuss the matter at an early stage with an official employed by the union, after obtaining the employee’s agreement. Q30. How can I be certain about the effective date of termination when dismissing an employee for gross or repeated serious misconduct?
A dismissal is effective only when communicated to the employee. To be certain that the employee is aware of the dismissal; the manager can inform them face to face that they have been dismissed. But there are occasions when this will not be possible and when the dismissal will be communicated in writing. In these cases the effective date of termination is the date the employee reads the letter or has a reasonable opportunity of reading it. It is not the date the decision was made or the letter was written, posted or delivered. However, the employee can reasonably be expected to be available to receive communications following the disciplinary meeting and should not deliberately avoid reading the letter.
Whilst it is reasonable to expect a letter to be read upon receipt there are instances when this will not happen, for example if the employee is on holiday or in hospital. If dismissing by letter with or without notice managers should do the following:
- Check and record in writing, at the disciplinary meeting, whether the employee has planned holiday or other absence in the foreseeable future.
- Confirm the employee's availability to receive the decision in writing by post.
- Discuss with the employee any alternative arrangements that need to be made so they can communicate the decision as soon as possible.
- Arrange for the dismissal letter to be hand delivered where practicable, preferably requiring the employee's signed acceptance of receipt.
- Telephone or email the employee to check that the letter has been received. Decision Manager’s checklist
Use the following checklist to help you follow the discipline process properly.
You should:
☐ Identify the level of misconduct and decide whether to take informal or formal action and consider if suspension would be appropriate
☐ If taking formal action, decide if fast track is appropriate
☐ Notify the employee accordingly (Model letter 1)
☐ If using the fast track, gather the necessary facts yourself
☐ If not using the fast track, arrange for an independent Investigation Manager to carry out investigation
☐ Consider the investigation report carefully, including associated documents such as witness statements
☐ Decide whether there is a case to answer and notify the employee?
☐ Invite the employee to a meeting and notify them of their right to be accompanied (Model letter 4)
☐ Ensure somebody is assigned to take notes at the meeting and that the employee investigated is notified of their presence
☐ Give the employee the opportunity to present their case and put forward mitigation for consideration, including evidence
☐ Advise the employee of your decision in writing and notify them of their right of appeal (Model letters 5-9)
And after the process, you should:
☐ Keep a record of all papers in line with principles Model Letter 1 - Informing employee about investigation on their alleged misconduct
Official – Sensitive
Date
[Name and location of employee]
Dear
Investigation
I am writing to advise you that [name of Investigation Manager] has been appointed to investigate (or I am investigating\*) [insert full details of the alleged incident to be investigated including severity of conduct i.e. minor, serious, gross].
The purpose of the investigation is to gather and present evidence. The investigation report will show whether, on the balance of probability, there is a case to answer.
Relevant witnesses will normally be interviewed and statements obtained where appropriate. If there are a large number of witnesses, it will be for the Investigation Manager (or \*I) to decide which witnesses to interview.
[Name of Investigation Manager] (or I\*) will be in touch with you shortly to arrange a date when they (or I\*) can interview you (at which you will have a right to be accompanied by a work companion or trade union representative). If you would like to name any witness to [name of the Investigation Manager] (or me\*) at this meeting please do so.
Any information that emerges from this investigation might be used in any misconduct proceedings against you. If it is decided to instigate discipline action, the procedures outlined in the discipline policy will be followed. The Investigation Manager’s (or my\*) report and any other information used in determining whether to proceed with misconduct/discipline action, will be made available to you.
Yours sincerely
Decision Manager Model Letter 2 – Meeting invite to witness / person making allegation
Official – Sensitive
Date
[Name and location of employee]
Dear
Investigation meeting invite
I am writing to advise you that I have been appointed to investigate (or I am investigating\*) [the alleged incident to be investigated].
You have been named as a witness / \*you have made the allegation against [the person being investigated]. I would like to interview you so that I can find out what you think happened. Your cooperation in this matter would help my inquiries and investigation report. The meeting will take place on [date and time] at [location].
Please let me know as soon as possible or at least three working days prior to the meeting, if you require any special arrangements or if you need any particular accommodation requirements to enable you to attend the meeting.
If you cannot reasonably attend the meeting, you should propose a new date to allow the meeting to take place within five working days of the original meeting date.
Any information that comes to light during my investigation might be used in misconduct/discipline proceedings. The record of our meeting, which will form part of my overall investigation report, will be made available to [name(s) of person(s) under investigation].
This investigation is confidential and should not be discussed with anyone unless it is necessary to do so in connection with the discipline procedure (e.g. you can tell your line manager you are being interviewed).
Yours sincerely
Investigation Manager Model Letter 3 - Meeting invitation to person being investigated
Official - Sensitive
Date
[Name and location of employee]
Dear
Investigation meeting invitation
I am writing to advise you that I have been appointed to investigate [the alleged incident to be investigated].
It has been alleged that you [the alleged incident to be investigated] and I should like to interview you so that I can find out what happened. Your co-operation in this matter will greatly assist my inquiries and will inform my investigation report. The meeting will take place on [date and time] at [location].
You have the right to be accompanied by a trade union representative or work colleague. If you or your companion cannot reasonably attend the meeting, you should propose a new date to allow the meeting to take place within five working days of the original meeting date. If you do not do this, or fail to attend the re-arranged meeting, consideration of the [discipline/\*misconduct case] will go ahead in your absence based on the available information.
Please let me know as soon as possible, or at least three working days prior to the meeting, if you or your companion require any special arrangements or if you need any particular accommodation requirements to enable you to attend or participate in the meeting.
If you or your companion cannot reasonably attend the meeting, you should propose a new date to allow the meeting to take place within five working days of the original meeting date.
It is essential that you do not discuss this matter with anyone other than your trade union representative or accompanying work colleague.
The record of my meeting with you, which will form part of my overall investigation report, will be made available to you.
Yours sincerely
Investigation Manager Model Letter 4 - Decision meeting invite
Official – Sensitive
Date
[Name and location of employee]
Dear
Discipline decision meeting
I am writing to inform you that you are required to attend a formal meeting under the ORR Discipline procedure.
The formal meeting will consider the allegation/s that you [describe conduct that fell short of expected behaviour] when you [describe incident and date/s].
(If appropriate\*) The report of [insert name of Investigation Manager]'s investigation into your alleged [insert details of incident] which took place on [insert date/s] has been sent to me to consider whether misconduct/discipline action should be taken. I enclose a copy of this report which may only be shared with your designated companion. Sharing it with other individuals may be viewed as serious misconduct.
At the end of the meeting I will decide what further action to take. The allegations concerning [insert details of behaviour] may result in [insert penalty/penalties being considered], OR As you are presently under [insert existing penalty] the meeting may result in [insert penalty/penalties being considered\*].
For gross misconduct or where dismissal is a possibility:
I must make you aware that the allegations concerning [insert details of behaviour] represent gross misconduct offences. The meeting may therefore result in your dismissal without notice or payment in lieu of notice. Or, as you are presently under a final written warning for misconduct the meeting may result in your dismissal. For all letters: The meeting is on [date] at [time] at [location]. [Note: always give at least five working days’ notice]. Also attending will be [Insert if note-taker to be present, giving name if known]. He/she will record our discussion.
You have the right to be accompanied by a trade union representative or work colleague. If you or your companion cannot reasonably attend the meeting, you should propose a new date to allow the meeting to take place within five working days of the original meeting date. If you do not do this, or fail to attend the re-arranged meeting, consideration of the [discipline/\*misconduct case] will go ahead in your absence based on the available information.
Please let me know as soon as possible or at least three working days prior to the meeting, if you or your companion requires any special arrangements or if you need any particular accommodation requirements to enable you to attend the meeting.
Witnesses would not normally attend discipline meetings. However, I may consider allowing them to attend if necessary. Please inform me as soon as possible or at least three working days prior to the meeting of any witnesses you wish to call. The number of witnesses should be kept to a minimum and I will have then have to decide the final number and relevance of requested witnesses and their attendance.
Yours sincerely
Decision Manager Model Letter 5 - First written warning for misconduct
Official – Sensitive
Date
[Name and location of employee]
Dear
First written warning
I am writing to confirm the outcome of your meeting with me on [insert date] to discuss the misconduct case brought against you.
We discussed your alleged behaviour [details of misconduct] during the meeting and you claimed that [insert details of employee's response].
I have carefully considered all the circumstances including (the results of the investigation) and/or your representations.
Either:
In view of your acceptance that you [insert details of misconduct]
Or: The investigation has concluded that you [insert details of misconduct]
I find the misconduct case substantiated and therefore issue you with a first written warning. This warning will remain live on your file for 12 calendar months from this letter's date; that is until [insert date]. Should you commit another act of misconduct within this time, you may receive a final written warning, or if gross misconduct, save in exceptional circumstances, you may be dismissed without notice and without pay in lieu of notice. It is therefore very important that you improve your standard of conduct and behaviour to that expected of all staff and act professionally at all times.
You have a right to appeal against this decision as long as you do so in writing within 10 working days. Any appeal should be addressed to [Insert name of the Appeal Manager].
A copy of the meeting notes is enclosed. If you have any comments on these notes please provide them to the Appeal Manager [insert name] in writing, together with your appeal. If they have not heard from you by [insert date] the record will be taken to be agreed.
Yours sincerely
Decision Manager
Enc: Notes of meeting Model Letter 6 - Final written warning for misconduct/serious misconduct
Official – Sensitive
Date
[Name and location of employee]
Dear
Final written warning
I am writing to confirm the outcome of your meeting with me on [insert date] to discuss the (serious) misconduct case brought against you.
We discussed your alleged behaviour [details of misconduct] during the meeting and you claimed that [insert details of employee's response].
I have carefully considered all the circumstances including (the results of the investigation) and/or your representations.
Either: In view of your acceptance that you [insert details of misconduct]
Or: The investigation has confirmed that you [insert details of misconduct]
I find the misconduct case substantiated and therefore issue you with a final written warning. This warning will remain live on your file for [12 months or, exceptionally up to a maximum of 24 months] from this letter's date; that is until [insert date]. Should you commit another act of misconduct within this time, you are likely to be dismissed, or if gross misconduct, save in exceptional circumstances, you will be dismissed without notice and without pay in lieu of notice. It is therefore very important that you improve your standard of conduct and behaviour to that expected of all staff and act professionally at all times.
You have a right to appeal against this decision as long as you do so in writing within 10 working days. Any appeal should be addressed to [insert name of the Appeal Manager].
A copy of the meeting notes is enclosed. If you have any comments on these notes, please provide them to the Appeal Manager in writing, together with your appeal. If they have not heard from you by [insert date] the record will be taken to be agreed.
Yours sincerely
Decision Manager
Enc: Notes of meeting Model Letter 7 - Dismissal for repeated misconduct
Official – Sensitive
Date
[Name and location of employee]
Dear
Dismissal for repeated misconduct
I am writing to advise you that a decision has now been taken regarding your employment with ORR.
[Insert history if repeated misconduct]. On [date] you were given a first written warning that you had failed to meet the standards of conduct expected of ORR members of staff. On [date] you were given a final written warning following a further failure to maintain acceptable standards of conduct. You were also informed that if your conduct fell below these standards again you were likely to be dismissed.
I am writing to confirm the outcome of your meeting with me on [insert date] to discuss the misconduct case brought against you.
We discussed your alleged behaviour [details of misconduct] during the meeting and you claimed that [insert details of employee’s response].
I have carefully considered all the circumstances including (the results of the investigation) and/or your representations.
Either: In view of your acceptance that you [insert details of misconduct]
Or: The investigation has concluded that you [insert details of misconduct]
After considering all the relevant factors—it has been decided that your employment with ORR is being terminated and your last day of service is [date decision to dismiss was made]. You are entitled to [insert number of weeks’ notice] weeks’ notice and you will be paid in lieu of notice. You are not required to attend work during this time. A further letter will be sent to you covering issues such as your obligations under the Official Secrets Act and payment for any untaken annual leave.
You have a right to appeal against this decision as long as you do so in writing within 10 working days. Any appeal should be addressed to [insert name of the Appeal Manager] and copy sent to your HR Business Partner.
A copy of the meeting notes is enclosed. If you have any comments on these notes please provide them to the Appeal Manager in writing together with your appeal. If they have not heard from you by [insert date] then the record will be taken to be agreed.
Yours sincerely
Decision Manager [with authority to dismiss]
Enc: Notes of meeting Model Letter 8 – Dismissal for gross misconduct
Official – Sensitive
Date
[Name and location of employee]
Dear
Dismissal for gross misconduct
I am writing to confirm the outcome of your meeting with me on [insert date] to discuss the gross misconduct case brought against you.
We discussed your alleged behaviour [details of gross misconduct] during the meeting and you claimed that [insert details of employee’s response].
I have carefully considered all the circumstances including (the results of the investigation) and/or your representations.
Either:
In view of your acceptance that you [insert details of gross misconduct]
Or: The investigation has concluded that you [insert details of misconduct and reasons for coming to the decision, including details of all mitigating factors\*]
After considering all the relevant factors, it has been decided that your employment with ORR has been terminated. This will take effect immediately, without notice and without pay in lieu of notice. Therefore your last day of service is [insert date decision was made]. A further letter will be sent to you covering issues such as your obligations under the Official Secrets Act.
You have a right to appeal against this decision as long as you do so in writing within 10 working days. Any appeal should be addressed to [insert name of the Appeal Manager].
A copy of the meeting notes is enclosed. If you have any comments on these notes please provide them to the Appeal Manager in writing together with your appeal. If the Appeal Manager has not heard from within 10 working days the notes of the meeting will be taken to be agreed by you.
Yours sincerely,
Decision Manager [with authority to dismiss]
Enc: Notes of meeting Model letter 9 - Downgrading for gross misconduct
Official - Sensitive
Date
[Name and location of employee]
Dear
Downgrading for gross misconduct
I am writing to confirm the outcome of your meeting with me on [insert date] to discuss the gross misconduct case brought against you.
We discussed your alleged behaviour [details of gross misconduct] during the meeting and you claimed that [insert details of employee’s response].
I have carefully considered all the circumstances including (the results of the investigation) and/or your representations.
Either: In view of your acceptance that you [insert details of gross misconduct]
OR: The investigation has concluded that you [insert details of misconduct and reasons for coming to the decision, including details of all mitigating factors]
The ORR is entitled to terminate your employment with immediate effect on the grounds of your gross misconduct but after considering all the relevant factors, I have decided to offer you the option to accept a downgrading as an alternative to dismissal.
Should you accept, this will take effect from [insert the date] and will be a permanent change to your terms and conditions of employment. HR will write separately to you about the changes that this will entail and will seek your formal consent and confirmation to the changes to your terms and conditions of employment.
Should you choose not to accept the penalty of downgrading, you will be dismissed with immediate effect, without notice and without pay in lieu of notice.
You have a right to appeal against this decision as long as you do so in writing within ten working days. Any appeal should be addressed to [insert name of the Appeal Manager].
A copy of the meeting notes is enclosed.
Yours sincerely
Decision Manager [with authority to dismiss]
Enc: Notes of meeting Model Letter 10 - Appeal invitation Letter
Official – Sensitive
Date
[Name and location of employee]
Dear
Invitation to appeal meeting
I am writing to invite you to a discipline appeal meeting to discuss [specify issue].
I will meet you on [date, time and location]. At the meeting you have the right to be accompanied by a trade union representative or a work colleague. You will need to let me know who they are prior to the meeting.
If you or your companion cannot reasonably attend the meeting, you should propose a new date to allow the meeting to take place within five working days of the original meeting date. If you do not do this, or fail to attend the re-arranged meeting, consideration of the appeal will go ahead in your absence based on the available information. [Insert if note-taker to be present, giving name if known.] He/she will record our discussion.
The purpose of the meeting is to examine the decision-making process and decide whether these were reasonable. It is not a full re-hearing of your case.
I will decide whether your appeal will be upheld or not. Be prepared to put to me any points and evidence you feel should be taken into consideration when reaching my decision.
Please let me know as soon as possible or at least three working days prior to the meeting, if you or your companion requires any special arrangements or if you need any particular accommodation requirements to enable you to attend the meeting.
Yours sincerely
Appeal Manager Model Letter 11 - Appeal decision
Official – Sensitive
Date
[Name and location of employee]
Dear
Appeal decision
You appealed against the written warning/final written warning/notice of dismissal/summary dismissal confirmed to you in writing on [date of letter].
Further to the appeal meeting held on [insert date of appeal meeting] I am now writing to advise you of/confirm the decision on your appeal.
Either:
Your appeal was not upheld and the original decision taken by the decision manager stands. [Include further explanation if appropriate].
This decision is final.
OR:
Your appeal was upheld. Accordingly the [specify penalty] is being revoked and I can assure you that your employment prospects within ORR will not be affected\*. [include further explanation if appropriate] However all details of the process will be kept securely as part of your confidential ORR discipline file.
For successful dismissal appeals\*
Your appeal was upheld. You will be re-instated to your position as [insert grade/name of position] with immediate effect without loss of pay. ORR will disregard any break in continuity in your employment for all contractual and other purposes and you will not lose seniority.
All letters
I enclose the notes of the appeal meeting.
Yours sincerely
Appeal Manager
Enc: Notes of meeting Model letter 12 - Informing employee where there is no case to answer
Official - Sensitive
Date
[Name and location of employee]
Dear
Discipline decision
I am writing to inform you that the investigation into your alleged misconduct [insert details of incident] which took place on [insert date/s] has concluded. I have carefully considered all the circumstances including [the results of the investigation] and/or your statement and have decided that there is no case to answer. No further action will be taken.
I enclose a copy of the investigation report, including witness statements for your information.
Thank you for your co-operation during the investigation.
Yours sincerely
Decision Manager
Enc: Investigation Report Model letter 13 - Informing employee where allegations are not proven
Official - Sensitive
Date
[Name and location of employee]
Dear
Discipline decision
I am writing to confirm the outcome of your meeting with me on [insert date] when we discussed the misconduct case brought against you.
We discussed your alleged misconduct [details of misconduct] during the meeting and you claimed that [insert details of employee's response].
I have carefully considered all the circumstances including the results of the investigation and your representations at the meeting. I have decided that the allegation has not been proven and that misconduct has not occurred. Therefore, I will take no further action.
A copy of the meeting notes is enclosed.
Thank you for your co-operation during the investigation.
Yours sincerely
Decision Manager
Enc: Notes of meeting Model letter 14 - Notice of suspension with pay
Official - Sensitive
Date
[Name and location of employee]
Dear
Notice of suspension
I am writing to confirm our conversation, that in view \*of the circumstances of your case/\*of the seriousness of the alleged offence you are to be suspended from duty with pay from [date of conversation] \*pending investigation into your alleged misconduct / * consideration of your alleged criminal offence.
It is important for you to note that suspension is neither an assumption of guilt nor a disciplinary penalty. It will not prejudice the outcome of the investigation.
I will review this decision at regular intervals.
You will remain an employee of the Department and must continue to comply with the Departments Standards of Behaviour. The normal rules regarding annual leave and sick leave continue to apply during your suspension.
You will continue to receive pay while suspended and are expected to remain available for duty during your normal working hours and to co-operate with the investigation.
The investigation taking place is confidential and should not be discussed with anyone except your companion during this period.
If you have any queries please do not hesitate to contact me.
Yours sincerely
Decision Manager Model letter 15 – Cessation of suspension
Official - Sensitive
Date
[Name and location of employee]
Dear
Cessation of suspension
You are currently on a period of suspension from duty with pay pending \*investigation into your alleged misconduct / \*consideration of your alleged criminal offence.
I am writing to inform you that this current period of suspension, which commenced on the [insert date of commencement] will end on [insert date].
You are expected to resume normal duty on [insert date/time of commencement]. If there are any reasons why you may not be able to attend at this time, can you please contact me as soon as possible.
Please report to [insert name] on your arrival.
If you have any further queries please do not hesitate to contact me.
Yours sincerely
Decision Manager
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19d3b97396c2512b67767c872b51a5f97e4c46a1 | Disclosure Ref: 1 sent 16/1
Freedom of Information Act 2000 Request
Cost of Liam Allen trial
Request
Liam Allan trial and preparation.
Please advise all costs associated with the above. Breaking it down to the various elements through preparation, bringing the case to the lower court and the higher court.
Response
Please note the following information only relates to external costs to the CPS for the case of Liam Allen at the Crown Court. The internal costs of the CPS in relation to this case cannot be provided as this information has not been specifically recorded. The response to your request can be viewed below.
Plea Trial Preparation Hearing (PTPH): £100 payment to Counsel and a conference fee of £80.40, this figure is inclusive of VAT.
Three day trial: Junior Counsel costs of £2,352.00, inclusive of VAT.
Cracked trial: Junior Counsel costs of £1,596.00, this figure is also inclusive of VAT.
Information Management Unit 020 3357 0899 [email protected]
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e7ef342575f930aa42f1fa961fce9cb396ef3d8e | Introduction
2017 marks the 500th anniversary of the beginning of the Protestant Reformation. In 1517, Martin Luther famously nailed his 95 Theses to a church door in Wittenberg, Germany. This act of defiance can be seen to herald the process of change in religious practice across Europe.
Henry VIII’s dissolution of the monasteries took place as part of the Reformation in England. It resulted in the plunder of church wealth and the destruction of monasteries and their communities.
‘Chronicles of the Dissolution – Piety, Plunder and Protest’ is a graphic arts project illustrated by eight students who spent a week at The National Archives in Kew illustrating their interpretations of Early Modern records from the State Papers of Henry VIII. The tales are told through the eyes of individual characters, from the lowliest carpenter to the ruthless commissioner.
Together they give us a unique insight into the consequences which followed dissolution as a result of Henry VIII’s determination to reform the English Church.
Ela Kaczmarska – Education Officer, The National Archives The Minstrel's Tale
Summertime. Mid-late 1530s, in an average town in England.
A troupe of MINSTRELS on a stage in a village square, holding a number of instruments: a lute, a fiddle, a trumpet, and a bagpipe. At the other side of the square, stands a PREACHER, on a box. A crowd has gathered. Half face the PREACHER, half the MINSTRELS.
PREACHER: No more taxes! Get rid of the sponging, thieving monks! Evil sorcerer scum! Posing as holy men with their sick superstitions, superfluous ceremonies, slanderous jugglings and counterfeit miracles! Fleecing you, the people, for a glimpse of an old cow bone!
(He holds up the items as he speaks)
Telling you it’s St Mary’s Girdle, or St Bridget’s elbow! The coals that St Lawrence was toasted with! The parings of St Edmund’s nails! St Thomas of Canterbury’s penknife! A bell to wear upon the head to dispel a headache!
PREACHER’S CROWD: Liars! Hypocrites!
PREACHER: Truth to tell, the nuns are all sultry sex slaves, salivating lasciviously –
The MINSTREL, strums a chord:
– Ah, the truth, the truth! Tell us, troll, what’s Cromwell paying you and all your mates to lurk in every village square?
The MINSTREL'S CROWD whistles and cheers. The PREACHER’S CROWD boos.
PREACHER: I am the agent of the Vicar General! I speak the truth –
The MINSTREL'S CROWD whoops. A chant rises:
Song! Song! Song! Song! Song!
The MINSTREL holds up a hand:
It’s great to be back here in –
BACKING MINSTREL, whispers:
Nottingham
MINSTREL:
– Nottingham!! So vibey! So what'll it be today, Nottingham? A couple of our good King’s tunes?
(He strikes a chord and nods to the band, and sings) Pastime with good company I love and shall until I die
The MINSTREL'S CROWD groans. The PREACHER'S CROWD applauds.
MINSTREL: No? A spot of Green Groweth the Holly? ... It Is to Me a Right Gret Joy? ... O My Hart?
CROWD: Noooooo!
MINSTREL: You're right, those tunes of Henry's are, what – at least ten years out of date. But wait! I have the very thing – (to fellow musicians) – on three. One, and a-two –
All musicians start playing. MINSTREL sings
Crim, Cram, and Rich! With the three L's and their like
CROWD: Layton! Legh! London! The priest, the lawyer, and the don!
MINSTREL: Catchy chorus! We'll come back to that!
As some men teach God them amend And that Aske may Without a delay Here make a stay And well to end
(He points to CROWD, who are waving banners with 'Resist' and other slogans)
MINSTREL'S CROWD chants: Layton, Legh, London!
PREACHER, enraged, pointing. Suddenly, the PREACHER'S CROWD parts to show
SOLDIERS: Traitors! There! Seize them! Slandering the names of the commissioners! Praising the rebel Robert Aske!
MINSTREL: But wait, wait! I have it now – the last few lines of that smash hit by our very own King Henry:
(He sings, as he is dragged away by soldiers)
Company with honesty Is virtue, vice to flee. Company is good and ill, But every man has his free will –
(A soldier knocks him unconscious.) The Maid's Tale
December 1532, Windsor Palace. Elizabeth BARTON (aka 'The Maid of Kent') – a young woman who is famous for her religious visions – is with her mentor Dr BOCKING. They are outside Henry VIII's bedchamber.
A split scene, showing Henry's bedchamber. HENRY (aged 42) is sitting on the edge of his bed, in his nightclothes. CROMWELL (aged about 47) stands nearby, with papers to sign, and on the other side of the door, Dr BOCKING (aged about 52) and Elizabeth BARTON (aged about 26). BOCKING is dressed as a monk, and BARTON as a nun. They whisper.
BOCKING: Go in, go in, the door's ajar!
BARTON: But –
BOCKING, shoving her: You must! I am your father in God, and I know best.
(Inside the bedchamber.)
HENRY You bore me, Cromwell, with your ifs and buts. I must marry Anne or –
(The door opens, and in runs ELIZABETH BARTON, her hair and clothes in disarray.)
BARTON: My King! My King! I am compelled! The heavenly voices speak in me!
HENRY: Well, well, if it isn't the Maid of Kent! St Sepulchre's nun! Let her be, Cromwell. I saw her twice before. Let's hear what she has to say.
BARTON Seizes his arm, looks him straight in the face: Heaven's door lies open, Prince, its windows all ablaze
(CROMWELL moves, but Henry shoos him back.)
BARTON but you – you crawl in darkness, tormented by your lust. Passion drives you onwards, but all too soon to dust your body falls.
(HENRY laughs. BARTON pulls Henry's head down to her stomach. CROMWELL goes to strike her. HENRY stops him.)
BARTON: Listen hard, poor Prince. Your ears will hear the call, the cries of Virgin Mary, mother of us all.
HENRY: How is it possible, Cromwell, that her voice seems to come from her stomach so? Look, her lips are barely moving. BARTON, in a terrible voice, eyes rolling, mouth frothing:
Your sight is short, your senses dim. You throw away your soul upon a whim. Marry Boleyn, and in but half a year You'll be six feet down, with all of hell to fear.
HENRY, angrily: Enough! Get rid of this versifying witch!
(January 1534. St Paul's Cross, London.)
BARTON and her followers, including Dr BOCKING, and many abbots and nuns kneel at St Paul's Cross. Richard LAYTON (aged about 32) and other of CROMWELL's men stand in front of them. It is snowing. BOCKING and Barton hold hands.
LAYTON, to BARTON: Most lying and false nun! Confess!
BARTON: I confess that when I said the devil did spit in my face, and it was black as soot and stinking as carrion, it was a fabrication!
(The CROWD shrieks, gasps)
LAYTON, turning to BOCKING: Confess, devil's bastard!
BOCKING, head bowed: I confess that I did encourage the Maid of Kent to say such things! It was not her doing.
BARTON looks at BOCKING:
No, no – it is I who am the cause of all this mischief. I fooled Wolsey then, and now Thomas More.
LAYTON, to the monks and nuns assembled: And you, treacherous doublehoods? Did you not follow the Maid and her ghostly father you see here?
MONKS AND NUNS, looking worried, shaking heads: If any of us heard or believed the said false revelations, we be right pensive and inwardly sorry.
CROWD: String 'em up! Put their heads on a spike!
(London Bridge, 13 April 1534. Thomas More is going to Parliament.)
Thomas MORE (aged about 54) is being driven by in a carriage. With him is his cat. He is anguished, distracted.
MORE, stroking his cat: So, puss, off to Parliament today, to swear allegiance to The Act of Succession! All for his new Queen, more like. Queen Anne – hah! The cat stares back at him. MORE looks out of the window.
Suddenly, he raps on the carriage to stop, pulls back curtain, looks out of the window. There, framed by the Houses of Parliament, is Elizabeth BARTON's head on a spike. Next to hers is that of BOCKING. MORE stares.
MORE: The Maid of Kent... I saw her with my own eyes when she was just a serving girl. She was right, so many times. I wasn't the only one who believed her, you know. Warham, Fisher of Rochester, the brothers of Syon, Wolsey, and even Henry himself!
(He pauses.)
When she spoke her visions, her voice was so unlike hers. Like a puppet, you know.
(To BARTON:) No heavenly voice will ventriloquize you today, dear lady. Oh, Maid! So silent, now when we need you most? Tell me, what will become of me? But wait! Of course! You have a message for me still. Qui tacet consentire videteur! (He laughs) You speak true, as ever, my dear!
(He raps on the carriage to move on.)
I shall not say a word! They cannot know my mind if I do not speak it – and silence means consent, in law!
On 1 July 1535 Thomas More was charged with high treason for refusing to acknowledge the Act of Supremacy. His defence was to remain silent. He was executed five days later. The Nun's Tale
London, The Rolls (The office of Thomas Cromwell).
Margaret VERNON (a middle-aged woman), Prioress of Little Marlow Abbey, and a young NUN (aged 25) stand in a busy street outside the Rolls – a grand court building in central London. Nearby is a pawn shop with an ornate iron sign hanging above it. In the sign is a diamond, with the words ‘Bestyan – Jeweller’.
VERNON is standing before two soldiers, who look past her. There is a queue of other people, including several MONKS. The NUN is standing to one side, looking at the shop window.
VERNON: But I must see him, I tell you! He knows me!
MAN: Oy, there’s a queue here you know!
WOMAN: Cheeky, innit.
MONKS: Sister, we too need to see Master Cromwell. So many of us have been turfed out, left with nothing!
VERNON: Well, I hear that many of my brothers get pensions, or openings as chaplains, or clerks. And at the very least, four shillings and a priest’s robe!
MONK: These rags? And not every man–
VERNON: Ah, but the women? Have you considered that nuns get nothing at all? Tell me, brother, why should that be?
MONK: The Lord moves in mysterious ways.
(As they argue, the NUN slips away inside the pawn shop. VERNON does not notice.)
VERNON, facing back to the soldiers: Tell Master Cromwell Margot Vernon is here. I am Prioress of Little Marlow nunnery, and was the teacher of his son!
SOLDIER, snickers: Yes, and I’m the Maid of Kent!
Inside the shop of Bestyan the Jeweller.
The shop is dark, dingy, full of objects pawned by desperate people. From the back of the shop a small middle-aged man appears. He is the jeweller, BESTYAN (aged about 50). He looks suspiciously at the nun. NUN, looking around anxiously: I hear, sir, that you do accept … certain goods. They say that you're the best.
BESTYAN: Well, you're better off with me than the goldsmith, that's for sure. Last week he pulled the wool over the eyes of the Abbot of Fountains alright. The goldsmith told him his rubies were garnets. A very fool and miserable idiot! But I see you are different, more intelligent, as well as beautiful.
NUN, hastily: I have no time, sir – just look.
(She reaches into a bag and pulls out a gold plate with emeralds, and a textile belt.)
BESTYAN: I'm always happy to take a look for a sister in God.
(He screws an eyeglass into his eye and examines both carefully.)
Hmm. And where did you come by this, you say?
NUN: Oh, I… found it. Near Little Marlow. Just lying in the road.
BESTYAN: Sadly, sister, these are just zircons, not emeralds. Practically worthless! And as for this old belt-
NUN: A holy relic – St Mary's girdle!
BESTYAN: I've seen ten of these this week.
NUN: But –
BESTYAN: But don't despair, sister – I'm sure we can come to a deal.
NUN: Thanks be to God!
Little Marlow Abbey. The Cell of MARGARET VERNON, Prioress.
Margaret VERNON in her cell in the convent, writing a letter. Other than the desk and chair there is a small chest in the corner. VERNON is irritated, distracted. With her stands the young nun.
NUN, curiously: Are you writing to Master Cromwell, mother?
A pause. VERNON, continues writing:
I would be, foolish girl, if only you didn't keep interrupting! NUN, starts to cry: It's not my fault I'm here! It's so unfair. Just because I turned 25 last month I can't leave with all the others! They can do what they like! They can get married –
VERNON: They cannot! The vow of chastity is broken only on the King's death! And don't think that the others aren't struggling.
NUN: And that Commissioner was so horrible, mother! What malice and grudge he bore against us, calling us spoilers and wasters! And what a lech! He was, like, totally obsessed! He kept asking me how many monks I'd – you know – done it with. None, I said, and then –
VERNON: Layton and the others are gone, now. Try not to dwell.
(A pause.)
I'm sure Master Cromwell will see us right. I am putting in a word for you now. I gave him my word that I would embezzle nothing, but leave the house as wealthy as I could, and so I will! After all, we have the Emerald plate and the Girdle of St Mary. In fact, I shall check on them now –
NUN, splutters: No! – no need, mother. I dusted and polished them only yesterday.
VERNON: Leave me in peace now, child.
The young NUN leaves. VERNON pauses, puts down pen, and goes to a small chest in the corner. She opens it. It is empty. She stares at it.
The Rolls, London.
CROMWELL with clerks. They are presenting petitions to him.
CLERK 1: So the Abbot of Fountains gets one hundred pounds a year. Dartford Prioress – Joan Vane, 100 marks. Re: Sion – the Abbess Agnes Jordan is to get 200 pounds. Oh, and I have a letter here from one Margaret Vernon, my lord, Prioress of Little Marlow nunnery.
CROMWELL: Vernon, you say?
CLERK: I have tried to see you, but am kept back by your men, she says. She seeks your help to some respectable living for herself. Could she be transferred to Malling in Kent, she says.
CROMWELL: Vernon! Of course! My boy Gregory's teacher! Yes, yes, transfer her somewhere else! Is it just for herself she asks?
CLERK, leafing through papers: She refers to a 'poor maiden' who is with her, but makes no case for her. CROMWELL: Give Vernon Mallings Abbey, and a pension of £40 a year.
Nuns under the age of 24 were permitted to abandon religious life. For those older than 24, however, there were few opportunities to earn a living, and they were unable to marry since their vow of celibacy was still in force. While monks may have had opportunities to work as private tutors, chaplains, clerks, and the like, little is known of what became of nuns that were released, although some records of pensions for both monks and nuns do exist. It is estimated that a minimum of 1,800 clergy were left with no visible means of support after the Dissolution of the Monasteries. The Monk's Tale
28 September 1536. Hexham Abbey, Northumberland.
We are inside the Abbey, near the altar. A group of monks huddle around MONK 1, who is hidden from view.
MONK 1: I can't! I am a man of faith, not –
MONK 2: Think of the many who resist! All men of peace. The Swalesford nuns, the Aylesford Friars! so meek, yet they defend our Queen against the King, – a herd of wild beasts, the King's men say.
MONK 1: The King's men –
MONK 2, angrily, gesturing to MONK 3: – sent out to spy, repress, redress, reform, extirp, correct, restrain, amend! as Layton says – that pestilential pug – it's all for increased virtue in the church!
MONK 3: We've heard the tales – what Layton and his friends do write in that compendium of theirs, that book so full of spite, and sin, and hate – where all monks are per volunt. poll. sodomites –
MONK 1: You what?
MONK 4 – a load of rubbish, mate, to you and me –
MONK 3: – we sleep with anything that moves, you know – the nuns as well, all peperit ex solute –
MONK 4: – that's ridiculous –
MONK 3: Like rabbits breeding every chance we get – and all is true, 'cos Layton says it's so. And now he's taken it to parliament. Our shame so public, so clear for all to see –
(Bells ring; the monks look startled.)
MONK 1: The bells! They're here! Make haste, make haste! MONK 2: Keep still, and let me do you up like so – – and there, we’re done! You stand in harness, brother.
(Stands back to reveal MONK 1, in full armour. Behind him, the altar cross.)
MONK 1: I never thought this day would come to pass.
On the tower of Hexham Abbey. Clouds gather. The MONKS stand in a row, in armour. The ABBOT of Hexham, Augustine WEBSTER (aged about 50), stands in front of them. Below them, a crowd, heavily armed, with halberds, bows, arrows, pikes and other weapons surround two men on horseback, who are carrying the King’s standard. They are Richard LAYTON (aged about 36) and Thomas LEGH (aged about 38), the King’s Commissioners.
LEGH: You’ve heard the talk: while many houses fall yet some lie low. In Louth the vicar there holds out.
LAYTON: I know. While Aske, the lawyer, stirs it up. But look, this crowd does not seem pleased at all –
LEGH: It’s like a town at war.
(The bells of the town and the monastery ring out. A voice from above.)
LEGH: You shall not have this house of God!
LAYTON: Yield! You must do so.
WEBSTER holds up a hand. The monks in armour flank him. The crowd falls silent.
WEBSTER: The King says not.
LAYTON (confused): What? How? That cannot be. The King decrees –
WEBSTER, unfolds a scroll in his hands:
Here is the confirmation of our house With the royal Seal –
LAYTON: – King Henry’s seal?
WEBSTER: The same. He gave it but a year ago. The house is ours, he said. And now he contradicts his own decree. (A murmur from the crowds. They gather more tightly around the men.)
WEBSTER: We shall all die before you take our lands, our goods, or house.
LEGH: Is this how you respond?
WEBSTER: It is, in full. And now we march, for God.
(He gives a signal, and the gates of the monastery swing open, revealing a group of monks, all armed. They march forward, pushing the men back. The last we see of them is the monks standing on the village green in a row, waiting until LAYTON and LEGH are out of sight.)
A month later. Somewhere in the woods of Northumberland.
The MONKS of Hexham are in hiding. They are injured, cold, desperate.
MONK 1: My cousin has come from Tyburn Tree today. Weber, she says, was brave. Reynolds of Syon Abbey too, and Lawrence of Bevall. Cromwell asked them one more time – are you content, says he, to take the King as Supreme Head on Earth of the Church of England?
(A pause.)
MONK 1: They all said no.
(The monks weep.)
MONK 1: The King’s men choked them half the way to death, and then relieved them from the noose, let fall their kicking, anguished flesh to God’s sweet ground, attached their limbs to ropes, and then, the ropes to horses, one of whom faced North, the others – South, and East, and West.
Their body parts now hang around the city.
The Hexham uprising was quickly put down, and the monks all executed. Days later, on 1 or 2 October 1536, an uprising at Louth in Lincolnshire began. It gained the support of at least 20,000 people (some reports say double this number). The Louth Rebellion lasted for around a fortnight. It was followed weeks later by another, even larger uprising in Yorkshire known as The Pilgrimage of Grace. The Rebel’s Tale
October 1536, Hampton Court Palace.
Indoors. HENRY (aged 45) stands impatiently while HOLBEIN the Younger (aged 39) paints him. Jane SEYMOUR (aged 28), his new wife, is sitting near him, embroidering. She is nervous.
HENRY: I can’t stand this any longer! Haven’t you heard there’s another uprising in the North? 40,000 men have gathered. Just days after all that trouble in Louth!
JANE: 40,000?
HENRY: At least, blast it!
JANE: But, your majesty, your brave men dealt with Louth; surely they will do the same here.
HENRY: This is different! This one’s not some peasant rabble led by a vicar and a shoemaker, Captain Cobbler! This time it’s the lords and nobles – all sworn to me, the traitors – and at their head a lawyer, one Robert Akse, Esquire. But I’ve sent Norfolk to deal with it – he’ll not spare them.
JANE: Aske? Robert Aske? The lawyer? But –
HENRY: Speak up, sweet! But, what?
JANE: He is my cousin. An honourable man, and honest –
HENRY, looking sideways at her, dangerously: Your cousin, you say?
JANE, gathering her courage. She throws aside her embroidery and falls to her knees: Yes, and on my bended knee, I plead, my Lord. Robert is a good, good man. Could these rebellions not be God’s punishment, my Lord, for overstepping the mark? If Robert leads them, it is a true cause!
HENRY: A true cause? Silence! Think on what happened to your predecessor, wife! Never mention his name again!
(He brushes her aside, walks round to looks at painting.)
Holbein! Are my eyes really that close together… and what do you think you’re doing, painting me so… fat?
HOLBEIN: You see far, my lord. You are grand. Mighty. Doncaster, 6 December 1536. The Duke of Norfolk and Richard Layton are meeting with the leader of the rebellion, Robert Aske.
A royal tent. Inside it, hangings, rugs, a table in the middle. Soldiers. The Duke of NORFOLK (aged 63) sits on one side, and on the other, Robert ASKE (aged 36). In the corner, Richard LAYTON.
NORFOLK: The King has asked me here to treat with you, Mister Aske. This uprising must stop.
ASKE: We wish no bloodshed, merely to present our Articles.
NORFOLK: Your… articles?
ASKE, counting off on his fingers: One, the suppressions must cease. Two, Cromwell must be expelled. Three, the monasteries must be re-established. Four, the King must yield to the Pope’s authority.
NORFOLK: The King is Supreme Head of the Church of England, you whelp. You dare –
ASKE: We have 40,000 men – more than your soldiers combined. We’ve taken York, Hull, Pontefract and Doncaster.
NORFOLK: You insolent –
LAYTON, stepping forward: Of course, of course. By the way, the King’s new wife, the Queen Consort – your cousin, I believe? – asks after you.
ASKE, surprised: Jane? I have not seen her for so long – is she well?
LAYTON: Come to London, my friend, and see her yourself.
ASKE, looking from one to the other. Both LAYTON and NORFOLK are smiling.
LAYTON spreads his hands, palms up, in a conciliatory gesture: The King offers all concerned an unconditional pardon.
ASKE, hesitates, then speaks: I will come. Aske met with Henry in London and negotiated a deal. However, fighting then broke out again in Yorkshire, and Aske was arrested and charged with high treason. Aske was hung in chains from the battlements of York Castle. The ringleaders of the Pilgrimage of Grace were arrested and executed.
After this, in the spring of 1537, the great monasteries surrendered one by one, starting with Furness. The Scaffolder's Tale
Lewes Abbey, 1538.
We are at the top of the abbey's spire, looking down. There are gargoyles on the spire. Seagulls circle. A SCAFFOLDER is up there, hammering boards together, securing poles and timber with rope and nails. Far, far below, we see two figures emerge. One is Richard LAYTON (aged about 38), and the other, PORTINARI (aged about 50), the Italian engineer hired to oversee the deconstruction of the great abbey.
SCAFFOLDER, to himself: Can't believe they're taking this old beauty down. It's stood here five hundred years – what a waste. All that Quarr limestone. Those tiles! Such craftsmanship, such artistry! But once Furness Abbey caved last year it's just been a matter of time.
(He pats a gargoyle, who is pulling a face.)
Mmm, I know how you feel, mate.
(Down below)
PORTINARI to LAYTON, both looking up at the spire: It's no easy job. The church is larger than we thought – look.
(He shows LAYTON a blueprint / diagram of the church, with specifications. The specifications read:
Front wall: 10 feet thick Height of steeple in front: 90 feet Height of platform with the five bells: 105 feet Circumference inside: 155,812 feet Circumference outside: 151,200 feet Length 420 feet width 692 feet Height: 63 feet Steeple: 10 feet 32 pillars 8 very large Each pillar: 14 feet thick 45 foot round Large pillars: 42 feet high Height of platform of the great altar: 93 feet)
LAYTON, looking displeased: It's beyond you, then? And yet you have brought down so many houses already –
PORTINARI, offended: I never said I couldn't do it. You see, the scaffolds are in place already. But I will need more men, and the means to pay them –
LAYTON: There is no shortage of men, nor means.
PORTINARI: And not locals – I need practiced hands! Experts. Men from London. Seventeen at least. Two more carpenters, two smiths, two plumbers, one furnace-man to melt the lead, and nine labourers. And we'll need straw – lots of it – to cushion the stones when they're thrown to the ground. Horses and carts to take the stone away.
LAYTON, making a note; It shall be so. And quickly – we cannot have this constant looting. There is stealing nightly. Comers and goers daily –
PORTINARI: I heard they stole glass out of the windows last night.
LAYTON: Next they will bear away doors, and pluck down ceilings!
PORTINARI: Very well, we start on Friday. We shall cut the wall behind the high altar, and then the foundations of these four great pillars. We shall put in props and then we will bring the whole thing down by burning the props with fire or powder.
SCAFFOLDER, up high, tying a rope: But it's well paid, there's no denying that. And those monks are all corrupt, aren't they. Who appointed them to lord it over us?
(Close up of his foot kicking a hammer. The hammer flies off the scaffold, and falls…)
– oops!
PORTINARI: – Watch out!
(He shoves Layton to one side. LAYTON, sprawls. The hammer lands where he was standing.)
LAYTON: – What? I –
(He laughs.)
An omen from above, master engineer!
Morning. RICHARD LAYTON's lodgings in LEWES.
Richard LAYTON stands in front of a mirror, his arms outstretched. He is wearing his nightshift. His servant BARTELOT (aged about 35) dresses him throughout the following, which is directed to a clerk sitting at a desk nearby.
LAYTON: Dictation: We have visited Battle, Bath and Lewes. At Battle the abbot is the arrantest churl that ever I see – a beetle and buzzard – a black sort of monk, past amendment, I am sorry to say.
(He lifts his arms over head)
At Bath we found the monks more corrupt than any others in vices –
(His nightshirt is pulled off him. He is bare-chested. BARTELOT glances at him, catches his eye) – with both sexes.
(He raises his arms again to receive a shirt)
The place is a very stews, and unnatural crimes are present both there and at Lewes –
(BARTELOT stands very close to him to lace up shirt)
– where I found corruption of both kinds – and what is worse, treason. The subprior confessed treason to me. I made him put his name to it, and confess that the prior knew of it too! That done, I then accused him of the further crime of concealing treason. I called him heinous traitor in all the worst names I could devise –
(looks down at BARTELOT, who is now kneeling to tie his britches)
– he all the time kneeling and begging me not to tell you of this. But I regarded his words –
(BARTELOT now holds up a hand mirror. LAYTON preens.)
– but smally.
London. The office of Thomas CROMWELL. CROMWELL (aged about 53), at his desk, listening, a stack of letters before him, and a large box, and behind them, three hawks on a stand. A clerk is reading a letter.
CLERK: ‘...but smally. Lewes Abbey is now being brought down. Portinari the engineer is overseeing. I send you the goods I have taken from there. Enclosed – vincula S. Petri, which women put about them at the time of their delivery.
(CROMWELL opens the box. Picks out several long pieces of mummified tendon, holds them with distaste.)
CLERK: I send you also a great comb called Mary Magdalene’s comb –
(CROMWELL Lifts out a comb, looks at it in bewilderment.)
CLERK: The prior of Bath sends you these Irish hawks. No hardier hawks can be.’
CROMWELL turns and looks at the hawks. They look back at him.
Lewes Abbey. A group of workman stand around outside the Abbey. PORTINARI is there, and the SCAFFOLDER, as well as the ABBOT (aged about 55) and monks.
PORTINARI: Get down and cover your ears!
They all crouch, apart from the ABBOT, who stands defiant. There is an explosion inside the abbey (or series). Lewes Abbey collapses before their eyes.
SCAFFOLDER, leads the ABBOT away: Come on, Father. Let's get you home. I'll take you on my cart.
The ABBOT's home. The ABBOT stares at a carriage drawn up before his house.
ABBOT: Who's that?
SCAFFOLDER: No idea – hang on.
He approaches the house. The door opens, revealing a young man and woman. It is GREGORY CROMWELL (aged about 18), and his new wife, ELIZABETH SEYMOUR (aged about 20), sister of JANE SEYMOUR.
ELIZABETH: Your father was so generous in agreeing to divide Sussex between himself and the Duke of Norfolk and in giving us this wonderful house! Oh, Greg, I love it here!
GREGORY: I know – and everyone's moving in! The Dacres, Gage, Gainsforth, Shelley, and Bellingham – all our friends –
ELIZABETH: So much merrymaking to be had!
GREGORY, catching sight of the SCAFFOLDER and the ABBOT: Can I help you, my good man?
SCAFFOLDER: I – no. We're just passing through.
Two months later GREGORY CROMWELL and ELIZABETH SEYMOUR fled Lewes after an outbreak of plague nearby. They moved to a former convent called the Motte, four miles out of Lewes. In 1551 GREGORY died of what was known as the 'sweating sickness'. The Carpenter’s Tale
Boxley Abbey, 7 February 1538.
Inside the monastery of Boxley. The interior has been attacked by the Commissioner’s men, with shattered bits of wood, chiselled off images all around. There are, however, flowers everywhere, more than would usually be the case. The monks and abbot stand near the Roode of Grace, which is a large wooden image of Christ on the Cross. It is attached to a pillar— or was, as it is now semi-attached, hanging precariously, bits of wire protruding from its back. The monks’ heads are bowed, apart from one old man at the front – the ABBOT – who is looking up at RICHARD LAYTON (aged 38). Layton is standing on the altar.
LAYTON: What do you mean, old fool, that you know nothing of these engines and old wire at the back here? These old, rotten sticks?
ABBOT: The Roode has not been moved for many years. Not since it was delivered to us, a miracle, on the back of a horse –
LAYTON, turned away, pulling at wires: – a whore, you say?
ABBOT: A horse, my lord, a riderless horse, that ran up to the door and thence to this pillar – A miracle, I tell you! The divine hand working! The King himself came here some thirty years ago, when he was but a youth, and gave us six shillings to see it! And you dare lay hands on it –
LAYTON, grunts, tugging at the wires and pulleys behind:
- and yet I am not the first, buzzard. Some cunning carpenter has been here before me!
(He opens compartment at back, wriggles his way into it. His head is no longer visible, but we hear his voice, suddenly, as Christ’s mouth moves up and down.)
LAYTON (as Christ): ‘Ooo, bishop, I am sore thirsty! Get me a gottle o’ gear, gah’on!’
(Christ’s eyes roll, and his head rolls from side to side. His eyebrows jiggle up and down.)
ABBOT and MONKS, shocked: Blasphemer! Such impiety!
LAYTON, appearing from behind the Roode, enraged: No! It is you who blaspheme! Peddling this false, crafty and subtle handling, to the dishonour of God, and illusion of the people!
(He accidentally knocks over giant vase of gillyflowers and roses.)
And why these blasted flowers everywhere?!
ABBOTT: Here at Boxley the people pay their rent in flowers. 24 February, 1538. St Paul's Cross, London.
The CARPENTER, an old man, is in a crowd of people at St Paul's Cross, gathered to watch the destruction of the Roode of Grace. On a platform, LAYTON, and others are with the Roode of Grace. There is a SOLDIER on stage with a bucket of water and a bar of soap.
CARPENTER, leaning on stick, to his granddaughter, who is agog: You know, I made the Roode of Grace! Oh yes, back in the day. The French took me as a Prisoner-of-War, back in the day of the King’s father – rest his soul! I was crammed in with thirty others into a stinking hole. The guards laughed at us, and said, pay us a ransom and you’re free!
GIRL: What did you do?
CARPENTER: Well, I said I’ll make you something the like of which you’ve never seen before, A living, breathing, thing, an automaton to match the finest in Europe –
GIRL: A what?
CARPENTER: Like a big puppet. With wires and wood and all. So they let me out, and gave me wood, and I whittled and fettled away. And when they saw it, they were so amazed they let me go, with it –
So I tied it to the back of a cart and off we go. I got to somewhere near Rochester when I was all of a sudden terrible thirsty. The horse was plodding along on its own in the right direction, so I thought, I’ll just pop in here to grab a quick half –
MAN in crowd, disbelieving: A likely story!
CARPENTER – and when I came out, blow me down if the horse hadn’t disappeared, with the Roode and all!
GIRL: Quiet! Look! They’re speaking!
LAYTON: People of London, behold this abomination, the Roode of Grace! We bring it here so that you may be disabused of idolatry, and to show you how the monks of Boxley of many years time out of mind did get great riches! How the monks did fatten their purses and lighten yours!
Signals to a soldier, who inserts himself inside the Roode. The crowd falls silent, apart from
GIRL, in a piercing voice: But do its eyes roll, granddad?
CARPENTER: Hush – LAYTON, waves hand: Observe the artifice!
(Christ lifts his head. The crowd gasps.)
The great blasphemy in the name of God!
(Christ’s eyes move left. The crowd titters. Christ shakes his head from side to side. LAYTON, signals angrily to the OFFICER in the Roode.)
Behold the foaming pestilence that comes from the false idol!
(Soap suds appear in Christ’s mouth, and trickle downwards, while Christ’s eyes roll and his jaws clack. The crowd laughs. CROMWELL, infuriated, gives a signal to the soldiers on stage. They raise hammers and chisels and attack the Roode.)
Let it be known that he who made this false idol was a great sinner!
GIRL, pointing at her grandfather: My granddad’s not a sinner! He’s a carpenter!
CARPENTER: No! Be quiet –
LAYTON nods to the soldiers. The crowd closes in. A small girl screams. The Abbot's Tale
29 June, 1539. Calais. The castle of Lord Lisle, Arthur Plantagenet, and Henry VIII’s uncle.
Arthur Plantagenet, LORD LISLE (aged 47) is reading a letter to his wife, Honor Glanville, LADY LISLE (aged 46). It is morning, in their bedroom. Lisle is in bed, looking tired. She looks bright and sits at her dressing table. She is already dressed.
LORD LISLE: Look, dear, Reginald says here that the Abbot of Glastonbury has not been spreading rumours about the King after all.
LADY LISLE, sarcastically, brushing her hair: Now, would that be the same Reginald Pole, son of the Countess of Salisbury, my dear? The one who took himself off to France, unable to support the King’s divorce? Your second cousin once removed – if we overlook your unfortunate illegitimacy?
LORD LISLE, crossly: The King himself overlooks it, and calls me uncle.
LADY LISLE, in mirror, to herself: As if we’re ever allowed to forget it! Lord, the tangled webs of these Plantagenets! So confusing!
LORD LISLE: But listen! Reggie says ‘I have examined him to the utterest, and can find no fault in him at all’. After all, he’s just an old man, dear, and not in the best of health –
LADY LISLE: Reggie says! Reggie – Cardinal Reginald Pole no less – is not to be trusted! He assisted the Pilgrimage of Grace, for goodness’ sake! This will not do. The abbot is a slanderous old goat. He says you are untrue to Henry – you cannot let this stand.
LORD LISLE, unhappily: I shall speak to Henry, dear.
GLASTONBURY, 19 September 1539. The House of the Abbot of Glastonbury, Richard Whiting.
Night. We see a house in Glastonbury, and in the distance, the Tor. One window is lit up. It is the Abbot’s study. The Abbot, RICHARD WHITING (aged 78) kneels – a small, very frail old man – while soldiers and LAYTON (aged 39) ransack the shelves around him.
LAYTON: Well, old man, we’ve been surveying your estate today. Truly it is the godliest house in all the land. Four parks! Four manor houses! A great lake filled with great pike, bream, and perch. And now we come to taste your hospitality. Hmm, what have we here? Books? What sort of books can they be, old man? WHITING, on his knees, head bowed: Not your kind of books.
LAYTON: Let’s see! Aha! Some pardons, and some papal bulls!
(He throws them down.) WHITING: They are holy books. Not your new fangylles!
LAYTON: What filth is this – a treatise against the King’s Divorce from Queen Katharine!
(He slams a book down in front of WHITING)
The counterfeit life of Thomas Beckett!
WHITING, raising his head How full you are of envy, malice and strife, Priest Layton.
16 November, 1539. Glastonbury.
A crowd standing in a semi-circle. The point of view is looking down on them. The people speak in turn.
WOMAN ONE: So I heard all about it from my cousin. The Crafty Cardinal – Glastonbury himself – plotted with the Abbot of Reading– and was it the Prior of Colchester? – with John Onyon, Bachelar Gyles, the Blynde Harper of Grey Friars, that Savoy priest Master Manchester, Dr Holyman, Roger London, John Rugg –
MAN ONE: – truly, what a ragman’s roll of old rotten monks, rusty friars, and pockeyed priests!
WOMAN ONE: Anyway it was all a huge conspiracy! Glastonbury gave pestilent and cankered counsel to overthrow the prince –
MAN ONE: – a prince most puissant!
WOMAN FOUR: They say they found gold and plate the old Abbot had hid in the walls, vaults, and other secret places. Every day they found more until they tore the Abbey down.
WOMAN THREE: What a beggarly, monkish merchant Whiting was! Even though the King had given him 7,000 marks a year!
(We see the Abbey Gate with pools of blood leading in and beyond.)
LAYTON: We drew him through the town upon a hurdle and executed him on the Tor Hill. He took his death patiently, asking pardon of God and the King for his offenses. What they were, he did not say. And now his body is divided. One quarter stands at Wells, another at Bath, at Ilchester and Bridgewater the rest – and here’s his head upon the Abbey gate. Lord Lisle was arrested on charges of conspiracy in 1540, as part of charges laid against a number of Plantagenets in France, who were accused of plotting Henry's downfall. Lisle was kept in the Tower of London for two years and then released. He died on his journey home.
In 1534 Glastonbury Abbey signed the Act of Supremacy, and the Abbot was told that the Abbey was safe from dissolution. But by 1539 it was a notable exception. Glastonbury Abbey was dissolved as part of the 1539 Act for the Dissolution of the Greater Monasteries. The Commissioner’s Tale
An image of Henry VIII, silhouetted against stained glass and a portrait of his fourth wife, Catherine Howard.
LAYTON: I know I should be there, Bartelot, at the King’s marriage to Catherine Howard. But I told him I was ill.
28 July 1540. Rectory of Harrow-on-the-Hill. LAYTON (aged 40) is standing on top of a hill, with a hooded goshawk on his arm. Behind him, an orchard. Behind him, his servant, BARTELOT (aged 37).
BARTELOT: Are you ill, my lord?
LAYTON: I have a heavy heart today.
(A pause.)
We had some good times, though, didn’t we?
(Another pause.)
Remember that time we went to Langdon? When I bashed down the abbot’s door in the middle of the night with a pole-axe?
BARTELOT: Very clearly, my lord.
LAYTON: Hah! I dashed it to pieces! And that little dog of his, that would not stop barking. So in I go, Bartelot, pole-axe raised, for I know the abbot is a desperate knave, and it is the middle of the night, you see – when all of a sudden out rushes his whore, alias his gentlewoman, and the tender damsel rushes straight into your arms out the back!
LAYTON: Eight days for her in a cage in Dover, if I recall right. Happy days, Bartelot.
BARTELOT: Happy days, my lord.
LAYTON: Oh, and the worst of them! Those canons at Newark –
BARTELOT: I don’t recall, sir, what they did – LAYTON: Well, truth be told, nothing much – so I accused them of sodomy and adultery, and from then went on to smaller things to see what I could find. They were the most obstinate canons that ever I knew!
LAYTON: But some of them really were up to no good! Remember Syon? The Bishop fixing up his cell for his wenches to pass to and fro at night! I remember the locksmith as he confessed to making keys –
BARTELOT: Taking out bars in the window –
LAYTON: Oh yes! Those letters from a nun to him – he told her that if she submitted her body to him during confession it would not count.
(Layton laughs. The hawk pecks at his hand.)
LAYTON: What untruth and dissimulation we found! What falsehood, what bribery, spoil and ravine with crafty colours of bargains! And do you recall that time in ’35 at Canterbury – when I almost burnt to death in my bed?
BARTELOT: Oh yes, sir, like it was yesterday.
LAYTON: Some fool servant must have placed a candle too near the rushes. Whoosh! That was nearly the end of me. Imagine!
BARTELOT: Imagine that, my lord.
LAYTON: Brrr! I feel someone stepping on my grave. So much death.
LAYTON, strokes bird’s head: I feel Cromwell’s spirit here. He loves – loved – hawks so. I always made sure to make him feel at home. You shall have twenty beds in the town, I would write, and a dozen more besides in the parsonage. I sent him partridges, freshly killed. Simon the Apostle himself was never so glad to see Christ his master, as I was to see my master Cromwell in my house.
I was always his most assured poor priest–
(He unhoods the bird)
Cromwell’s alter ego I.
BARTELOT, holding the bird’s chain: Now, my lord?
LAYTON: Now. And now Cromwell himself is in the Tower. Mercy, mercy, mercy! He cries.
(The bird is unchained. It flies off, high in the sky, until it is a just a speck.)
Thomas Cromwell was executed at the Tower of London on 28 July 1540, the day of Henry VIII’s marriage to Catherine Howard.
Richard Layton continued to have a successful career in Henry’s administration. In 1543 he was appointed as ambassador to Paris. In June of 1544 he died of unknown causes in Brussels. Notes
Timeline:
Death of Cardinal Wolsey November 1530 Thomas Cranmer consecrated as Archbishop of Canterbury March 1533 Henry marries Anne Boleyn January 1533 Act of Succession April 1534 Act of Supremacy November 1534 Treason Act November 1534 Cromwell appointed Chancellor of the Exchequer April 1533 Thomas More is executed July 1535 Cromwell is appointed as the king's vicegerent July 1535 Valour Ecclesiasticus and start of the visitation of the monasteries 1535 Act for the Dissolution of the lesser monasteries February 1536 Louth Rebellion and Pilgrimage of Grace October 1536 Execution of Anne Boleyn 19 May 1536 Henry marries Jane Seymour 30 May 1536 Act for the Dissolution of the greater monasteries 1539 Execution of Thomas Cromwell July 1540
All of the stories within this book were inspired by documents held by The National Archives. The documents are open to the public and can be found through The National Archives' catalogue using the following document references:
SP 1/22 SP 1/31 SP 1/55 SP 1/80 SP 1/82 SP 1/92 SP 1/95 SP 1/96 SP 1/97 SP 1/98 SP 1/102 SP 1/106 SP 1/107 SP 1/108 SP 1/126 SP 1/129 SP 1/130 SP 1/131 SP 1/132 SP 1/133 SP 1/140 SP 1/141 SP 1/153 SP 1/241 SP 3/13 SP 5/4 KB 27/997 KB 27/963 C 65/143 E 344/22 E322/12 E164/25 MP CC1/7
Key:
SP = State Paper KB = King’s Bench C = Chancery E = Exchequer MP = Maps and Plans
Script: Carol Adlam
Illustrators:
Saffiya Abdul-Mujib Shannon Bowie-Mangan Agna Chunbang Sam Cunningham Isobel Hartnett Robyn King Matthew Lee Hema Rajput
Producer: Ela Kaczmarska
Design: Rosie Morris
With thanks to:
The Friends of the National Archives The National Archives Education Service Sean Cunningham Marianne Wilson In the summer of 2017, eight students arrived at the National Archives to embark upon a project which would become this book. Each a talented artist, aged between 17 and 20, they were given stories of the Dissolution of the Monasteries to illustrate, based on historical records held within the archives.
Written by Carol Adlam, each story tells the tale of a real event from the Dissolution, through the experiences of the people who would have been there. From the lowliest builder to the Abbot of Lewes Abbey, the tales show the wide ranging effects of Henry VIII’s determination to dismantle the existing Catholic church in the formation of the Church of England.
Each student could illustrate their tale in their own style, using any medium they desired. These tales are now presented in this graphic novel to bring you the story of The Chronicles of the Dissolution.
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3212acf3e2b8ce619d26f3f3774bcfc00f9341c5 | To understand the relation between international trade and poverty in Peru, it is fundamental to explore how trade impacts on agricultural activities since most of the poor depend on them to sustain their livelihoods.
Evidence from Peru shows that the FTA with the US could produce a financial gain of US$ 575 millions in urban Peru, but losses of US$ 158 in rural Peru. This situation highlights the need for pro-poor complementary policies that can secure the livelihoods of the poor.
An increase in rural poverty will have collateral effects as the deterioration of family expenditure in education, while also a massive school drop out that will push children and adolescents to engage in economic activities. Access to health services may also be affected.
The establishment of specific product subsidies is not convenient to tackle the potential negative impacts of the FTA in Peru. A better policy option would be that conditional-cash transfers programs—as Juntos—focus their actions in generating economic opportunities for the poor affected by the FTA.
Introduction
The link between trade liberalisation and economic growth does not appear to be conclusive. For some authors, liberalisation favours economic growth, while others indicate that it is an export-led strategy, rather than the elimination of trade barriers for imports, that promotes economic growth.
In Peru, given that the great majority of the poor depend directly or indirectly on agricultural and farming activities in order to sustain themselves, in order to evaluate the impact of international trade on poverty we need to examine how trade influences these activities. What is the effect of trade liberalisation on the agricultural and farming sectors in Peru? The answer to this question is complex, because in our countries tradable agricultural and farming goods, that is, products for export or for the substitution of imports, coexist with non-tradable goods, or products that are exclusively for the domestic market and do not compete directly with imports.
Meanwhile, globally, the unilateral international trade liberalisation in the 1980s and the beginning of the 1990s has been replaced by free trade agreements between two or more countries. In the case of our country, a free trade agreement (FTA) has been signed with our principal trading partner, the United States of America.
Do traditional trade policies, which constitute unilateral liberalisation to facilitate imports from the rest of the world, and new trade policies, based on bilateral agreements, contribute to the development of the agricultural and farming sector, and, thus, to poverty reduction?
1/ Principal professor in the Economics Department of the Pontifical Catholic University of Peru. The experiences of East Asia and, recently, China have framed the discussion: is it the insertion in international markets through exports, rather than opening up to imports, that favours economic growth? »
The objective of this article is to answer this question. In the following section, I will present a recent analysis that connects trade policy and poverty, at the international level. In section 2, the same issue is discussed, but in the Peruvian case. In section 3, I will review Peru’s FTA with the United States and its implications for poverty. Finally, section 4 will present some conclusions and implications for economic policy.
1. Trade policy and poverty: international evidence
The link between trade liberalisation and economic growth is far from clear. According to one school of thought, trade liberalisation favours economic growth. According to these authors, the countries that are the most open to international trade grow more than those that are less open (open countries converge more rapidly to the level of developed countries). In this way, the poverty reduction observed in recent decades, economic growth, and the increasing globalisation of trade would be considered to be aspects of the same phenomenon.
However, there are other economists who are less convinced of the benefits of international trade. Authors such as Rodrik (1995) and Stiglitz (2006), among others, caution that the relationship found between trade liberalisation and growth could be spurious, due to the difficulty of establishing an exogenous indicator of trade liberalisation. Moreover, these authors claim that it is export-led strategies, not the elimination of trade barriers, that act as the motor for growth. The notable growth of the Chinese economy over the past few decades contributes to the strength of this analysis.
The experiences of East Asia and, recently, China have framed the discussion: is it the insertion in international markets through exports, rather than opening up to imports, that favours economic growth? The economic growth in China of the past 20 years has certainly contributed to an important degree to 400 million people rising out of poverty.
Trade policy, thus, under certain conditions, can contribute to economic growth. And what does the international experience tell us about the links between economic growth and poverty reduction?
According to Mendoza and Garcia (2006), at the international level, the positive relationship between macroeconomic performance, as measured by GDP, and poverty, as the percentage of the population whose levels of consumption or income do not reach the cost of the basic basket of goods to satisfy their needs, is evident. According to Dollar and Kraay (2001), economic growth is fundamental for permanent poverty reduction. The Chinese experience of notable poverty reduction, as depicted by Sachs (2006), is another convincing example of the importance of economic growth. Finally, according to Sala-i-Martin (2007), over the past three decades, global economic growth has accelerated and poverty rates have been reduced to about two-thirds of prior levels.
2. Trade policy and poverty: The Peruvian Case
Trade policy in Peru has been determined by essentially macroeconomic needs, that is, to open the economy to international trade, correct external disequilibria or increase protections for local industry, and not for its probable effect, in one way or another, on poverty and inequality.
The government of Velasco Alvarado (1968-1975) deepened the import substitution model inherited by his administration, by imposing considerable tariffs and a bundle of non-tariff measures, including the prohibition of a large group of imports and the requirement of licenses to import certain goods.
2/ For a balanced treatment of this issue, see McCulloch, Winters and Cirera (2002). 3/ Sachs and Warner (1995), Edwards (1997), Frankel, Romer and Cyrus (1996), Berg and Krueger (2003) and Sala-i-Martin (2007). 4/ Sachs and Thye (1997). 5/ See for example Rojas (1996, 1997) and Morón et al (2005) for a description of the trade policy of recent decades. Towards the end of the 1970s, the turn towards greater trade liberalisation began, with the elimination of the National Registry of Manufacturing, the dismantling of exchange controls and the reduction of the average tariff rate to approximately 40% in 1979, which was interrupted by the debt crisis and international recession. These events forced the government to increase the average tariff rate, and, with the election of Garcia in 1985, revive prohibitions, licensing regimes and differentiated exchange rates.
This development model that emphasised the domestic market was eliminated in the beginning of the 1990s, during the Fujimori administration, through one of the most radical liberal reform movements of Latin America. Between 1990 and 1991, the dominant trade structure was demolished, tariff rates were drastically reduced, quantitative controls on imports were eliminated, and almost all non-tariff restrictions as well as the differentiated exchange rate system were repealed.
Given that the vast majority of the poor in Peru directly or indirectly depend on agricultural and farming activities for their survival, it is appropriate to focus attention on this sector in order to assess the effects of international trade on poverty.
What is the effect of trade liberalisation, understood as a unilateral tariff reduction, on the agricultural and farming sector in Peru? The answer to this question is complex, because, in Peru, there are many agricultural and farming sectors.
In aggregate terms, one can distinguish between two types of agricultural and farming activities. The tradable agricultural and farming activities, whether exportable or importable, where prices are determined by international prices, the exchange rate, and by tariffs and subsidies, and an excess of supply or demand are faced with more imports or exports, and non-tradable agricultural and farming activities, that are produced exclusively for the domestic market and that do not face foreign competition, where supply is given in the short term and prices are flexible and adjusted based on the excess of supply or demand.
In this framework of general equilibrium, tariff reduction for imported goods does not only affect price parity of imports and exports, but also distinct functions of supply and demand of non-tradable agricultural goods.
A reduction in tariffs can cause a decrease, in the first place, in the price of importable agricultural and farming goods, which would benefit consumers, by lowering prices for those that have access to markets; but it would harm the producers of importable goods, by reducing income from sales of these producers. Given that agricultural and farming tradable goods are substituted by non-tradable agricultural and farming goods (Hopkins, 1994), the price reduction of importable goods causes a drop in the demand for non-tradable agricultural and farming goods, depressing their prices and affecting the income of producers of non-tradable agricultural goods.
In this way, trade liberalisation can harm not only producers of agricultural and farming goods for import, but also producers of non-tradable goods.
Thus, the beneficiaries of import liberalisation would be agricultural and farming exporters, because liberalisation can cause a drop in the price of their imported inputs for the productive process.
«Given that the vast majority of the poor in Peru directly or indirectly depend on agricultural and farming activities for their survival, it is appropriate to focus attention on this sector in order to assess the effects of international trade on poverty.»
«The price reduction of importable goods causes a drop in the demand for non-tradable agricultural and farming goods, depressing their prices and affecting the income of producers of non-tradable agricultural goods»
6/ See Rossini (1991). 7/ According to Mendoza (1992, 1994). 3. The Free Trade Agreement with the United States and poverty
Over the past few years, the unilateral liberalisation for international trade of the 1980s and the beginning of the 1990s has been replaced by free trade agreements between two or more countries. According to Sala-i-Martin (2007), currently, 40% of world trade is supported by free trade agreements; there are approximately 200 free trade agreements in operation and another 60 under negotiations.
Peru has signed a free trade agreement (FTA) with its principal trade partner, the United States. The FTA constitutes the deepening of a process of trade liberalisation which has been underway in Peru since 1990. Subsequently, the Andean Trade Preferential Act (ATPA) was signed in 1991 and the Program for Andean Trade and the Andean Trade Programme and Drug Eradication Act (ATPDEA) was signed in 2002.
With this treaty8, our country, rather than promoting a permanent extension of the ATPDEA and a gradual reduction, over a period of up to 17 years, of the majority of tariffs for those Peruvian agricultural and farming products considered sensitive, has offered concessions by diminishing import tariffs for American products. The treaty also accepts that the United States will maintain unaltered non-tariff restrictions for Peruvian products and authorises the protection of test data for pharmaceutical and chemical products.
What is the probable effect of this group of agreements on the agricultural and farming sector and on poverty?
Some analysts sustain that the FTA will provoke a greater drop in prices of the basic products of the food basket, massively subsidised by the U.S., such as grains, milk, oil products, sugar and fibres and, as a result, will depress the prices of goods produced in traditional agriculture9. Furthermore, since the FTA requires the dismantling of the free price zone system, the prices of products such as rice, sugar, milk, and, to a lesser degree, yellow corn, will be reduced, aggravating the situation for agricultural producers of these import goods.
Because the non-tradable agricultural and farming goods are, in general, substitutions for tradable goods, the prices of these non-tradable products, widely produced in the South Sierra, such as potatoes, barley, and white amilaceo maize will also be reduced.
In this way, the terms of trade for importable and non-tradable agricultural goods would deteriorate. The new agreement will likely benefit agricultural exporters, due to the opening of the American market for their products and the decrease in tariffs of some imported inputs.
In a similar vein, Escobar and Ponce (2006) affirm that the effects of the FTA in the short term could be fairly heterogeneous among geographic areas and population groups with different characteristics. A simulation exercise indicated that the FTA would produce profits of around US$ 575 million in urban Peru, but losses of US$ 158 million in rural Peru.
The increase in rural poverty would have several collateral effects. As the income of rural households drop, school attendance could be negatively impacted by the combined effect of a reduction in education spending and increased truancy, due to the need for children to generate income to help support the family. The other effect of the reduction of income in rural areas is the impact that it will have on health in rural populations, by affecting the capacity of the poor to access health services.
4. Conclusions and implications for economic policy
What are the effects of trade policy on economic growth? International trade favours economic growth
8/ Regarding this issue, see Fairlie (2006) and Tello (2006). 9/ Zegarra (2005) when the emphasis is placed on exports, before the unilateral reduction of tariffs.
And what is the relationship between economic growth and poverty? In the literature reviewed here, the relationship between economic growth and poverty is indeed solid; all economies that have managed to significantly reduce poverty have also exhibited sustained growth, through international trade or by other means.
And what is the link between trade policy and poverty? Given that the great majority of the poor in Peru depends directly or indirectly on agricultural and farming activities for their survival, in order to understand the link between trade policy and poverty in Peru, we must first analyse the relationship between trade policy and the agricultural and farming sector. When trade policy constitutes an opening for imports, rural poverty can be aggravated.
What would be the effects of the FTA with the U.S. on poverty? The official government claim is that the FTA is essentially an opening of the North American market for Peruvian products. However, the FTA is not only an opening of the North American market for Peruvian products. The opening of the North American market was achieved with the ATPDEA. The number of additional items that were not present under the ATPDEA and that were consolidated under the FTA is rather limited. As a result, apart from the fact that the FTA solidified the opening of the North American market, which was transitory with the ATPDEA, the FTA is, essentially, an opening for American imports, with negative consequences for the producers of non-tradable agricultural and farming goods.
As a result, there should be special attention paid to the study of compensatory policies for those who are conceptualised as the “losers” of the FTA. The study of the Mexican and Chilean experiences could be very useful in this regard. As Grade cautions (2006) in a critique of the Mexican program to compensate producers of wheat, corn and cotton who could be affected by the FTA with the U.S., the fact that compensation was directed towards specific products, and not towards all the producers, generated an unforeseen and undesirable consequence, because it provided incentives to produce less profitable agricultural goods, despite having expanded markets for much more profitable goods.
Under these conditions, the recommended solution is for programs of conditional monetary transfers, in order to create a social support network for vulnerable populations in the rural sector. Social protection programs such as JUNTOS could be expanded and should concentrate on promoting opportunities and economic capabilities for those affected by the FTA. ◆ BIBLIOGRAPHY
Berg, Andrew and Anne Krueger 2003 Trade, Growth, and Poverty: A Selective Survey, IMF Working Paper No 30
Dollar, David and Aart Kraay 2001 Trade, Growth and Poverty. World Bank.
Edwards, Sebastian 1997 Openness, Productivity and Growth: What do we really know? NBER Working Paper Series No 5978, March.
Escobal, Javier and Carmen Ponce 2006 Liberalización del comercio y el bienestar de la niñez: evaluando el impacto del Acuerdo de Libre Comercio entre Perú y Estados Unidos, GRADE, Perú.
Frankel, Jeffrey, Romer, David and Teresa Cyrus 1996 Trade and Growth in East Asian Countries: Cause and Effect? NBER Working Paper Series No 5732, August.
Grupo de Análisis para el Desarrollo (GRADE) 2006 Vulnerabilidad de los hogares peruanos ante el TLC. En CIES, CIP, Congreso de la República e IPAE, Selección de documentos sobre el Tratado de Libre Comercio con Estados Unidos de América. Lima.
Hopkins, Raúl 1994 Agricultura, tasa de cambio y política macroeconómica en una economía en desarrollo: el caso peruano. IEP, Documento de Trabajo Nº 62, Lima
McCulloch, N., Winters, A., and X. Cirera 2002 Trade Liberalization and Poverty: A Handbook, CEPR-DP14, London
Mendoza, Waldo 1992 Políticas macroeconómicas y agricultura: ¿Qué sabemos? in Debate Agrario No 13, CEPES, Lima. 1994 Agricultura y estabilización macroeconómica. Perú, 1990-1993. in Investigación Agraria, volumen 9, número 3, Madrid.
Mendoza Waldo and Juan Garcia 2006 Perú 2001-2005: Crecimiento económico y pobreza. Documento de Trabajo Nº 250, Departamento de Economía-PUCP.
Morón, E., M Bernedo, J. Chavez, A. Cusato and D Winklered 2005 Tratado de libre comercio con los Estados Unidos: una oportunidad para crecer sostenidamente, CIUP-IPE, Lima
Rodrik, Dani 1999 The New Global Economy and Developing Countries: Making Openness Work, Johns Hopkins University Press, Washington DC.
Rojas Jorge 1996 Política comercial y cambiaria en el Perú, 1960-1995. Fondo Editorial PUCP. 1997 La política comercial peruana reciente. En Economía No 39-40, PUCP, Lima
Rossini, Renzo 1991 Liberalización del comercio exterior en el Perú. En Foro Económico: Liberalización del comercio exterior en el Perú. Portocarrero, Javier (Editor), Fundación Friedrich Ebert, Lima.
Sachs, Jeffrey and Andrew Warner 1995 Economic Convergence and Economic Policies, NBER Working Paper Series No 5039, February.
Sachs, Jeffrey and Wing Thye 1997 Chinese Economic Growth: Explanations and the tasks ahead, in Joint Economic Committee, China’s Economic Future: Challenges to US Policy. M. E. Sharpe, USA
Sachs, Jeffrey 2006 El fin de la pobreza. Cómo conseguirlo en nuestro tiempo. Arena Abierta, México
Sala-i-Martin, Xavier 2007 Economic Integration, Growth and Poverty. Inter-American Development Bank. Integration and Trade Policy Issues Paper.
Stiglitz, Joseph 2006 Cómo hacer que funcione la globalización, Taurus-Pensamiento, México.
Tello Mario 2005 ¿Es necesaria la firma del TLC Perú-EEUU? Condiciones y lecciones. Economía y Sociedad No 58, Lima. 2006 Marco técnico sobre el impacto del TLC Perú-Estados Unidos. En CIES, CIP, Congreso de la República e IPAE, Selección de documentos sobre el Tratado de Libre Comercio con Estados Unidos de América. Lima.
Zegarra, Eduardo 2005 El TLC con Estados Unidos y la agricultura peruana: reflexiones en torno a costos, beneficios y desarrollo agrario. CEPES, Debate Agrario.
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61e29e4eaa14efa2000b12b2f272e9731eb57ee2 | # Internal Audit Report
## Community Infrastructure Levy (CIL) and Section 106 (S106) – Phase II, Expenditure, January 2018
| To: | Deputy Chief Executive, LBB | Associate Director, Planning, Re | |-----|-----------------------------|----------------------------------| | | Strategic Director - Environment, LBB | Head of Performance and Risk, Re | | | Director of Growth and Development, LBB | Programme Support and Controls Manager, Re | | | Director of Finance, LBB | Head of Strategic Planning, Re | | | Commissioning Lead - Planning, LBB | Infrastructure Planning Team Manager, Re | | | Strategic Lead - Commercial, LBB | Service Director - Highways, Re | | | Commercial Advisor, LBB | Head of Business, Enterprise and Skills, Re | | | Head of Finance, LBB | Operations Director, CSG | | | Finance Manager, LBB | Head of Finance – Closing and Monitoring, CSG | | | Operations Director, Re | Head of Finance, CSG |
| From: | Internal Audit Executive, LBB |
We would like to thank management and staff of Re, CSG and LBB for their time and co-operation during the course of the audit. Executive Summary
| Assurance level | Number of recommendations by risk category | |-----------------|------------------------------------------| | Limited Assurance | Critical | High | Medium | Low | Advisory | | | - | 3 | 1 | 2 | 1 |
Scope
The purpose of this two phase review was to review the design and operating effectiveness of key controls associated with the administration of the Council’s CIL scheme and S106 agreements. Phase I, completed in May 2017, focussed on income. This phase (Phase II) focussed on expenditure, benefits monitoring and governance.
Summary of findings
We found that RE and Council management are proactively addressing some known issues with the controls and processes around CILs and S106. This includes:
- Recruitment in 2016/17 of experienced key staff into the RE Planning Obligations team.
- Improvement of oversight and governance of CIL infrastructure spending through a CIL and S106 Officers Group (CSOG). This is chaired by the Director for Development and Regeneration, was established in April 2017 and has met monthly since that time (excluding August). To secure CIL and S106 funding, officers write and present proposals to the Group which considers the requests and then makes a recommendation to approve or reject the proposal when it reaches the Assets and Capital Board. The Group are also responsible for reviewing the progress of S106 projects and expenditure and to review the progress of allocation and expenditure of neighbourhood CIL. Due to the recent formation of the Group we were unable to comment on the operating effectiveness of this control at the time of the audit, although we did find evidence to confirm that bids were being proposed and approved in line with our expectations.
- Management confirmed that they were undertaking a reconciliation of all CIL and S106 schemes to ascertain allocation and expenditure agreed to date.
- The CIL and S106 schedules were maintained within Excel spreadsheets to assist in the management of charges and agreements. At our Phase I audit we commented that the manual nature of the process heightens the risk of data accuracy issues arising due to fraud or error. Management confirmed that the Exacom database system has been procured and is currently being implemented with CIL notices now being issued through Exacom. The Strategic Planning Infrastructure Team are currently migrating information from the manual spreadsheets into Exacom with approximately 90% and 10% of, respectively, the historic CIL and S106 data now being held within Exacom (November 2017). The implementation of the Exacom system will reduce reliance on the manual monitoring spreadsheet and will facilitate more effective monitoring and oversight through improved reporting.
We found that improvements needed to be made with regard to the monitoring of CIL and S106 expenditure and identified a number of control weaknesses. These should be addressed as part of the work being undertaken by management to improve this area.
This audit has identified 3 high, 1 medium and 2 low risk findings. We have also raised one advisory recommendation.
We identified the following issues as part of the audit:
**Roles, Responsibilities and Decision Making (finding 1, high rated)**
- There are a number of different teams involved in the administration of Community Infrastructure Levy (CIL) and S106 expenditure. Processes involve several departments within the Council, Re, CSG Finance and HB Public Law. Due to the number of teams involved in the process and the number of individuals within some of those teams, there are a number of dependencies and we found a lack of clarity and awareness around respective responsibilities in the administration, allocation and draw down of CIL and S106 expenditure.
- Problems were exacerbated by key posts within the Planning Obligations team being vacant during part of 2015/16 and 2016/17, and turnover of staff in other areas.
- We also found a lack of clarity over the authorisation required for CIL/S106 funding drawdowns.
**CIL and S106 Expenditure and Monitoring (finding 2, high rated)**
We inspected the S106 Schedule and found a lack of clarity around expenditure information in the S106 monitoring schedule. A full reconciliation of the data is underway to confirm whether up to £1,459,350.44 has been spent within required time periods. The move to the EXACOM system is facilitating reconciliation, but this key task is incomplete and is necessary to ensure issues are remedied. Without resolution of this matter the funds could potentially be reclaimed. A clear position on the matter and resolution of issues is required rapidly.
**Specific development non-financial obligation tracking and verification (finding 3, high rated)**
We selected a sample of 12 specific S106 schemes and for the 6 where there were non-financial development obligations we traced to ensure the delivery of these had been appropriately verified. We found exceptions with 2/6 schemes (33%). The exceptions related to Affordable Housing, Travel Plans and Apprenticeship schemes. The governance arrangements were not clear in this area in that agreements had been made with developers but these were not clearly documented and had not been reported to Committee.
**Administrative CIL (finding 4, medium rated)**
We found a number of issues relating to the treatment of CIL to be spent on administrative expenses:
- At the time of the audit, for administrative expenses relating to Barnet CIL there was a lack of evidence and no clear audit trail to confirm the administrative CIL expenditure made to date and to ensure it had been in line with the legislation. For administration expenses relating to Mayoral CIL we found that £127,560.54 related to a narrative of ‘Designated and Regulatory Services Management’. We were not provided with a detailed breakdown of this cost and therefore cannot provide assurance that this expenditure specifically related to CIL administration.
We found that funding relating to CIL administration expenditure had been carried forward from 2016/17 but this was not in-line with the legislature.
Identification and management of infrastructure investment needs and priorities (finding 5, low rated)
Regulation 123 of the Community Infrastructure Levy Regulations requires charging authorities to set out a list of those projects or types of infrastructure that it intends to fund, or may fund, through CIL. We found that it is not clear how the Council’s Regulation 123 list has been formulated and whether it has been informed by an up to date and detailed infrastructure needs assessment for the Borough.
Publication of the Regulation 62 report (finding 6, low rated)
We found that the 2015/16 Regulation 62 report had not been published until the summer of 2017 despite a statutory deadline of publication by 31st December 2016.
## 2. Findings, Recommendations and Action Plan
| Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | 1. | **Roles, Responsibilities and Decision Making**\
*General roles and responsibilities – We found:*
- There are a number of different teams involved in the administration of Community Infrastructure Levy (CIL) and S106 expenditure. Processes involve several departments within the Council, Re, CSG Finance and HB Public Law as well as several boards and officer groups; and
- Due to the number of teams involved in the process there are a number of dependencies and a lack of clarity and awareness around respective responsibilities in the administration of CIL and S106 expenditure.
*Authorisation of CIL/S106 funding drawdown*\
At the time of the audit, Assets and Capital Board (ACB) reviewed schemes/projects for inclusion on the capital programme. The capital budget/programme is approved at Policy & Resources Committee. This governance and decision making process authorises the commencement of the capital project, it does not authorise the funding source.
Whilst the CIL/S106 officer group (CSOG) reviews the proposed drawdown of CIL/S106 funds to support infrastructure investment we found ambiguity around where these drawdowns are authorised and who has the requisite decision making powers for drawdowns. For example there was ambiguity around whether a delegated powers report was necessary to support drawdowns being If key stakeholders are not identified and engaged in decision making and oversight of the CIL fund then amounts may not be used in line with local infrastructure needs resulting in resident dissatisfaction. | **High** | a) The Council, RE and CSG Finance will agree a protocol all areas relating to the expenditure of CIL and S106 monies to ensure everyone is aware of their roles and responsibilities and accountabilities and ensure there is effective oversight between the three parties. This will be prepared by Re in its role “providing support for the end-to-end [Planning Obligation] process with support from CSG and LBB”.\
The Deputy Chief Executive will formally approve and issue the protocol document.\
One agreed and finalised HBPL will be provided with a copy so they are aware of the agreed processes that will be followed by Re, CSG and LBB relating to the agreed expenditure of CIL and S106 monies.
**Responsible officers:**\
Deputy Chief Executive, LBB\
Commissioning Lead - Planning, LBB\
Head of Strategic Planning, RE\
Head of Finance, CSG | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | made. | | | Target date: 30 April 2018. | | | We selected four capital schemes, two which were to be paid for wholly or in part by S106 and two by CIL. In the Capital Plan reported to the Policy & Resources (P&R) Committee neither of the two schemes to be funded by CIL was reported as such; they were noted as being funded from ‘Capital Receipts’. This was an error in the drafting and approval of the P&R papers as this should have read ‘Capital Reserve’ or ‘Infrastructure Reserve’ (i.e. CIL or New Homes Bonus). We consider there is an opportunity to increase oversight of CIL spending by more clearly documenting schemes within P&R Committee papers which are to be funded by CIL. | | | b) The Schemes of Delegation for the Deputy Chief Executive, the Commissioning Director for Environment and the Director of Resources will be reviewed by LBB Commissioning to ensure clarity around who has the delegated authority to draw down CIL and S106 capital and revenue funding. | | | | | | Responsible officers: | | | | | | Deputy Chief Executive, LBB | | | | | | Commissioning Lead - Planning, LBB | | | | | | Target date: 30 April 2018. | | | | | | c) The Schemes of Delegation will then be followed when CIL and S106 funding is drawn down i.e. depending on value this will be decided by the appropriate Area Committee / Chief Officer / Summary DPR to enable funds to be spent effectively and efficiently. | | | | | | Responsible officer: Assistant Director of Finance, CSG | | | | | | Target date: 30 April 2018. | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | | | | d) When providing finance clearance, CSG Finance and LBB’s Head of Finance will ensure Policy & Resources Committee papers clearly indicate schemes to be funded by CIL. Any substitutions will be clearly reported through the budget update reports and Re will be informed. The process to be followed will be agreed in the protocol document (see recommendation 1(a)). | | | | | | Responsible officers: | | | | | | Head of Finance, LBB | | | | | | Assistant Director of Finance, CSG | | | | | | Head of Finance, CSG | | | | | | Target date: 30 April 2018 | | 2. | **S106 and CIL expenditure and monitoring** | If S106 amounts are not used in line with the terms of agreements and relevant legislation then the Council may have to repay funds to developers. If the Council does not make use of available funds then the planned benefits of the CILs and S106 agreements may not be realised. | High | a) RE Management and CSG Finance will ensure the reconciliation of RE monitoring data with CSG Integra data is completed. This will include cross-referring to the Uniform system. | | | **S106** – S106 income is held (on trust) by the Council on behalf of developers. It is managed on the Council’s behalf by CSG and RE. A monitoring spreadsheet is maintained by the RE Planning Obligations team that captures all S106 schemes in place. The schedule captures key information regarding schemes in place including key conditions such as expiry dates. Upon reviewing a sample of 12 specific S106 schemes to confirm that the details recorded in the tracker were accurate as well as reviewing the tracker and considering how the schedule supports the management of S106 schemes we found: | | | Responsible officers: | | | | | | Head of Strategic Planning, RE | | | | | | Head of Finance, CSG | | | | | | Target date: 28 February 2018 | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | - There is no proactive, systematic review of the schedule to identify and manage schemes that are approaching their expiry date.
- Some schemes had officially 'expired' before balances have been spent; therefore there is a risk that developers could ask for the S106 funding to be returned. Management have stated that in practice this rarely happens;
- Upon reviewing the schedule 69 S106 schemes were listed as having an unspent/unallocated balance which in aggregate totals £1,459,350.44;
- Management highlighted there are discrepancies between the records held between Re and CSG relating to income, allocations and expenditure against S106 agreements. There is an ongoing programme to reconcile all income received against individual S106 agreements and associated expenditure to verify the actual position to inform future allocations and drawdowns;
- For one S106 scheme the expiry date field had been completed with a '?' meaning it was not possible to determine the expiry date from the schedule and therefore does not facilitate effective oversight and monitoring;
- For 1/12 (8%) a copy of the original S106 agreement to confirm that details held within the schedule were complete and accurate; and
- For 1/12 (8%) the details of the expiry date within the tracker did not match that within the agreement. | | | b) The Chair of the CSOG will ensure that CSOG meetings include discussion of funds coming to the end of their expiry date.\
**Responsible officer:** The Chair of the CSOG\
**Target date:** 28 February 2018.\
c) A protocol will be agreed which details the proactive engagement which will be undertaken with services across the Council to ensure effective awareness of available funds and that suitable projects are identified and progressed in a timely manner (see recommendation 1a). This will ensure that there is effective oversight of said funds and they can be effectively monitored to reduce the likelihood of reaching expiry date.\
**Responsible officers:**\
Deputy Chief Executive, LBB\
Commissioning Lead - Planning, LBB\
Head of Strategic Planning, Re\
Head of Finance, CSG\
**Target date:** 30 April 2018. | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | the Planning Obligations email box. This is picked up by Planning Obligations team who incorporate the agreement into the schedule. As part of our testing, to give assurance over the completeness of the S106 schedule maintained by the Planning Obligations team, we asked HB Public Law (HBPL) for a list of the S106 cases they have worked on. We would then have reconciled this with the S106 Schedule used by Planning Obligations. However, at the time of drafting this report HBPL were yet to provide this list. It should be noted the Council has agreed to fund (from CIL administration contributions) and Re is now implementing the Exacom system to support stronger CIL and S106 administration. This has the possibility to alleviate some of the weaknesses identified above through reducing reliance on an unsecured shared monitoring spreadsheet as well as facilitating the potential for more effective monitoring and oversight through improved reporting. Management assert that the system will be up and running by Q4 2017/18. **CIL** - CIL income is held (owned) by the Council and managed on the Council’s behalf by CSG and RE. Since the inception of the CIL scheme in 2013 the Council has collected approximately £33m to be invested in local infrastructure. At the time of audit testing approximately £11m has been spent to date and £22m remains to be spent and has been allocated within the Capital Programme. The Capital Programme across the Council has suffered slippage in the past few years which has resulted in CIL allocations not delivering within the financial years to which they are programmed. It is not clear whether the Council is proactively considering the phasing of CIL expenditure | | | d) RE management will ensure all priority S106 agreements are transferred from the excel spreadsheet to EXACOM. On the transfer of data from RE management will ensure that: - all relevant S106 agreements are held on file; - all relevant fields within EXACOM are correct and match S106 agreements; and - all relevant fields with EXACOM accurately provide details of how funds have been applied. Priority schemes will be those which: - have not yet commenced; - were signed on or after 1 Jan 2015; - finance records following the reconciliation indicate there is a balance; and - EXACOM indicates the scheme has commenced but there are empty fields within the database. **Responsible officer:** Head of Strategic Planning, RE **Target date:** 30 April 2018. | | | e) RE and LBB management will | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | and whether there are infrastructure investment opportunities that can be prioritised and progressed to utilise available funds. **See finding 5, Identification and management of infrastructure investment needs and priorities.** | | | agree a strategy for transferring non-priority S106 agreements from excel into EXACOM. On the transfer of data from RE management will ensure that: | | | | | | • all relevant S106 agreements are held on file; | | | | | | • all relevant fields within EXACOM are correct and match S106 agreements; and | | | | | | • all relevant fields with EXACOM accurately provide details of how funds have been applied. | | | | | | **Responsible officers:** | | | | | | Commissioning Lead – Planning, LBB | | | | | | Head of Strategic Planning, RE | | | | | | **Target Date:** 30 April 2018 | | | | | | f) In line with the protocol (see action 1a), when making approved changes to use of S106 or CIL funds within revenue budgets or Capital Programme, including substitutions, CSG Finance will continue to ensure they liaise fully with RE management to ensure full compliance with S106 and CIL legal controls (as this data is not held in finance systems). RE Management will then use this | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | | | | occasion to retain full and accurate records of how funds are being applied. | | | | | | **Responsible officer:** | | | | | | Head of Strategic Planning, RE | | | | | | Head of Finance, CSG | | | | | | **Target date:** 30 April 2018 | | 3. | **Specific development non-financial obligation tracking and verification** | If non-financial development obligations are not monitored and validated then benefits may not be delivered as part of developments in line with requirements and the opportunity to agree a suitable remedy may be missed. | **High** | a) RE Management will complete their historic reconciliation of non-financial obligations and start to take any action necessary as a result of this reconciliation. | | | | | | **Responsible officers:** | | | | | | Head of Strategic Planning, RE | | | | | | Infrastructure Planning Manager, RE | | | | | | Service Director - Highways, RE | | | | | | Head of Business, Enterprise and Skills, RE | | | | | | **Target date:** 30 April 2018 | | | | | | b) A protocol will be developed (see action 1a) to clearly document the roles and responsibilities of parties in the monitoring and delivery of obligations, including where delivery is not in-line with the S106 agreement. Records of delivery will be maintained on file. |
Specific non-financial development obligations are set out as part of planning permissions granted as well as S106 agreements as required. Upon confirmation of these agreements HB Public Law (HBPL) send an email to the responsible team and the obligations are incorporated into the relevant team’s tracker/pipeline and the delivery of these obligations is monitored at a devolved service level.
We selected a sample of 12 specific S106 schemes (see Finding 3 above) and for the 6 where there were non-financial development obligations we traced to ensure the delivery of these had been appropriately verified. We found exceptions with 2/6 schemes (33%):
- For 1/6 (16%) we noted that there was an obligation for the developer to create apprenticeships as part of the construction process. At the time of our fieldwork evidence could not be provided to demonstrate the service had verified that the developer has provided apprentices in line with the agreement. Management confirmed that they are currently undergoing a historic reconciliation of non-financial obligations and ensuring that developers have | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | delivered S106 obligations in full. They are also devising a process to ensure that there is a robust monitoring process in place going forward; - For 1/6 (16%) there was a requirement for the developer to submit travel plans. We inspected the tracker used by the Travel Team which stated that the Travel Plans have not yet been signed off. This has yet to be completed and the site has been occupied since December 2016 and therefore the creation of a retrospective travel plan may be of less value than one completed and agreed on time; and - For 1/6 (16%) the affordable housing requirement within the Affordable Housing Officers pipeline did not match that within the S106 agreement. The site had not been ‘triggered’ yet and work had not been commenced onsite. Management confirmed that this was a documentation error within the pipeline tracker document only and that the S106 agreement is always revisited when sites move towards completion. Planning obligations are legal deeds which need to be formally altered. If planning obligations are not met, a proportionate remedy should be agreed with the developer. | | | Responsible officers: Head of Strategic Planning, RE Infrastructure Planning Manager, RE Service Director - Highways, RE Head of Business, Enterprise and Skills, RE Target date: 30 April 2018 | | | | | | c) As part of their meetings the CSOG will challenge of delivery of non-financial obligations within S106 agreements. Responsible officer: The Chair of the CSOG Target date: 28 February 2018. | | | | | | d) Where planning obligations are found not to have been met without prior agreement, RE management will pursue an appropriate remedy with the developer. Responsible officers: Head of Strategic Planning, RE Infrastructure Planning Manager, RE Service Director - Highways, RE Head of Business, Enterprise and Skills, RE | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|---------------| | | | | | Skills, RE | | | | | | **Target date:** 31 March 2018 | | | | | | e) For transparency, a summary of non-financial obligations delivered through S106 schemes will be incorporated into the Annual Regeneration and Growth Programme Report which is due to be presented to the Assets, Regeneration and Growth Committee in March 2018. | | | | | | **Responsible officer:** Programme Support and Controls Manager, RE | | | | | | **Target date:** 12 March 2018 | | 4. | **Administrative CIL** | If the Council does not make use of available funds then the community will be missing out on important new infrastructure improvements. If Administrative CIL is not clearly recorded and monitored then use of CIL monies could be not in line with legislative restrictions, either through fraud or error. | **Medium** | a) LBB Commissioning and CSG Finance, together with RE Planning Obligations staff, will complete their reconciliation of admin expenses received and spent to date to ensure historic expenditure has been spent in full accordance with Regulation 61 of the CIL legislature. This will allow for clarity between spends on Neighbourhood and Administrative CIL. | | | | | | **Responsible Officers:** Commissioning Lead – Planning, LBB; | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | collection. In Barnet Re administer the CIL and 4% of all Mayor CIL collected is retained to cover administrative costs. | | | Finance Manager, LBB; Infrastructure Planning Manager, RE Head of Finance, CSG | | | a) **Barnet CIL** Management informed us that £197,920.29 of Barnet Administration CIL was applied in 2016/17. We asked for a breakdown of this expenditure and were supplied with a list of spend relating to Neighbourhood CIL (the 15% of the CIL ‘pot’ assigned for use by Local Area Committees), not Administration CIL. Provision 61 of the CIL regulations requires the Council to produce a report which documents the amount of CIL applied to administrative expenses and that amount expressed as a percentage of CIL collected in the year. We noted that this report is due for publication by 31st December 2017 and that LBB Management had confirmed that this statistic was ‘to be confirmed following historic reconciliation’. | | | **Target date:** 23 December 2017 | | | b) **Mayoral CIL** Management informed us that £213,638.56 of Mayor Administration CIL was spent in 2016/17. We asked for a list of expenditure made against this figure and were informed that: - £127,560.54 related to a narrative of ‘Designated and Regulatory Services Management’. We were not provided with a detailed breakdown of this cost and therefore cannot provide assurance that this expenditure specifically related to CIL administration; and | | | b) CSG Finance will ensure any errors from 2016-17 regarding use of CIL administration funds are taken into consideration within the 2017-18 calculations prior to publication by RE of the Regulation 62 notice. **Responsible officer:** Head of Finance, CSG **Target date:** 23 December 2017 | | | | | | c) CSG Finance will ensure that going forwards all carried over funds are appropriately processed in line with the legislature. **Responsible officer:** Head of Finance, CSG **Target date:** 23 December 2017 | | | | | | d) LBB Finance will ensure there is agreement between Re, CSG and the Council about historic and future allocations of administrative expenditure relating to CIL in line | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | - £86,078.06 related to the salaries and on-costs of Commissioners at LBB. The funding for these posts should have been allocated from Barnet CIL not Mayoral CIL. We found authorisation from the CSG Finance Manager but considered monies relating to the administration portion of CIL should be assigned by someone with the appropriate authority under the relevant scheme of delegation. | | | with the appropriate scheme of delegation. | | | c) **Rolling forward of funds between years** The CIL legislation states that between years one to three of the scheme authorities can only spend an aggregate maximum of 5% and 4% of, respectively, Barnet and Mayoral administrative CIL collected over years 1-3. For year four and subsequent years expenditure cannot exceed that collected within the year (i.e. administrative CIL cannot be carried forward at all after year three) We noted that the CIL scheme in Barnet commenced in May 2013 and as such: - Year 1 is all CIL collected up to the end of 2014/15 - Year 2 is all CIL collected in 2015/16 - Year 3 is all CIL collected in 2016/17 - Year 4 is all CIL collected in 2017/18, at which point expenditure cannot exceed that collected within the year. We inspected the spreadsheet which detailed the high level movements within CIL accounts and for 2016/17 we found that: - For Barnet CIL £599k was carried over at the end of | | | **Responsible officer:** Finance Manager, LBB | | | | | | **Target date:** 23 December 2017 | | | e) RE Management will maintain clear records to support the allocation of administrative CIL. This will enable the publication by RE of an accurate and complete Regulation 62 notice by 31st December 2017. | | | **Responsible officer:** Infrastructure Planning Manager, RE | | | | | | **Target Date:** 23 December 2017 | | | (see Finding 6, Expenditure and Benefits monitoring – CIL – Regulation 62 report) | | | **(see Finding 6, Expenditure and Benefits monitoring – CIL – Regulation 62 report)** | | | f) The Commissioning Lead – Planning will become the Budget Manager in Integra for the Administrative CIL funds to ensure there is effective oversight and challenge of spends. | | | **Responsible officers:** Commissioning Lead – Planning, | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | 2016/17 and £736k is currently forecast to be carried over at the end of 2017/18. The historic carry forward is in part due to historic problems with the management of the scheme, which the service has been resolving over the past six months. Any amount that is not required for administrative purposes should be returned to the main CIL Infrastructure ‘pot’ as per the regulations by the closure of 2017/18 accounts. | | | LBB; Finance Manager, LBB; Infrastructure Planning Manager, RE Head of Finance, CSG | | | - For Mayoral Administrative CIL expenditure was £1,687.94 more than permitted under the regulations (there was a carryover of £1,687.97 which was not permitted in accordance with the regulations). However the recent reconciliation of administrative expenses has resolved the draw down errors that caused this money to be carried forward. | | | | | 5. | **Identification and management of infrastructure investment needs and priorities**\
Regulation 123 of the Community Infrastructure Levy Regulations requires charging authorities to set out a list of those projects or types of infrastructure that it intends to fund, or may fund, through CIL. We found:
- It is not clear how the Council’s Regulation 123 list has been formulated and whether it has been informed by a detailed infrastructure needs assessment for the Borough;
- The Council’s Regulation 123 list is dated 01 May 2013. The list states it will be reviewed and updated every year however it is not clear whether this has happened and revised lists have been created; and
- It is not clear how the Regulation 123 list is being | If the Regulation 123 list is not properly maintained then individual developments could be unlawfully charged for the same infrastructure items through both Section 106 Agreements and the CIL | Low | RE management and the Council will agree an approach to ensure that the Council’s Regulation 123 list is brought up to date. Any changes to the Regulation 123 list will be presented to the Council’s Policy and Resources Committee in November 2018. | | | | | | Responsible officers:\
Commissioning Lead – Planning, LBB\
Head of Strategic Planning, RE | | | | | | **Target date:** 30 November 2018 | | Ref | Finding | Risks | Risk category | Agreed actions | |-----|---------|-------|---------------|----------------| | | used to (a) inform the capital programme and (b) guide decision making regarding CIL drawdown. | | | | | 6. | **Expenditure and Benefits monitoring – CIL – Regulation 62 report**\
At the time of the audit the Regulation 62 report for 2015/16 had not been uploaded onto the website by 31 December 2016 as required by the legislature.\
The regulations require the council to document 'the amount of CIL applied to administrative expenses pursuant to regulation 61, and that amount expressed as a percentage of CIL collected in that year in accordance with that regulation. The report stated that this was 'Tbc following historic reconciliation'. | If CIL expenditure and benefits are not clearly recorded and monitored then there may be ambiguity whether use of CIL monies is in line with legislative restrictions | Low | RE will ensure that complete and accurate Regulation 62 reports are uploaded onto the Council's website by the end of the calendar year, as prescribed by the regulations.\
**Responsible officer:** Infrastructure Planning Manager, RE\
**Target date:** Implemented |
## Advisory findings
| REF | FINDING | RECOMMENDATION | |-----|---------|----------------| | 7 | **Exacom and Integra interface**\
At present information regarding S106 and CIL schemes is managed through manual spreadsheets and financial information regarding income and expenditure is recorded on the Integra general ledger system. The reconciliation of information regarding underlying schemes and associated financial information, such as whether income has been received and whether expenditure has been incurred, is dependent on a very manual process that happens on a periodic basis. For example expenditure information is only mapped to S106 schemes on an annual basis.\
The Council has agreed to fund (through CIL administration funds) and Re is now implementing the Exacom system to support CIL and S106 administration which will reduce reliance on the manual monitoring spreadsheets in place to capture scheme information.\
We understand that an interface between Exacom and Integra is not possible. This would have enabled the automatic mapping of financial data to schemes to enable this information to be available in one location in real time. | Whilst an automated interface may not be possible RE management should use the Exacom system implementation as an opportunity to improve system design to facilitate easier and quicker reconciliations between scheme and financial data. This could be achieved through ensuring there are common unique identifiers used in both systems. At the time of testing it was not clear these design principles had been explored and confirmed. |
### Appendix 1: Definition of risk categories and assurance levels in the Executive Summary
| Risk rating | Immediate and significant action required. A finding that could cause: | |-------------|---------------------------------------------------------------------| | **Critical** | • Life threatening or multiple serious injuries or prolonged work place stress. Severe impact on morale & service performance (e.g. mass strike actions); or\
• Critical impact on the reputation or brand of the organisation which could threaten its future viability. Intense political and media scrutiny (i.e. front-page headlines, TV).\
• Possible criminal or high profile civil action against the Council, members or officers; or\
• Cessation of core activities, strategies not consistent with government’s agenda, trends show service is degraded. Failure of major projects, elected Members & Senior Directors are required to intervene; or\
• Major financial loss, significant, material increase on project budget/cost. Statutory intervention triggered. Impact the whole Council. Critical breach in laws and regulations that could result in material fines or consequences. | | **High** | Action required promptly and to commence as soon as practicable where significant changes are necessary. A finding that could cause: | | | • Serious injuries or stressful experience requiring medical many workdays lost. Major impact on morale & performance of staff; or\
• Significant impact on the reputation or brand of the organisation. Scrutiny required by external agencies, inspectorates, regulators etc. Unfavourable external media coverage. Noticeable impact on public opinion; or\
• Significant disruption of core activities. Key targets missed, some services compromised. Management action required to overcome medium-term difficulties; or\
• High financial loss, significant increase on project budget/cost. Service budgets exceeded. Significant breach in laws and regulations resulting in significant fines and consequences. | | **Medium** | A finding that could cause: | | | • Injuries or stress level requiring some medical treatment, potentially some workdays lost. Some impact on morale & performance of staff; or\
• Moderate impact on the reputation or brand of the organisation. Scrutiny required by internal committees or internal audit to prevent escalation. Probable limited unfavourable media coverage; or\
• Significant short-term disruption of non-core activities. Standing orders occasionally not complied with, or services do not fully meet needs. Service action will be required; or\
• Medium financial loss, small increase on project budget/cost. Handled within the team. Moderate breach in laws and regulations resulting in significant fines and consequences. | | **Low** | A finding that could cause: | | | • Minor injuries or stress with no workdays lost or minimal medical treatment, no impact on staff morale; or\
• Minor impact on the reputation of the organisation; or\
• Minor errors in systems/operations or processes requiring action or minor delay without impact on overall schedule; or\
• Handled within normal day to day routines; or\
• Minimal financial loss, minimal effect on project budget/cost. |
| Level of assurance | | |--------------------|---------------------------------------------------------------------| | **Substantial** | There is a sound control environment with risks to key service objectives being reasonably managed. Any deficiencies identified are not cause for major concern. Recommendations will normally only be Advice and Best Practice. | | **Reasonable** | An adequate control framework is in place but there are weaknesses which may put some service objectives at risk. There are Medium priority recommendations indicating weaknesses but these do not undermine the system’s overall integrity. Any Critical recommendation will prevent this assessment, and any High recommendations would need to be mitigated by significant strengths elsewhere. | | **Limited** | There are a number of significant control weaknesses which could put the achievement of key service objectives at risk and result in error, fraud, loss or reputational damage. There are High recommendations indicating significant failings. Any Critical recommendations would need to be mitigated by significant strengths elsewhere. | | **No** | There are fundamental weaknesses in the control environment which jeopardise the achievement of key service objectives and could lead to significant risk of error, fraud, loss or reputational damage being suffered. | Appendix 2 – Analysis of findings
| Area | Critical | High | Medium | Low | Total | |-------------------------------------------|----------|------|--------|-----|-------| | | D | OE | D | OE | D | OE | D | OE | | | Expenditure and benefits monitoring - CIL | - | - | 1 | - | 1 | - | 1 | - | 4 | | Expenditure and benefits monitoring - S106 agreements | - | - | 1 | - | - | - | - | - | 2 | | Governance | - | - | - | - | - | - | - | - | 1 | | Total | - | - | 1 | 2 | - | 1 | - | - | 2 |
Key:
- Control Design Issue (D) – There is no control in place or the design of the control in place is not sufficient to mitigate the potential risks in this area.
- Operating Effectiveness Issue (OE) – Control design is adequate, however the control is not operating as intended resulting in potential risks arising in this area.
| Timetable | |-----------------------------------------------| | Terms of reference agreed: 13/2/17 | | Fieldwork commenced: 21/8/17 | | Fieldwork completed: 25/10/17 | | Draft report issued: 12/12/17 | | Management comments received: 09/01/18 | | Final report issued: 18/01/18 |
## Appendix 3 – Identified controls
| Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | Expenditure and benefits monitoring - CIL | Expenditure in relation CIL charges is used appropriately, and in line with budgeted amounts. | If the Council does not make use of available funds then the community will be missing out on important new infrastructure improvements. | As of April 2017, the Council's Assets and Capital Board (ACB) agreed to a new process which saw the creation of the CIL/S106 Officers Group (CSOG) which reports to the ACB. The objectives and proposed agenda of CSOG are documented in the ACB report 'CIL Governance' which was presented to the Board in April 2017. | | Specific legislative restrictions around CIL expenditure in relation to administration costs are complied with – Up to 4% Mayoral and 5% Barnet CIL can be used for administration. | If the Council does not make use of available funds then the community will be missing out on important new infrastructure improvements. | CSG Finance (Closing and Monitoring) hold a list of the Barnet and Mayoral admin CIL including amounts brought forward from the previous year, income, expenditure and funding to be carried forward to the subsequent year. Drawdowns are approved by the Finance Business Partner for Re. | | Reporting of CIL receipt and expenditure is done in accordance with the regulations – Regulation | If the Council does not make use of available funds then the community will | The Authority’s Monitoring Report, which is published on the Council's website, includes a section on CIL and acts as the Council’s Regulation 62 report. |
### Control Design Issue
- We found there was a lack of clarity regarding the roles, responsibilities and decision making regarding CIL and S106 expenditure (Finding 1)
### Operating Effectiveness Issue:
- At the time of the audit, for administrative expenses relating to Barnet CIL there was a lack of evidence and no clear audit trail to confirm the administrative CIL expenditure made to date and to ensure it had been in line with the legislation (Finding 4).
- For administration expenses relating to Mayoral CIL we found that £127,560.54 had been spent against ‘DRS Management Fees’ but we could not be supplied with evidence of what this related to (Finding 4).
- We found that funding relating to CIL administration expenditure had been carried forward from 2016/17 but this was not in-line with the legislature (Finding 4) | Expenditure and benefits monitoring - S106 agreements | 62 report to be published for financial year before the end of the calendar year. | be missing out on important new infrastructure improvements | |-----------------------------------------------------|---------------------------------------------------------------------------------|---------------------------------------------------------------| | Neighbourhood Portion of CIL is spent in accordance with the regulations and the local process that has been agreed by Barnet Council | - We found that the Section 62 Report was not published within the timeframes stipulated by the CIL regulations (Finding 6). | | If the Council does not make use of available funds then the community will be missing out on important new infrastructure improvements | Each of the three area Committees have an annual budget (15% of receipts (and 25% for redevelopment projects within the constituency) which is capped at £150K. LBB has produced guidance on its rationale for this which was presented and agreed at the Council’s Policy and Resources Committee on 9 July 2015. Officers or Members present proposals to the relevant Area Committee who then formally approve spend. | | Expenditure in relation to S106 agreements and CIL charges is used appropriately, and in line with budgeted amounts. | New Process | | If the Council does not make use of available funds then the planned benefits of the S106 agreements may not be realised. | The Officer wishing to make a bid must complete a CIL/S106 Funding bid which requires information to be included such as summary, sponsor, timescales, strategic alignment and whether the scheme is on infrastructure and can be linked to the Council’s Regulation 123 list. Capital costs and deliverables must be included alongside project constraints, contingencies and risks. The CSOG (CIL and S106 Officers Group) review and approve bids to be presented to the Assets and Capital Board (ACB) for formal approval. | | Previous Process | | The Capital Plan documents S106/CIL funding by project which is approved by the Council’s Policy and Resources Committee. Any changes are made through changes to the CSG Capital book which is then approved by the Committee. | | Control Design Issues: | | - We found there was a lack of clarity regarding the roles, responsibilities and decision making regarding CIL and S106 expenditure (Finding 1); | | - There is no proactive, systematic review of the s106 schedule to identify and manage schemes that are approaching their expiry date (Finding 2). | | - Management confirmed there are discrepancies between the records held between Re and CSG (Finding 2) |
### Operating Effectiveness Issue
- Upon reviewing the S106 schedule some schemes showed as having unspent/unallocated balances and there were instances where the S106 schedule did not fully reflect the details of the S106 agreement in place (Finding 2).
- We could not be provided with all the S106 agreements within the schedule (Finding 2).
### Expenditure is linked to expiry periods for funds to ensure that funds are spent in accordance with the scheme
| If S106 amounts are not used in line with agreements in place or in line with relevant legislation then the Council may have to repay funds. | |---| | Once sealed, HBPL send a copy of the agreement to Planning Obligations Team (Re) via email. Planning Obligations Officers incorporate the agreement into the S106 schedule. For non-financial agreements, HBPL send an email to the relevant team who incorporate the agreement into their trackers or pipeline. |
### Control Design Issue
- We found that there was no proactive systematic review of the schedule to identify and manage scheme that are approaching their expiry (Finding 2):
### Non-financial S106 specific development obligations are delivered in line with agreements.
| If non-financial development obligations are not monitored and validated then benefits may not be delivered as part of developments in line with requirements | |---| | Each Team delivering non-financial obligations hold their own schedule/tracker/pipeline to monitor obligations and ensure compliance with the agreement. |
### Control Design Issue:
- We found exceptions related to Affordable Housing, Travel Plans and Apprenticeship schemes. The governance arrangements were not always clear regarding delivery of non-financial S106 obligations (Finding 3).
### Governance
| CIL expenditure is efficient and delivers new and improves existing infrastructure in a cost effective way. | |---| | For Barnet CIL CSOG (CIL and Section 106 Officers Group) is attended by Strategic Planning Group Members and as required, LBB/ Re Service Areas and Commissioners ACB (Assets and Capital Board): Attendees are from across the Council (Chief Exec, Deputy Chief Exec and Commissioners) as well as senior management from CSG and Re ( | | There is sufficient oversight of the CIL scheme to ensure strategic objectives are met. | If key stakeholders are not identified and engaged in decision making and oversight of the CIL fund then amounts may not be used in line with local infrastructure needs resulting in resident dissatisfaction. | See controls listed above. | |---|---|---| | Appropriate parties are involved in decision making to ensure the allocation of funds is | If key stakeholders are not identified and engaged in decision making and oversight | See controls listed above. |
**Policy and Resources Committee: Members**
**For Neighbourhood CIL**
- Area Committee Budget Applications Guidelines were published for 2017/18
- Reports are made to each Area Committee which document all spends and agreements in place. The document includes budget allocation and monitoring of agreed spends, such as actuals, predicted spends as well as date of committee approval. These are made publically available for challenge and scrutiny.
**Control Design Issue:**
- We found there was a lack of clarity regarding the roles, responsibilities and decision making regarding CIL and S106 expenditure as well as delivery of non-financial obligations (Findings 1)
**Operating Effectiveness Issue:**
- We found that it is not clear how the Council’s Regulation 123 list has been formulated and whether it has been informed by an up to date and detailed infrastructure needs assessment for the Borough (Finding 5). | equitable. | of the CIL fund *then* amounts may not be used in line with local infrastructure needs resulting in resident dissatisfaction | Appendix 4 – Internal Audit roles and responsibilities
Limitations inherent to the internal auditor’s work
We have undertaken the review of Community Infrastructure Levy (CIL) and Section 106 (S106) – Phase II, Expenditure, subject to the limitations outlined below.
Internal control
Internal control systems, no matter how well designed and operated, are affected by inherent limitations. These include the possibility of poor judgment in decision-making, human error, control processes being deliberately circumvented by employees and others, management overriding controls and the occurrence of unforeseeable circumstances.
Future periods
Our assessment of controls is for the period specified only. Historic evaluation of effectiveness is not relevant to future periods due to the risk that:
- the design of controls may become inadequate because of changes in operating environment, law, regulation or other; or
- the degree of compliance with policies and procedures may deteriorate.
Responsibilities of management and internal auditors
It is management’s responsibility to develop and maintain sound systems of risk management, internal control and governance and for the prevention and detection of irregularities and fraud. Internal audit work should not be seen as a substitute for management’s responsibilities for the design and operation of these systems.
We endeavour to plan our work so that we have a reasonable expectation of detecting significant control weaknesses and, if detected, we shall carry out additional work directed towards identification of consequent fraud or other irregularities. However, internal audit procedures alone, even when carried out with due professional care, do not guarantee that fraud will be detected.
Accordingly, our examinations as internal auditors should not be relied upon solely to disclose fraud, defalcations or other irregularities which may exist.
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d85b88be0fae07212427768ea16c20dd089eea58 | S106 vs S278 vs CIL- your approach
Why is it important? The new Regulations have adjusted how council's need to plan for, and implement, the use of CIL alongside S106. This has an impact on: viability evidence, Infrastructure evidence, and Regulation 123 list. So pretty much everything required to pass a successful CIL examination!
A reminder - Planning Obligations, S278 Highways Act and Reg 122 & 123 CIL As a reminder, S106 Planning Obligation are obligations secured pursuant to Section 106 of the Town and Country Planning Act 1990. They are entered into as legal agreements between local planning authorities, landowners, developers and potentially other affected third parties. They can impose financial and non-financial obligations on a person or persons with an interest in the land and become binding on that parcel of land. Planning obligations are used to make acceptable development which would otherwise be unacceptable in planning.
A 278 agreement (of the Highways Act 1980) is:
- an agreement between the Council and developer which describes proposed modifications to the existing highway network to facilitate or service a proposed development
- typically the scope of any off site works that are required to mitigate the impact of the development on the existing road network
- examples of works covered by this type of agreement could include:
- roundabouts,
- signalised junctions,
- right turn lanes,
- safety related works such as traffic calming,
- street lighting,
- improved facilities for pedestrians and cyclist.
CIL Regulation 122 changes the use of planning obligations, introducing the three legal test. This has not changed with the amended regulations.
Regulation 123 has been adjusted (Feb 2014) (CIL Reg 123 Feb 14 update) to encompass agreements under section 278 of the Highways Act. In summary it states that:
- Granting planning permission cannot be dependent on a S106 or S278 for infrastructure on Reg. 123 list
- Authorities cannot pool from more than five separate S106 planning obligations
- Limitations on pooling for infrastructure begins from all obligations collected since 6th April 2010
- There is no limitation on pooling for S278 agreements.
There is much discussion about the definition of a planning obligation with respect to the pooling restrictions. For example, if an authority has already entered into more than 5 obligations for education, can it then enter into another obligation for a specific school? DCLG have clarified their view that this was within the rules and that the regulations were designed to stop double changing rather than restrict a council’s ability to deliver the infrastructure that is needed.
| Regulation 122 | Regulation 123 | |----------------|----------------| | **Timing** | From adoption of charging schedule or 6th April 2015 whichever is earlier | | **Impact** | Granting planning permission cannot be dependent on a S106 or S278 for infrastructure on reg 123 list | | | Cannot pool from more than five separate S106 planning obligations | | | Limitations on pooling for infrastructure begins from 6th April 2010 | | | No limitation on pooling for S278 agreements |
**What does the new S106, s 278 – CIL changes mean for you?** From April 2015 you will only be able to pool S106 on a very limited basis. If a CIL is not in place your council is at risk of significantly reducing income from developer contributions.
**S106, S278 and CIL Decisions** Looking at the practicalities the regulations require you to consider when you will use s106 and CIL in the future.
Some authorities have found it helpful to develop a decision tree as a planning tool. This is not something they use to assess planning applications but rather they use it during the CIL evidence gathering process.
Running through a methodical process allows local authorities to consider what S106 requirements may remain, which will inform:
a) Viability evidence assumptions, especially for strategic sites b) Analysis of CIL income against income from other sources, include s106.
If you understand which mechanism you will use to deliver infrastructure on each of your sites you can generate a regulation 123 list. Developing an Approach to s106 vs s278 vs CIL
So, there are a number of steps you will need to take to plan for CIL implementation, with respect to S106.
1. Review existing planning permissions, S106/S278 agreements to see if you have exceeded the pooling limits.
2. Have discussions with development management colleagues explore how S106 currently operates and how it could be used in the future (post CIL adoption).
3. Have discussions with developers to explore how S106 could be used in the future, particularly for strategic sites that may have significant on-site infrastructure requirements.
4. Have discussions with County (two-tier authorities) discuss how S106 could be used in the future. This will be vital for education and infrastructure provision where the practice has been to pool S106.
5. Consider how you can use the new infrastructure in lieu and phased payment provisions.
S106 vs S278 vs CIL - Local Authority examples
Wycombe have created suite of documents to support Reg 123 list: http://www.wycombe.gov.uk/council-services/planning-and-buildings/planning-policy/community-infrastructure-levy/spending.aspx
- CIL and planning obligations funding decision protocol – Sets out process and protocol for allocating CIL funding
- CIL spending programme – Sets out projects set to receive CIL in this financial year
- Section 106 developer contributions spending programme – Sets out amounts and project allocations over two year period • CIL funding available – Sets our indicative amounts and infrastructure type allocations for next financial year.
**Shropshire** have highly detailed reg.123 list which list individual projects - 18 place plans that prioritise the infrastructure needs at a local level: [https://shropshire.gov.uk/planning-policy/what-is-the-community-infrastructure-levy-(cil)/distributing-the-levy/](<https://shropshire.gov.uk/planning-policy/what-is-the-community-infrastructure-levy-(cil)/distributing-the-levy/>)
**TIPS for approach to delivery -CIL Reg. 123 list, s 106 or s 278**
1. Methodically go through each site and determine whether you will use CIL, S106 or S278 to deliver the infrastructure (or a combination)
2. Use your understanding of the three legal tests and pooling restrictions to pick the appropriate mechanism
3. If CIL is going to be used for everything then the reg 123 list will be generic
4. If S106/S278 is going to be used for everything then the reg 123 will be very short!
You will need to be able to explain your approach as part of your CIL story at examination.
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d5f322bb0aa1089805370dc549fe495d70a2f144 | Community Infrastructure Levy
The Community Infrastructure Levy (CIL) provides an opportunity for local authorities to fund ‘community infrastructure’ support for new developments (such as transport, schools and hospitals), by charging developers. However, it also brings challenges, particularly in London, where both the Mayor and boroughs will be able to charge CIL. This briefing provides an overview of the government’s proposals and the Mayor’s plans and discusses the likely implications for boroughs.
Overview
Community Infrastructure Levy (CIL) is a levy charged to developers by boroughs to pay for the infrastructure needed to support a development. The larger a development, the more a developer will have to pay. It is a type of ‘planning obligation’. Any authority that levies CIL has to publish their tariff schedule, so developers can know the ‘cost’ of developing a given amount in that area, thus bringing more certainty to the planning process. Over time it is intended to replace Section 106 (S106) planning obligations (which are negotiated on a case-by-case basis by local authorities, and are thus less certain). As soon as a borough starts to charge CIL, S106 planning obligations can only be used for affordable housing and any site-specific requirements, for example a new access road required as a result of the development.
Timeline
- **2008** the Planning Act 2008 allows local authorities to levy CIL
- **April 2010** CIL regulations come into effect enabling it to be levied
- **November 2010** (new) government confirms that CIL stays, but with modifications
- **December 2010** Localism Bill published containing some modifications to CIL
- **Spring 2011** GLA consults on Mayoral CIL; also some minor changes announced by the government in November 2010 come into force
- **Summer 2011** government consults on Localism Bill’s revised CIL regulations
- **Autumn 2011** Mayoral CIL Examination in Public
- **April 2012** Mayoral CIL is levied (until 2019); MDCs can start charging CIL (see over) and CIL can be given to neighbourhoods to spend
- **April 2014** Boroughs no longer allowed to pool S106 contributions to fund general infrastructure needs that CIL could fund instead. Background
CIL was introduced in 2008, and offers many advantages to boroughs as it should be easier to secure contributions from new developments - only 7 per cent of developments in London involved a S106 agreement in 2007/8 (the latest year for which figures are available) and S106 agreements often involve lengthy negotiations.
Many more developments should be ‘captured’ by CIL and, as the charge is levied according to a published schedule, CIL will provide more certainty over the amount of money generated from a scheme, helping both boroughs and developers. The merits of this charging approach, combined with the fact that the 2010 CIL regulations placed restrictions on the use of S106 contributions from 2014, make it very likely that all local authorities will levy CIL in the future.
In November 2010 a number of technical modifications to CIL included a new requirement for local authorities to allocate a ‘meaningful proportion’ of CIL revenue raised back to the neighbourhood in which it was raised, to spend on the infrastructure that local people consider is most important. The government has not yet indicated what proportion it considers to be ‘meaningful’, although some have suggested that 5 per cent of gross CIL revenues could be viewed as appropriate.
Under the proposals in the Localism Bill, Mayoral Development Corporations (MDCs) will be able to charge CIL if they have been given full planning powers for their area. Subject to the outcome of a consultation, these revisions could then be included in further revised regulations due to come into force in April 2012.
CIL in London
In London, both the Mayor and the boroughs will be able to charge CIL (although only Redbridge has started doing so). Boroughs will be required to collect CIL on behalf of the Mayor. The funding agreement for Crossrail requires the Mayor to raise £300 million through CIL over the seven years up to March 2019 (the Crossrail construction period) in addition to £300 million being raised through S106 developer contributions. Although the regulations allow the Mayor to collect CIL for any strategic transport infrastructure, he will initially only use it for Crossrail. Further, although boroughs will be required to take account of the rate of Mayoral CIL when assessing the viability of their CIL rate, the Mayor will not be required to take account of borough CIL or S106 arrangements when setting his CIL.
The rates for the Mayoral CIL have been calculated based on the need to raise £300 million in seven years. The proposal is to split boroughs in to three zones as set out in Table 1 (below). These will have different charges to reflect varying levels of development viability. The zones are based on house prices which are being used as a proxy for all land values.
| Zone 1 | £50 | |--------|-----| | Camden, City of London, Westminster, Hammersmith and Fulham, Islington, Kensington and Chelsea, Richmond-upon-Thames, Wandsworth |
| Zone 2 | £35 | |--------|-----| | Barnet, Brent, Bromley, Ealing, Greenwich, Hackney, Haringey, Harrow, Hillingdon, Hounslow, Kingston upon Thames, Lambeth, Lewisham, Merton, Redbridge, Southwark, Tower Hamlets |
| Zone 3 | £20 | |--------|-----| | Barking and Dagenham, Bexley, Croydon, Enfield, Havering, Newham, Sutton, Waltham Forest |
Although boroughs will be required to take account of the rate of Mayoral CIL when assessing the viability of their CIL rate, the Mayor will not be required to take account of borough CIL or S106 arrangements when setting his CIL. The Mayor is proposing that developments used wholly or mainly for the provision of any education or health services will not pay the levy. Developments by charities for their own purposes, and affordable housing are excluded by law.
The Mayor intends to start charging CIL from Spring 2012 at which point boroughs will be required to collect it on his behalf so will need to have collection and enforcement procedures in place regardless of whether they are introducing CIL themselves.
Redbridge has proposed a flat rate charge of £70 per sqm and is working to a similar timetable for introducing CIL (this excludes an additional £35 Mayoral CIL charge).
Commentary
There are still some uncertainties about exactly how CIL will operate, particularly with regard to the more recently proposed requirement to allocate CIL to ‘neighbourhoods’. In addition, the fact that CIL is only charged on net additional development means that where development is on brownfield sites (which is often the case in London) CIL would only be paid on any floorspace, which is additional to that which was on the site originally. This could mean some developments paying less under CIL than under a borough’s existing S106 arrangements.
Although it will not be mandatory for boroughs to introduce CIL, the Government’s restrictions on the use of S106 agreements may effectively force boroughs to introduce CIL if they want to continue raising contributions from developers for anything other than affordable housing and site-specific requirements.
London Councils has raised concerns about the Mayoral CIL during the consultation period in early 2011. The Mayoral CIL effectively taking precedence over any borough CIL could impact on boroughs’ ability to secure funding for other local and sub-regional priorities that are currently funded through developer contributions, including the delivery of affordable housing.
London Councils is also stressing that TfL need to fully consider all possible alternatives before going ahead with the proposals for raising CIL, including the potential for generating this funding in other ways, such as increased borrowing, or from other parts of TfL’s budget, especially given that it represents a small proportion of this. In addition, TfL should also consider extending the period over which the charge is collected in order to reduce the amount that needs to be raised each year and thus the level at which the charge is set.
Further, the charge could act as a disincentive to development in London, at a time when it is particularly important to be focusing on the future economic prosperity of the capital. We are also lobbying the Secretary of State for Transport to ensure that those areas outside London which benefit from Crossrail also make a fair contribution to its cost.
Without further details it is impossible to tell exactly what impact the requirement to pass funding to neighbourhoods would have on boroughs.
Some already work closely with community groups when agreeing the S106 requirements on major developments and this could be viewed as an extension of that idea. It is also likely to make it easier to get local support for new developments which could be of benefit to boroughs.
However, there may well be tensions between what local communities view as necessary and what the local authority considers to be the priorities for the wider area. Such tensions are likely to be particularly acute in London where the Mayoral CIL will also have an impact on the amount of CIL that boroughs can raise making it even harder for them to balance the competing priorities locally.
In London, the need to split CIL between neighbourhoods, boroughs and the Mayor may mean that there is not enough for boroughs to fund necessary community infrastructure to support new development.
It may be that, for the duration of the Mayoral CIL, some relief on the requirement to pass CIL to neighbourhoods is necessary to make CIL a viable means to fund infrastructure. There are also issues regarding how any CIL passed to neighbourhoods will be accounted for - who will have the authority to spend the money, and how?
Ultimately, there is a very real concern that the borough CIL will end up being squeezed between the requirements of neighbourhood CIL and the Mayoral CIL, leaving very little for local infrastructure requirements such as schools, clinics and local transport.
Author: Nigel Minto, Head of Housing and Planning (T: 020 7934 9805) Click here to send a comment or query to the author
Links: More information on the CIL (CLG website) London Councils response to CIL consultation
This member briefing has been circulated to: Portfolio holders and those members who requested policy briefings in the following categories: Housing, Planning
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4fb6d8add01b92df34726c6e10e21197c4523468 | Proposed Commissioners’ Directions on reporting of passenger and crew information for customs purposes: a Consultation Document
Consultation document Publication date: 25 March 2015 Closing date for comments: 15 May 2015 Subject of this consultation: Proposed Commissioners’ Directions (CDs) on reporting of passenger and crew information for customs purposes
Scope of this consultation: The purpose of this Consultation document is to consider the new proposed CDs and the advance notification timescales.
Who should read this: Anyone required to report passenger information in advance for customs purposes, particularly those involved in general aviation.
Duration: 25 March 2015 to 15 May 2015
Lead official: Karen Rourke
How to respond or enquire about this consultation: Please send email responses to Excise & Customs Law Team. Please send written responses to HMRC, Excise & Customs Law, 7th Floor SW, Alexander House, 21 Victoria Avenue, Southend-on-Sea, SS99 1AA
After the consultation: We will publish a summary of the feedback
Getting to this stage: This is the culmination of two years of work already undertaken to establish Commissioners’ Directions.
Previous engagement: We have already notified our intention to consult through engagement at meetings with the trade and also through the GA Challenge Panel.
## Contents
1. Purpose of the Paper ........................................ 4
2. Background .................................................. 4
3. Airport Designations ........................................ 3
4. Proposed Changes ........................................... 5
5. Other considerations ......................................... 6
6. Question ...................................................... 7
Annex A Legislation
______________________________________________________________________
On request this document can be produced in Welsh and alternate formats including large print, audio and Braille format
1. Purpose of the Paper
1.1 In May 2013, new Commissioners' Directions (CDs) on reporting of Passenger Information for customs purposes came into effect. The General Aviation (GA) Trade Sector identified difficulties in complying with the advance notification timescales in the CDs and, as a result, the time limits specified in the CDs are not being enforced.
1.2 The Government recognises the problems facing UK GA and is committed to ensuring that customs requirements do not impede opportunities for GA to continue to contribute to the UK’s growth. GA poses particular challenges for the customs authorities because of the unscheduled and unpredictable nature of the traffic. The Government is committed to delivering the smoothest passage possible for legitimate pilots, passengers and goods, with the intention that UK Customs is recognised globally as the world’s leading Customs authority for facilitating legitimate trade.
1.3 Therefore the purpose of this discussion paper is to consider the new proposed CDs and the advance notification timescales.
1.4 The Directions state: ‘unless otherwise agreed with the Commissioners’. This effectively ensures that existing arrangements for scheduled airlines and shipping traffic remain as before these CDs were published. Neither do they affect the current reporting requirements for pleasure craft or ferry companies.
2. Background
2.1 The Customs and Excise Management Act 1979 (CEMA) provides for Commissioners’ Statutory Directions, which are a form of secondary legislation that lay down detailed rules of procedure or requirements.
2.3 The CDs are made under CEMA sections 35(1) and 64(1) in 2001 to set out the requirement for passenger information, for customs purposes. Since then the Directions have formed the basis of operational practice.
2.3 There is a Customs Civil Penalty for a failure to report, with a maximum penalty of £1000. The use of regulatory civil penalties to underpin customs requirements is well-established and uncontroversial and they provide a method for penalising non-compliance with customs law where criminal prosecution would not be appropriate. When faced with non-compliance all the circumstances are considered and the most appropriate response is used. Penalties are not issued automatically or as a first resort. 2.4 The information is required so that customs officers can (a) monitor the travel movements of known and suspected criminals in and out of the country and (b) apply profiling techniques developed over many years to flights and maritime journeys (and their passengers) leading to the identification of those who may be involved in smuggling prohibited/restricted goods or dutiable products.
2.5 In early 2012 General Aviation (GA) reports could be submitted via the ‘Collaborative Business Portal’ (CBP). As a result of this, in May 2013, new CDs came into effect. However, because of the difficulties identified with the advance notification timescales, the time limits specified in the CDs are not being enforced. HMRC is now proposing to revise the CDs with new advance notification timescales.
2.6 Directive 2010/65/EU on reporting formalities for ships arriving in/or departing on ports of the Member States is due to come into force in 2016. This may result in further changes being necessary to the CDs. However, there are ongoing discussions with the Commission over the implementation of Directive 2010/65/EU on reporting formalities for ship arriving in/or departing from ports of the Member States. Therefore, we will not review maritime arrangements, including Commissioners’ Directions, until it is known how the Directive will be implemented.
3. Airport Designations
3.1 All Aircraft, save as permitted (by the Commissioners of HMRC which includes Border Force), are required to land at a ‘customs and excise’ airport when entering from a third country. Once designated, the airport is required to operate under a full customs Examination Station Approval (ESA). It is subject to any conditions laid down in an extant ESA but there are no customs restrictions on the types of traffic that may be handled there.
3.2 This requirement is disapplied for the purpose of EU flights. For customs purposes, when using an airport which does not have any type of designation or a Certificate of Agreement, operators can only fly within Great Britain and Northern Ireland or to/from destinations within the European Union (EU).
3.3 To facilitate trade and provide a wider range of airports to fly into from outside the EU, HMRC uses the ‘save as permitted’ to provide for ‘Certificate of Agreement’ (CoA) airports. Whilst they are not subject to a formal ESA, they operate under a lower level formal agreement (which allows them to handle a limited range of traffic from third-countries, including the Channel Islands).
3.4 Non-designated airports covered by Certificates of Agreement are not open generally for passenger or freight activities. An operator or pilot of a general aviation aircraft is required to report in relation to international or Channel Islands journeys to or from the UK, unless they are travelling outbound directly from the UK to a destination in the European Union. 4. Proposed Changes
4.1 This Discussion Paper sets out the proposed changes to the CDs for consideration. The proposed approach to be taken is that the timescale for advance notification for all airports will be:
(a) in the case of arrivals, no later than two hours before departure from the last destination before the ship, aircraft or train arrives in the United Kingdom.
(b) in the case of departures, no later than two hours before departure from the United Kingdom.
4.2 The information will be required to be provided by granting direct access to relevant computer systems, by electronic transmission or, where neither of these is possible, by delivering the particulars in writing, in a readable form and in the prescribed manner.
4.3 As a result of harmonising these timescales at all airports, the GA sector will no longer have to identify what airports are CoA or designated C&E airports.
5. Other considerations
5.1 The Government is committed to reducing the regulatory burden on GA and these timescales will harmonise the timescales with those envisaged as being required under the new Counter Terrorism & Security Act (CTSA).
5.2 On 29 August the Joint Terrorism Analysis Centre raised the UK threat level from SUBSTANTIAL to SEVERE, meaning that a terrorist attack is “highly likely”. On 1 September 2014, the Prime Minister announced that legislation would be brought forward in a number of areas. The Counter-Terrorism and Security Act 2015 received Royal Assent on 12 February 2015.
5.3 The measures will strengthen security arrangements in relation to the border and to aviation, maritime and rail transport. These provisions would extend the scope for authority to carry (‘no fly’) schemes, allow the Secretary of State to make regulations in relation to passenger, crew and service information and to give directions in relation to security measures to aviation, shipping or rail transport operating to the UK.
5.4 The CTSA 2015 will also include enabling provisions for regulations that will require advance notification for arriving and departing GA aircraft for police and immigration purposes. The detail of the requirement (data content, timescales for advance notification, form and manner of data submission) will be in regulations. The Home Office will consult publicly in the development of the regulations and will aim for as much harmonisation as possible between the reporting frameworks. 5.5 This will reduce the burden on the GA sector as, not only will they no longer have to identify the difference between CoA and C&E designated airports, they will also no longer have to try to identify different timescales and requirements. They will be able to fly into the UK secure in the knowledge that they are complying with all requirements from the Law Enforcement agencies at the Border.
5.6 This information obtained via the CDs will enable Border Force to carry out customs controls and safety and security checks on goods, people and means of transport at the Border in accordance with legal obligations and risk priorities.
6. Questions
6.1 The Government would like to find a solution that balances a customs service that reflects modern international trade practices with delivering a safe, secure and effective Border, featuring safeguards and sanctions that help reduce the tax gap, stop prohibited goods from causing harm, and protect UK Borders from other threats.
6.2 To help us resolve these issues, we are seeking views on the following:
(a) Would the advance notification timescales, detailed above, in relation to both ‘designated customs & excise airports’, and ‘certificate of agreement airports’ achieve this objective? If not, why not?
(b) Do you think there could be other ways that the Government could achieve this objective?
7. Timetable for next actions by Government
What you tell us will be taken into account when the Government decides how to proceed. Therefore, a statement will be made as soon as possible after the end of Consultation.
8. The Consultation Process
This consultation is being conducted in line with the Tax Consultation Framework. There are 5 stages to tax policy development:
Stage 1 Setting out objectives and identifying options. Stage 2 Determining the best option and developing a framework for implementation including detailed policy design.
Stage 3 Drafting legislation to effect the proposed change.
Stage 4 Implementing and monitoring the change.
Stage 5 Reviewing and evaluating the change.
This consultation is taking place during stage 3 of the process. The purpose of the consultation is to seek views on draft legislation in order to confirm, as far as possible, that it will achieve the intended policy effect with no unintended effects.
How to respond
Feedback on this paper should be submitted to: If you have any questions about this change, please contact by e-mail, Excise & Customs Law Team or by post to:
Excise & Customs Law team HM Revenue and Customs Room LG/74 100 Parliament Street London SW1A 2BQ
Or by fax to 03000 594275
by 15 May 2015
Paper copies of this document or copies in Welsh and alternative formats (large print, audio and Braille) may be obtained free of charge from the above address. This document can also be accessed from HMRC Inside Government. All responses will be acknowledged, but it will not be possible to give substantive replies to individual representations.
When responding please say if you are a business, individual or representative body. In the case of representative bodies please provide information on the number and nature of people you represent.
Confidentiality
Information provided in response to this consultation, including personal information, may be published or disclosed in accordance with the access to information regimes. These are primarily the Freedom of Information Act 2000 (FOIA), the Data Protection Act 1998 (DPA) and the Environmental Information Regulations 2004. If you want the information that you provide to be treated as confidential, please be aware that, under the FOIA, there is a statutory Code of Practice with which public authorities must comply and which deals with, amongst other things, obligations of confidence. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on HM Revenue and Customs (HMRC).
HMRC will process your personal data in accordance with the DPA and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties.
**Consultation Principles**
This consultation is being run in accordance with the Government’s Consultation Principles. [If you wish to explain your choice of consultation period, this is the place. Also, if you are holding additional meetings or using alternative means of engaging, please mention this here].
The Consultation Principles are available on the Cabinet Office website: [http://www.cabinetoffice.gov.uk/resource-library/consultation-principles-guidance](http://www.cabinetoffice.gov.uk/resource-library/consultation-principles-guidance)
If you have any comments or complaints about the consultation process please contact:
Oliver Toop, Consultation Coordinator, Budget Team, HM Revenue & Customs, 100 Parliament Street, London, SW1A 2BQ.
Email: [[email protected]](mailto:[email protected])
Please do not send responses to the consultation to this address. Annex A: Relevant Draft Government Legislation
The Commissioners for Her Majesty’s Revenue and Customs, in exercise of the powers conferred on them by sections 21, 35(1) and 64(2)(b) of the Customs and Excise Management Acts 1979 (“CEMA 1979”), direct as follows-
(a) The Passenger Information Directions made on 21 May 2013 are revoked.
(b) In the case of any certificate of agreement airport- i) these Directions are to be treated as forming part as of the terms of approval in place at the airport, and ii) any requirement specified in terms of approval is revoked to the extent that it is inconsistent with these Directions.
(c) Save in the manner specified in (b) above, nothing in these Directions alters any other direction given under section 21, 35(1), or section 64(2) of CEMA1979.
(d) The following directions shall be cited as:
Commissioners’ Directions Passenger and Crew Information
1. These Directions apply in respect of: (a) any ship, aircraft or through train which it is intended will next travel to a place in the United Kingdom from a place outside of the United Kingdom;
(b) any ship or aircraft which it is intended will next travel from any port or airport in the United Kingdom to a final destination outside either the European Union or the Isle of Man.
2. Unless otherwise agreed with the Commissioners, an owner of a ship, aircraft or through train, to which these Directions apply must provide the prescribed information to the proper officer no later than the time specified in paragraph (3) below.
3. The prescribed information is to be provided- (a) in cases described in paragraph 1(a) above, no later than 2 hours before departure from the place outside the United Kingdom.
(b) in cases described in paragraph 1(b) above, no later than 2 hours before departure from the United Kingdom, or
(c) before such time as the Commissioners may otherwise direct.
4. (1) The prescribed information is only to be treated as having been provided for the purposes of these Directions if-
(a) in cases where the information is comprised of data electronically stored by the owner-
(i) the proper officer is granted direct access to the system on which that data is stored it, or
(ii) the data is transmitted electronically to the proper officer, or
(b) in cases where it is either not reasonably practicable to comply with paragraph (4)(1)(a) above, or where the Commissioners otherwise direct, by delivering the information in writing, in a readable form and in the prescribed manner.
(2) For the purposes of this paragraph information is delivered in the prescribed manner-
(a) in cases where it is in respect of the intended travel of an aircraft, when it is notified to the Commissioners in the form specified in Schedule 2, and
(b) in any other case, when it is notified to the Commissioners in such form as they may direct or approve
5. In these Directions: “certificate of agreement airport” means an airport, not being a designated “customs and excise airport” for the purposes of section 21 CEMA 1979, and operating under a certificate of agreement. “crew” does not include crew members of any ship who are required to be reported pursuant to IMO FAL form 5.
“owner” includes an operator, commander or master;
“prescribed information” means the information specified in Schedule 1, but only to the extent such information would otherwise have been obtained by the owner in the course of their business or have been within their knowledge or possession;
“proper officer” means….
“ship” does not include a ship certified to carry 12 passengers or fewer;
“shuttle train” and “international service” have the meanings given in sections 1(9) and 13(6) of the Channel Tunnel Act 1987 (“the Act”).
“through train” means a train, other than a shuttle train, which, for the purposes of section 11 and 12 of the Act is engaged on an international service;
Made by: On date:
and: On date:
Two of the Commissioners for Her Majesty’s Revenue and Customs SCHEDULE 1: List of Information Required
1. General information for the ship, aircraft or train: (a) name, number or registration details of the flight, ship or train; (b) total number of passengers carried; (c) particulars of the departure to include point of departure, UK county, date and time; (d) particulars of the intended arrival to include the point of arrival, UK country, date and time; (e) name and job title of the person completing the report; (f) contact telephone number for the owner.
2. Specific passenger and crew information: (a) identity including: full name, date of birth, nationality and any other information displayed on the person’s travel document; (b) address and any contact details; (c) any particulars recorded in connection with the reservation and checking in; (d) any particulars recorded in connection with the issue of the ticket (for travel); (e) any particulars recorded in connection with the payment made for that ticket; (f) number and names of passengers on the same booking; (g) particulars of the journey and of any journey covered by the same reservation; (h) particulars of any seat allocated to that passenger; (i) particulars of any services or facilities covered by the reservation made for that passenger; (j) particulars of any vehicle carried on the plane, train or ship in relation to which that person is a driver or passenger.
Schedule 2: General Aviation Report
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0cd876faeee95fb34abe378fb6760757521f449f | Are you eligible for Research and Development relief?
1. Does your company develop new products or processes, or enhance existing ones?
- Yes
- No
2. Do you set out to achieve an advance, not just in your company’s own knowledge, in overall scientific or technological capability?
- Yes
- No
3. Does the project involve a technical uncertainty that a knowledgeable professional in your field can’t easily solve?
- Yes
- No
4. Is your company part of a group of companies (any share holder of over 25% by one enterprise may be relevant)?
- Yes
- No
Your company may be eligible as part of a group. Please find further information about groups here and general information here.
Your company is unlikely to be performing R&D for tax purposes and appears to be ineligible for any R&D relief. More information is available on GOV.UK.
5. Are you a sub contractor, performing the research and development of someone else?
- Yes
- No
Your company is ineligible for the R&D for SME scheme. However you may be eligible for RDEC. More information is available here.
6. Is the turnover of your company (or group) not more than €100m or the balance sheet less than €86m?
- Turnover less than €100m
- Balance sheet less than €86m
- No – both are over the limit
7. Are there less than 500 full time members of staff?
- Yes
- No
Your company is ineligible for the R&D for SME Scheme. However you may be eligible for RDEC. More information is available here.
8. Has the company received any grants or subsidies for the research and development project?
- Yes
- No
Your company could be eligible for SME tax relief. You could also seek Advance Assurance. Please visit GOV.UK for more information.
9. Is the grant or subsidy a notified state aid? If unsure, check with your grant provider.
- Yes
- No
Your company is ineligible for the R&D for SME scheme. However you may be eligible for RDEC. More information is available here.
Your company could be eligible for SME tax relief. You could also seek Advance Assurance. Please visit GOV.UK for more information.
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bdcef63558da9641559f30ac5c574f051b9c19af | CIRD11530 (A): intangibles: FA02 rule: acquired assets flowchart Do not use if any of the exceptions listed in CTA09/S882(6) apply (see CIRD11520)
Acquisition expenditure incurred(^6) by company on or after 1 July 2020(^6)?
- **No**
- Acquisition expenditure incurred(^6) by company between 1 April 2002 and 30 June 2020(^6)?
- **No**
- From unrelated party? CIRD11610
- **No**
- Is asset a chargeable intangible asset in the hands of the related party? CIRD11630
- **No**
- Asset previously acquired in qualifying(^c) circumstances? CIRD11640
- **No**
- Pre-FA02 asset
- **Yes**
- Was asset created(^a) (by anybody) on or after 1 April 2002? CIRD11650
- **Yes**
- Part 8 asset
- **Yes**
**Notes:** (a) Apply rules in flowchart (C) to establish if and when an asset is created for purposes of CTA09/Part 8. (b) See flowchart (C) on when expenditure incurred. (c) Broadly, acquired on or after 1 April 2002 from unrelated party. (d) The answer to this question is ‘no’ if an asset is acquired on or after 1 April 2002 without incurring any expenditure.
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1ff9fc8f4d3d9e2277703e8ef3bca4fec3f2d283 | Expenditure incurred after commencement on ‘creation’ of goodwill, or expenditure of a type not qualifying for capital allowances incurred on ‘creating’ an asset?
Yes
Business carried on (goodwill) or other asset held by company pre-1 April 2002? CIRD11680/11685
No
Pre-FA2002 asset
Yes
Another type of expenditure incurred after commencement on ‘creation’ of an asset? CIRD11600
No
Asset within new rules
Note a. See flowchart (C) on when expenditure incurred If expenditure on creation also incurred before commencement treat blocks of expenditure as separate assets
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223f4eb1373ac01ec96bcaa19609297502bfd529 | If expenditure is on creation the asset will fall within CIRD11680 & CIRD11685 and when expenditure incurred will be irrelevant.
Expenditure incurred when recognised under GAAP CIRD11690.
Expenditure incurred before 1 April 2002 - CIRD11690.
Would the expenditure have qualified for capital allowances apart from Part 8?
Yes
Expenditure is incurred when unconditional obligation to pay it arises - CIRD11675 & CIRD11690.
No
Was the expenditure on the acquisition of the asset?
Yes
Would the expenditure have qualified for any form of tax relief against income apart from Part 8?
Yes
Expenditure incurred when recognised under GAAP CIRD11690.
No
Would the acquisition have been recognised under the rule in TCGA92/S28 as taking place before 1/4/02?
Yes
Expenditure incurred before 1 April 2002 - CIRD11690.
No
CIRD11530 (C): intangibles: FA02 rule: supplementary flow-chart: when expenditure on creation or acquisition of an asset "incurred"
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8f43e2c56003f62f226b53145eec9151ef383538 | Disposal of tangible asset before 1/4/02?
Yes
Disposal of intangible asset before 1/4/02?
Yes
Disposal of tangible asset on or after 1/4/02?
Yes
Disposal of intangible on or after 1/4/02?
Yes
CG relief available except against acquisition of CIAs; no relief under new rules
CG relief available only against acquisitions prior to 1/4/02
Relief available under new rules against acquisition of CIAs (on disposal of other intangibles as well as those qualifying for CG roll-over relief)
CIRD20280 - Reinvestment relief: computation: interaction with CG roll-over relief: flowchart
Rollover relief on disposal of an asset which is not within new rules; i.e. asset is not a 'chargeable intangible asset' ('CIA')
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063485d5b3bddce1bf871063f69cc3688d2d21b2 | Patent Box Decision Chart
01. Are you a company?
- Yes - go to 2
- No – END
02. Do you hold a qualifying IP right or rights by way of ownership or exclusive licence (CIRD210110)?
- Yes - go to 3
- No – END
03. Were any of those qualifying IP rights acquired or applied for before 1/7/16 (see CIRD240160 if acquired as part of a Transfer of a trade as special rules apply)?
- Yes - go to 4
- No – go to 9
04. Did you/will you elect into the Patent Box before 2 years after the end of your Accounting Period which straddles 30/6/16?
- Yes - go to 5
- No – go to 9 Old Regime
05. In addition to qualifying IP rights acquired or applied for before 1/7/16, do you have any IP acquired or applied for on or after 1/7/16?
No - go to 6
Yes – go to 9
06. Are any of the qualifying IP rights acquired from a connected company in a country which does not have a Patent Box regime, on or after 2/1/16 (CIRD270200)?
No - go to 7
Yes – go to 9
07. Does the income from 6 above relate to before 31/12/16?
No – go to 9
Yes - go to 8
08. UNLESS THIS CHANGES, STAY IN OLD REGIME UNTIL 1/7/2021. FOLLOW calculation at CIRD220110 but start to track and trace R&D expenditure from 1/7/16 on IP assets still likely to be qualifying on 1/7/2021 per CIRD272000.
END New Regime (Track and trace R&D expenditure and acquisition costs for these qualifying IP rights per CIRD272000)
09. Does the company meet the criteria for Small Claims Treatment (CIRD220470) and want to elect into any or all of the Small Claims Treatment elections (CIRD273200, CIRD273100 or CIRD220480)?
Yes - go to 10
No – go to 12
10. Elect into the new regime immediately and forgo any grandfathering provision. Make election for Global streaming if you want to use a Global stream, (CIRD273200)
Go to 11
11. Split income and expenditure into streams of NON RIPI and global stream. Start tracking and tracing R&D expenditure and acquisition costs for this IP per CIRD272000.
Go to 12 New Regime (continued)
12. Is income from any of the qualifying IP rights ‘IP derived income’? (CIRD220250) This might be from process patents, leasing, or service income for example.
13. Follow the rules at CIRD220251 to ascertain IP derived income relating to the Qualifying IP rights in 12. Does the company meet the criteria for Small Claims Treatment (CIRD220470)?
14. Make a small claims election for notional royalties if you want to take the appropriate percentage of IP derived income to be 75% (CIRD273100)
15. Complete the notional royalty calculation by calculating an appropriate percentage of deemed IP income using transfer pricing principles.
No – go to 16
Yes - go to 13
No – go to 16
Yes - go to 14
Yes – go to 16
No - go to 15
Go to 16 New Regime - Streams
16. Can you identify income relating to every qualifying IP right and track its related R&D expenditure? The criteria is that you should use the most detailed level that you are able to.
Yes - go to 17
No – go to 18
17. (All sub stream(s) at IP level). Split income and expenditure into streams of NON RIPI, old RIPI (if applicable – there may be none or an election may have been made to treat all as new) and new RIPI, the latter being divided into sub stream(s). CIRD271500 provides Guidance. Track and trace R&D expenditure and acquisition costs at this level per CIRD272000.
Go to 21
18. You are having to stream with at least one stream at product/process level or product/process family level. The most detailed level possible should be chosen. Do the sub streams with these products or processes have a combination of old and new qualifying IP rights within them?
Yes - go to 19
No – go to 20 19. Use the Core Value or numeric methods of calculation at CIRD271600 to ascertain whether the sub streams with products/processes or product/process families can be regarded as being grandfathered or whether they are in the new regime. Track and trace R&D expenditure and acquisition costs for all qualifying IP rights per CIRD272000.
Go to 20
20. (At least one stream is at product/process or product/process family level). Split income and expenditure into streams of Non RIPI, old RIPI (if applicable) and sub streams at an appropriate level for qualifying IP rights in the new regime. The Qualifying IP rights grouped together need to be capable of being used for the same or substantially the same, purpose.
Go to 21 New Regime – Stream Adjustments
21. Are there any new qualifying IP rights within the sub streams for which income related acquisition payments are required?
Yes - go to 22
22. Remove the income related acquisition payments from expenditure in that sub stream.
Go to 23
23. Deduct the expenditure debits from the income in each stream. Calculate the routine return deduction for each stream and sub stream with relevant IP income and deduct it from those streams or sub streams. (CIRD220440). Does the company meet the criteria for Small Claims Treatment (CIRD220470)?
Yes - go to 24
No – go to 26
No – go to 23 New Regime – Stream Adjustments continued
24. Do you want to make a small claims election for a Marketing Asset Return deduction of 25% for any stream or sub stream (CIRD220480)?
Yes - go to 25
25. Make the Small claims elections and apply the Marketing Asset Return of 25% to the relevant streams.
Go to 26
26. Apply a relevant Marketing Asset Return deduction to all streams and sub streams apart from the stream with no relevant IP income.
Go to 27
No – go to 26 27. Use the tracking and tracing records to identify direct R&D expenditure (D), unconnected party subcontracted R&D expenditure (S1), connected party subcontracted expenditure (S2) and acquisition expenditure (A) for each sub stream. Calculate fractions using the formula ((D+S1) \\times 1.3/(D+S1+A+S2)), capped at 1, for each sub stream. Does the result provide an incongruous result?
28. Consider whether it is appropriate to make an election to use an alternative Value Fraction instead of the R&D fraction per CIRD275500.
29. Multiply each sub stream by the relevant fraction to create a figure for each sub stream.
30. Add the sub stream figures from 29 together with the figure from the stream with old RIPI to create a Patent Box profit or loss.
If profit go to 32
If loss go to 31
31. The Patent Box loss should be ring fenced and any related company’s Patent Box profit or any future Patent Box profit should be reduced by this amount.
32. Multiply the Patent Box deduction by (MR-IPR)/MR where MR = main rate of CT and IPR = special rate of Patent Box CT (10%) and if before 2017, reduce using the commencement (phasing in) provision at CIRD260170.
END
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00706050079eae2e88dbb14b6c0fe13291472057 | Company Construction Industry Scheme (CIS) deductions set off against monthly or quarterly tax/National Insurance contributions payments
Companies that have CIS deductions taken from their income as subcontractors should set these off against their monthly or quarterly payments to HMRC. Companies should reduce their tax/National Insurance contributions or CIS payments by the amount of CIS deductions taken from their incoming payments.
Only companies may use this arrangement. It is not available to individual subcontractors or partnerships.
CIS deductions taken in a pay period that cannot be fully set off against payments due to HMRC for that period should be carried forward and used for later pay periods within the same tax year.
When the CIS deductions available for set off in a pay period do not cover the whole of the company’s liability for that period, the company must pay over the balance by the normal payment date.
Companies need payment statements for all the CIS deductions taken from their income and should have received these from the paying contractor(s). But if the statements have not yet been received a company can still set off the CIS deductions against its monthly or quarterly payments.
Companies must keep a record of the amounts set off. You may use the table overleaf. If you use a form P32 Employer Payment Record or the table in your Payslip Booklet to record your tax/National Insurance contributions payments, leave columns 16 and 17 blank.
When we have received the company’s last Full Payment Submission (FPS) and Employer Payment Summary (EPS) due for the tax year, any CIS deductions that have not been set off during the tax year may be repaid. Or we may set them against any unpaid tax, depending on the amount involved.
If you need more information
You may phone the CIS Helpline on 0845 366 7899 if you need to know more about how the changes will affect you.
For more guidance, go to www.hmrc.gov.uk/CIS | Tax month | Ending | Net Income Tax including amounts you deducted from subcontractors from Col 3 of P32 or Payslip Booklet | Net National Insurance contributions from Col 15 of P32 or Payslip Booklet | CIS deductions brought forward from earlier pay period (from Col H) | CIS deductions taken from the company in this pay period (D + E) | CIS deductions set off in this pay period (lesser of C or F) | Excess CIS deductions carried forward to next pay period (F minus G) | Tax figure to appear on payslip (A minus G) | Net National Insurance contributions figure to appear on payslip (figure in Col B) | Total amount paid (I + J) | Date paid | |-----------|--------|-------------------------------------------------------------------------------------------------|--------------------------------------------------------------------------|------------------------------------------------------------------|-----------------------------------------------------------------|-----------------------------------------------------------------|-----------------------------------------------------------------|---------------------------------|---------------------------------|-----------------------------|-----------| | 1 | 5 May | | | | | | | | | | | | 2 | 5 Jun | | | | | | | | | | | | 3 | 5 Jul | | | | | | | | | | | | 4 | 5 Aug | | | | | | | | | | | | 5 | 5 Sep | | | | | | | | | | | | 6 | 5 Oct | | | | | | | | | | | | 7 | 5 Nov | | | | | | | | | | | | 8 | 5 Dec | | | | | | | | | | | | 9 | 5 Jan | | | | | | | | | | | | 10 | 5 Feb | | | | | | | | | | | | 11 | 5 Mar | | | | | | | | | | | | 12 | 5 Apr | | | | | | | | | | | | Totals | | | | | | | | | | | |
\*Set off the full amount in Column G against tax, even if the figure in Column I becomes a minus figure.
Example
Net tax payable (Column A) 1300 CIS deductions set off (Column G) 1500 Tax figure on payslip (Column I) Minus 200
You will have shown the figures in this column on Employer Payment Summary (EPS) returns sent during the tax year.
† If the amount in Column K is NIL, send a payslip marked NIL to HM Revenue & Customs Accounts Office.
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2d11cdae6649cf40c3cb7b127b2c057d1365c935 | Library and Archives Canada Wallot-Sylvestre Seminar 2018
Archives Matter
Jeff James, Chief Executive and Keeper, The National Archives UK
25 September 2018 Catalogue ref: MEPO 31/21. Archives inspire rights: ‘Black Power’ demonstration, London, 1970 ARCHIVES UNLOCKED DELIVERING THE VISION Archives Revealed is a new funding programme from The National Archives and The Pilgrim Trust to support the cataloguing of archive collections. The programme will transform access to archives for a wide range of users, enabling more people to engage with the UK’s rich documentary heritage. DIGITAL IS DIFFERENT Archives provide value to society by keeping records and by providing access to them. Fundamentally, digital archives provide value the same way. In that context, preserve means trusted digital records are kept safe for the future so they can always be used. Contextualise means that digital records can be understood in the context of their creation and continuing use. Present means that open digital records are available and can be produced for users. Enable use means that we offer the ability for users to compute over all open digital records for research purposes as well as to enable indexing for search and discovery.
5.2 Preserve
We will widen the types of digital record we can preserve. We currently concentrate on images, document formats (for example, Word or Excel), email, videos and mixed media (including websites and tweets). We need to develop the capability to preserve structured datasets and computer code. This involves developing new capabilities for example to preserve geospatial information.
We will manage preservation risks to digital records much earlier. Through developing expert knowledge – both internally and externally – and taking practical steps like enabling earlier transfers for digital records, or advising government departments when they are developing new systems, we can counter some of the known difficulties of digital preservation. We need to develop tools such as DROID so that the digital preservation risks can be managed effectively for records we do not hold. From l-r: TNA catalogue refs – ZMAP 4/18, Hollar's Survey of the City of London 1667, and E 170/252, part of a tax hearth return taken just before the Great Fire of London, 1666 Public task and public value
Public Task
Public value
Potential public value
Public good
Merit good Thank you for listening
@UkNatArchives
@jeffddjames
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4d5e137f3a43f9b19c3dbf9e314046ddd62a2b0b | Archives Matter
- [Archives Inspire video played]¹
Introduction
- Thank you, it’s a great pleasure to be here.
- I hope you will agree with the conclusion of the video you’ve just seen. Archives across the globe are facing a paradigm shift. And while it’s an interesting and exciting time to be a part of it, we all recognise the need to work at pace to address the challenges and to embrace the opportunities on the horizon.
- So today, I’d like to talk about how The UK National Archives is collaborating with archives and other institutions in the UK and beyond, to meet this paradigm shift.
¹ nationalarchives.gov.uk/about/our-role/plans-policies-performance-and-projects/our-plans/archives-inspire/ • I’ll talk about our ambitious, audience-focussed **four-year strategic plan**, *Archives Inspire* that sets out to *change the way people think about archives*.
• I’ll talk about how the UK archive sector has **created its own robust and innovative strategic vision**.
• I’ll then share how we are working to embrace the challenges and opportunities digital technologies present, and **our strategy to meet these**. I will argue that it is only by collaborating and working in partnership that we’ll address these challenges. Finding pioneering solutions to problems like digital preservation is an **international team sport**.
• Finally, I’ll talk about how *Archives Inspire* broke with our past strategies, how it articulates what archives are *for* rather than what they do – and to that end, why archives across the globe can deliver so much more than their public task and, in doing so, fulfil their potential as a **public good**. Archives Inspire
- Imagine a world without archives. Without records, people could not prove where and when they were born, or who owns the property they live in. They could not trace their ancestry, explore their collective and individual identities, or hold government and organisations to account.
- The impact of archives is felt right across society, underpinning academic research, fuelling the digital economy and inspiring innovation and creativity.
- In short: archives matter!
- Over the last few years, the UK public has witnessed a rise in high-profile inquiries, and public appreciation of the importance of archives has never been higher. However, this comes with increased expectations about ease of access, and the ability to find everything at the click of a mouse.
- Archives are at a cross-roads. They face unprecedented opportunities, especially the ones offered by digital technology. But archives also need to undergo fundamental transformation if they are to capitalize on these opportunities. • In April 2015, the UK National Archives launched *Archives Inspire*, our ambitious, audience-focused, four-year strategy. It was a deliberate departure from our previous business plan, *For the Record, For Good*, which was largely an articulation of our public task to *collect, preserve and provide access* to public records.
• *Archives Inspire* speaks to the public good we deliver, **changing the way people think about archives** – by articulating what archives are *for*. It looks outwards, arguing that we need to think and organise ourselves differently, if we are to meet the needs of our four core audiences – government, the public, academia and the archive sector.
• From the outset, *Archives Inspire* explicitly identified **digital as the single biggest challenge** facing us all. Implicitly, it identified the need for greater collaboration and partnership across the UK and globally.
• *Archives Inspire* recognised the need to work together with the archive sector and its stakeholders to make the case for archives as a vital part of a nation’s heritage. In the UK, *Archives Inspire* was a catalyst for the archive sector to create its own strategic vision – *Archives Unlocked*. Archives Unlocked
- *Archives Unlocked* is the UK government's strategic vision for archives. It was launched by the then Minister for Digital and Culture in March 2017.
- The development of the vision was led by the UK National Archives. However, it was very much the sector's own vision, developed through an extensive process of co-creation with the sector and with key partners.
- The scale of the challenges facing archives can be overwhelming, so the vision needed to present an inspiring message for the future. It had to be practical and grounded to help guide archives through the change. It also needed to be something that resonated with the entire archive sector, while providing a compelling message for decision makers and funders.
- The UK benefits from an extensive and distributed archival collection, and from sound professional practice that has evolved over the last century. The UK National Archives is proud to lead and work with over 2,500 archives across the country. But the UK’s archives are funded by – and belong to – a wide range of organisations including: local authorities, universities, businesses; charities, religious bodies and private individuals.
- **Each archive is therefore different**, and the leadership approach to the sector needs to reflect this diversity. Together, the sector is an *ecosystem* of collections that intersect to form the rich tapestry that is the nation's documentary heritage. This is underpinned by a profession that is well-networked to support researchers to connect and analyse records from many different sources.
- The breadth and diversity of this archival infrastructure is a great strength, as it means archives are not dependent on one source of funding – and the ecosystem can evolve and adapt as funding climates change.
- However, such diversity also presents challenges when creating overarching strategies that are meaningful to such a broad constituency. • Furthermore, agendas can change quickly. So, the new vision needed to focus on the **fundamental values that archives bring to society**. This meant creating a vision that would remain inspiring over time – while providing both sustainability, and the impetus for sector transformation.
• The UK National Archives embarked on a year-long process of co-creation to develop the vision. From the outset, this was far more than just a consultation. The intention was to start with a blank sheet, **and for us to lead and work with the archive sector and stakeholders** to generate a vision that everyone felt they owned.
• It had to be a **real tool for change** – not a glossy brochure that sat forgotten on a shelf. The co-creation work began with a series of roundtable events throughout the country, attended by representatives from across the archive sector and beyond.
• The emerging vision was then tested through an open survey, and explored in a series of targeted interviews. We coordinated expert panels to draw in knowledge from organisations that sat within and around the archive sector, including digital bodies. • To support this, we pulled together a reference group of thought leaders, innovators and sector leads, who critically assessed the emerging vision in terms of **ambition and deliverability**.
• And from this wide-ranging co-creation process, a coherent message emerged about the role of archives. This was then distilled into three core values – (i) archives will strengthen society through the **trust** they inspire, (ii) the **enrichment** they offer, and (iii) their **openness** to all.
• Archives are homes for our collective memory. Records give us new and often very personal perspectives on what we thought we knew about the past. They are vital resources that underpin research and inspire creativity. They connect us to our past, inform our present, and illuminate our future. Most crucially, they allow society to **hold those who held power – in government and elsewhere – to account**.
• In 1989, ninety-six people tragically lost their lives owing to fateful overcrowding in a football stadium in Sheffield, in the North East of England. The Independent Police Complaints Commission, the body then responsible for overseeing complaints against police forces in England and Wales, conducted an investigation into this tragedy, which became known as the ‘Hillsborough disaster’. • The investigation provided a powerful example of trust, illustrating the vital role archives played in providing information and evidence to underpin the democratic process.
• The integrity of such archival processes, and the safe custody of records like these, reassure the public that archives can be relied on to support accountability.
• The vision used further case studies, including the archive of the children’s charity Barnardo’s, the archive of the John Lewis Partnership – one of the UK’s most prominent retailers – and the digital mapping project for the West of England, ‘Know Your Place’. These helped bring to life – in practical and inspiring ways – how archives are not just inspiring trust, but are also enriching people’s lives, and opening themselves up to innovative use, and re-use.
• These practical case studies were complemented by think-pieces from contributors within and beyond the archive sector, challenging existing norms and provoking new ideas for the future.
• Finally, the co-creation process explored the key development challenges facing the archive sector, to enable the creation of a clear action plan to underpin the vision. • This action plan was a vital part of building confidence in the vision, and in securing commitment from the wide range of delivery partners from across sectors. It was vital that the UK National Archives didn’t deliver the action plan in isolation.
• Three specific areas for development were identified within the action plan: (i) to build digital capacity, (ii) engineer resilience and (iii) demonstrate impact. The plan includes a wide range of initiatives under each area, including pilot programmes and innovation testing, targeted grants programmes, training programmes, guidance and advice.
Archives Revealed
• The focus for the first year has been on developing coherent and multi-layered strategies for workforce development and digital capacity building.
• The action plan is supported by over 1.5 million pounds(^2) of funding, including 825,000 pounds(^3) under Archives Revealed, a partnership programme between us, and the heritage grant-giving body, The Pilgrim Trust – with additional financial support from the Wolfson Foundation.
(^2) Approximately over 2,561,384.32 Canadian dollars
(^3) Approximately 1,408,949.96 Canadian dollars • For 2017-18, *Archives Revealed* also welcomed an additional 50,000 pounds(^4) of funding from the Foyle Foundation. It is the only funding stream available in the UK dedicated to **cataloguing and unlocking archival content**.
• From the Heritage Lottery Fund – the body in the UK which distributes lottery funding to heritage projects – a further 749,000 pounds(^5) was secured to help expand digital expertise across the archive sector.
• The funding for this ‘Bridging the Digital Gap’ initiative was awarded as part of the Heritage Lottery Fund's ‘Skills for the Future’ programme to fund 24 digital trainees. It aims to help drive forward the **digital archive skills** that are essential to the survival and promotion of the nation’s digital heritage.
• ‘Bridging the Digital Gap’ is supported by the Archives and Records Association – the professional body for archivists and records managers in the UK and the Republic of Ireland – and by the Digital Preservation Coalition.
______________________________________________________________________
(^4) Approximately 85,435.64 Canadian dollars
(^5) Approximately 1,274,739.29 Canadian dollars The digital challenge
- So, *Archives Unlocked* frames the major challenges facing the archive sector. Of those challenges, the **most pressing and the most urgent is the challenge of digital**.
- The shift to digital is transforming **every aspect of the archival landscape** – be it appraisal and selection, preservation, access, presentation or use.
- **Each and every archival function** is in the process of being profoundly changed. Where yesterday’s records were tangible, those of today and tomorrow are intangible. The very nature of what a record is has changed – from a world of letters, memos and minutes, to email, data and computer code. The ones and zeros **are the record**.
- Archives need to develop new capacity and capabilities to ensure that digital records can continue to be kept and used. It was therefore not surprising that, of the three major themes to emerge from *Archives Unlocked*, **digital capacity was at the forefront**. In the area of digital, the following actions were identified:
- **Scope** a programme to build digital capacity for the sector, to address digital preservation, discoverability and digitisation;
- **Foster** expertise and shared solutions through a learning set of archivists. This involves local and regional digital preservation projects;
- **Increase** access to archives through innovation in online catalogues, data collection, analysis and re-use;
- **Build** partnerships with digital and IT leaders to establish shared standards and models of good practice;
- And, **develop** the archive service accreditation scheme, to assess and support improved management of digital collections. • Since the vision was launched, we have worked hard to deliver initiatives to support this digital programme. An Archives Unlocked board has been established, comprising representatives not only from archives, but from the wider digital, professional and cultural sectors, to take forward the vision. Over the course of the rest of this year and 2019, a coherent strategy for digital capacity will also be developed, in conjunction with the board.
• In the meantime, we have already supported some specific initiatives. For example:
o Research in Dorset, in the south-west England, into digital audience expectations. This will be used as a template for other archives;
o Funding and support for a number of pilot projects in digital preservation;
o and, the delivery of digitisation seminars to help address sector need – delivered in collaboration with the arts organization, Tate; and the not-for-profit digital services and solutions body, Jisc. • In addition, the foundations have been laid for a number of broader pieces of work. These include kick-starting the facilitation of a Digital Action Learning Set, which will share learning through a series of events to join up knowledge and approaches. It also includes commissioning an audit of sector digital skills to inform a training and development programme.
• *Archives Unlocked* and the challenges it aims to address are of relevance to other sectors too. So, we have established a Memorandum of Understanding with Jisc, developed our current Memorandum with Research Libraries UK and, we continue to work on a range of issues with the Digital Preservation Coalition.
**Digital strategy**
• The digital capacity strand of *Archives Unlocked* does not, however, sit in isolation from the rest of the UK National Archives. It is closely connected to our digital strategy, which was launched in the same month as *Archives Unlocked*.
• The digital strategy’s focus on the areas of preservation, context, presentation, and enabling use, directly maps onto the *Archives Unlocked* ambitions of trust, enrichment and openness.
______________________________________________________________________
6 [nationalarchives.gov.uk/about/our-role/plans-policies-performance-and-projects/our-plans/digital-strategy/](http://nationalarchives.gov.uk/about/our-role/plans-policies-performance-and-projects/our-plans/digital-strategy/) • Trust in the digital archive can only be achieved if users can be assured of the **provenance and authenticity of the records** contained in it. Furthermore, it can only enrich and be open if people can use it and find what they need.
• Our digital strategy sets out a radical new departure in thinking. It recognises that many principles in archival theory are fundamentally challenged, and identifies some of the practices that **are holding us back in the digital era**. It maps out some of the completely new capabilities that we need.
• The strategy therefore sets out ambitious plans to meet the challenges presented by digital records by:
o *creating* the ‘disruptive’ digital archive;
o *extending* our reach and engaging new audiences using the web;
o *transforming* how the physical archive is accessed and used;
o *developing* digital capability, skills and culture; and, forging partnerships with other archives progressing digital transformation.
- This searching focus on the challenge of digital ensures that we can continue to provide leadership and support to the wider archive sector, as the outputs of this high-level work filter down into common practice.
- However, in order to achieve the paradigm shift and to find solutions to the digital challenges and opportunities facing archives, the sector also needs to invest in digital skills, and undertake digital research.
- That’s why, alongside the Heritage Lottery Funded programme, ‘Bridging the Digital Gap’, we are also investing directly in digital skills development. In 2017, five software developer apprentices from Ada, the National College of Digital Skills, started at the UK National Archives on a two-year apprenticeship as part of their foundation degree in Digital Innovation.
- Two years ago, we also commissioned work on digital research challenges, which was then subsequently taken forward to form a Digital Research Roadmap, since wrapped into our broader Research strategy. • Our Head of Research has now developed research themes, priorities(^7) and questions so funding can be targeted. Research partnerships have been developed to test approaches that will address some of the key problems raised by the shift to digital.
• Staff at the UK National Archives are already working on projects to explore innovative solutions. For example, the Archangel project, in partnership with the University of Surrey, is investigating whether distributed-ledger technology could provide a new approach to digital authenticity.
• Meanwhile, our recent research project, Traces through time, links methodologies to mathematical certainty measures, to suggest potential matches for archival search queries. This offers researchers results they might otherwise have missed.
• It is through research and partnerships such as these that the wider information sector, both nationally and internationally, will move forward.
(^7) nationalarchives.gov.uk/about/our-research-and-academic-collaboration/our-research-and-people/our-research-priorities/ Archives Inspire the world
- Indeed, **collaboration is the golden thread** that links the UK government’s vision for the sector, *Archives Unlocked* with our organisational strategy, *Archives Inspire* and our international strategy, *Archives Inspire the world*.
- *Archives Inspire the world* aims to **leverage international collaboration** to build a future for archives on a truly global scale.
- It’s an **international calling card** – encouraging partners from around the world to work together, to drive the development of an exciting future for archives. By working in partnership with other government bodies, archives, cultural and heritage organisations, academic institutions and businesses, we aim to help champion:
______________________________________________________________________
8 [nationalarchives.gov.uk/about/our-role/plans-policies-performance-and-projects/our-plans/archives-inspire-the-world/](http://nationalarchives.gov.uk/about/our-role/plans-policies-performance-and-projects/our-plans/archives-inspire-the-world/)
- **Collections** - by promoting their value and enabling greater access;
- **Digital** - by pioneering approaches for digital preservation;
- **Commercial** - by generating income through appropriate and profitable activity;
- **Research** - by developing innovative resources and networks to share knowledge and expertise;
- and, **Standards** - by supporting policy development, standard setting and access to legislation.
- Fortunately, archivists are born collaborators, and there should be no geographical borders to collaboration. The challenges and opportunities facing the UK archive sector are **shared by archives around the world**. This is especially true of digital access and preservation.
- As I said earlier, **digital preservation is an international team sport** but, like any sport, it requires determination, effort, and focus to achieve results, not just a predilection for collaboration. • Archivists are fortunate to work in a sector that finds itself at a ‘once-in-a-lifetime' watershed moment. They have the commitment and the appetite, if not yet all of the skills, to enable transformational change.
• As I said earlier, we are proud to be the leadership body for the UK archive sector, and privileged to be the custodian of some of the nation’s most iconic documents dating back more than 1,000 years. Archives present a uniquely personal experience within the cultural sector, and the sector must continue to engage audiences in new and exciting ways.
• However, the reality is that digital has also transformed the way that researchers and archivists think about records, the way that archives look after them, and the way that access is provided to them.
• But this isn’t about a shift from paper to digital. It is fundamentally about preserving and rejoicing in the nation’s physical documentary heritage, while also exploiting the endless virtual opportunities presented by digital technology. • Digital has transformed access to that shared content, **opening up** collections and transforming people’s lives wherever they live, irrespective of where the record resides.
• For the last 12-months, we’ve been working with volunteers from the Friends of the UK National Archives on an ambitious project to **open up** prisoner-of-war collections. This involves almost 200,000 records of allied servicemen captured in German-occupied territory in the Second World War. Not just British prisoners of war, but individuals from Australia, Canada, New Zealand and South Africa.
• While at its heart a traditional cataloguing initiative, the project blog has attracted comments from across the globe, connecting generations, and enhancing the **collective understanding of who we are, where we came from, and where we are going**.
• The discoverability of, understanding of, and access to collections across the world is being enhanced through partnership working. In 2017, we started a collaboration with the National Archives of the United Arab Emirates to digitise and make available records relating to the UAE and other Gulf States. The **Arabian Gulf Digital Archive** combines the skills and knowledge of both institutions to make available 500,000 images from our holdings. • In 2018, we also began a **ground-breaking 20-year research collaboration** with the University of Oldenburg – uncovering hundreds of thousands of letters and papers confiscated from ships captured by the British, between 1652 and 1815. The ‘Prize Papers’ project, as it’s known, is funded by the German Academy Programme, and is of unprecedented scale for a humanities research project.
• To capitalise on collaborative opportunities like these requires ambition and bold leadership not just at the local and national level but also globally.
• The Forum of National Archivists, or FAN is a section of the International Council on Archives. It is a body of national archivists responsible for developing high-level strategic responses to the contemporary challenges of managing archives.
• Like the UK, FAN has identified **digital as its key strategic priority**. It is now in the process of sharing best practice and digital resources while encouraging new approaches that **can inform and benefit national, regional and local practices**. • Recently FAN also recently delivered an international digital symposium that took place at the UK National Archives, exploring the use of artificial intelligence and machine learning in archives.
Widening the public value of archives
• I hope that what I’ve talked about so far today has demonstrated why archives truly matter. How they can make an impact across societies; how they inform a broad sweep of research disciplines; how they enable pioneering solutions in digital preservation, and how they inform digital economies.
• Yet, there is no getting away from the fact that archives need to be used to be useful. Those of us that work in archives may well recognise or own value and worth. But, against rapidly changing societal and economic contexts, and rapidly evolving digital technologies, the future for archives across the world is as uncertain as it is exciting! • I mentioned earlier that *Archives Inspire* set out to illustrate what archives are for, rather than what they do. There are things that we **have to do**, but there are also things that we **choose to do**. Alongside our core purpose or task – preserving records and providing access to our diverse collections – there are also the things we do that add to our value, to the audiences we serve.
• In considering how an archive might widen its **public value**, realising more benefits above and beyond its core purpose, we could ask ourselves a few key questions:
o Why are things the way they are?
o How might things be different for archives for the future?
o What does all of this mean for fulfilling our value as an archive, and in our case, as a public institution?
• We have come a long way since we started out on our *Archives Inspire* journey, but there are deeper strategic questions ahead. In our case, *Archives Inspire* will come to completion in April 2019, so it presents a timely moment to ask the question – What’s next? What more of our potential might we realise? • It might help to frame this by way of a story. At their best, archives are storytellers, after all.
• At the UK National Archives, we have a wonderful education service. We believe it's vital to bring children into direct contact with the primary sources we hold.
• Our Head of Education could tell this story perhaps better than me, but in essence, here's how it goes. In every school in the UK, five and six year olds learn about the Great Fire of London in 1666. Indeed, speak to a six year old and you will find that they know a lot about the Fire. They know where and when it started, and how much of the city burned. They know that the fire started in Pudding Lane.
• When groups of five and six year olds come to visit us at Kew, there is, therefore, little to be gained from teaching them about the Great Fire of London – they know it all already! Instead, we teach them about the importance of evidence, by way of a momentary existential crisis.
• We ask the children to tell us what they know about the Fire. We compile the whole story from these young minds and from what they know. And then we ask them, how do they know? • The typical answers that come back are usually ‘my teacher or my mum told me’, and we gently point out that, old as their teacher may be, they weren't alive in 1666. It is then that you see the thought dawning on the children. How do we know? In fact, how do we know anything? How do all of these people telling us all these things know anything?
• At this precise moment, the moment of crisis and doubt, we introduce them to the record.
• [See slide 8 of the Archives Matter PowerPoint presentation]. On the image on the right, you can see the name Thomas Farriner, Baker who owned one oven on Pudding Lane. It is amazing to see a child respond to seeing this document. This is how we know; we know because of the record. It's not just what we've been taught – it is what the evidence leads us to understand.
• Hopefully, those children will grow up and still work with, and enjoy, and experience the joy of discovery that is the archive, and remember the importance of evidence.
• This joy of discovery is a huge part of what it means to experience an archive. But – it’s also interesting to think about what the joy of discovery will be for records that are in a very different form, in the digital age. Aided by advanced technologies, what new discoveries might we be able to unearth from our extraordinary collections?
- Thinking about the future, it’s today’s children who will perhaps most benefit from our work – to identify, capture and preserve the current record of government, as prospective users of the archive in 20 or 30 years’ time.
- The right information, in the right place, has the power to change lives. The rise of the World Wide Web has given wonderful opportunities to archives. It has enabled us to reach and engage new audiences. By making our catalogues available online, people who never knew that an answer to their question might be found in an archive, can find us in a click from a Google search. With digitised content, learning resources and research guides – the archive is in people’s hands in a way that was unimaginable 20 to 30 years ago.
- The economics of content in the information age also pose new questions. At the UK National Archives, we’ve pioneered the commercial digitisation of our collection; and it has worked brilliantly to widen access. But, it also means people pay for the content they use when accessing the archive from home. We work hard to avoid it, but in charging, there is a risk that some people might be excluded. But without charging, hundreds of millions of records would never have been digitised in the first place.
- What is the right thing to do for an archive in this scenario? What are the right sets of decisions? Especially when funding constraints exist, and archives need to turn to additional sources of funding to open up their collections?
- It’s a tricky issue. We are long time advocates of the benefits of open data. But, we are also a cultural and heritage institution looking to maximise our public value with rich content online – more than we can afford to produce with taxpayer funding alone – and through the power of physical records, by drawing people into the archive through inspiring events and activities.
- So, how do we go about maximising our public value? How does this relate to our public task? Where best to deploy our taxpayer funding, and how do we take advantage of commercial opportunities in the service of our strategy? • Our public value is so much bigger than the sum total of the things we have to do, to meet our legal obligations. Archives Inspire speaks to a sense of a wider public value – and potential value beyond that. As I mentioned earlier, the strategy sets out how an archive is hugely useful for many different people, for many different purposes, and that we should act to help realise more of our potential.
• So, we are rightly focussed on the things the law says we must do, on our public task. But, we are also keenly aware of the things we might choose to do, and know what we are capable of doing as an archive, such as educating children.
• When we look into the future, underlining all of this is a wider sense of the potential value of archives – and this potential is enormous.
• We are all having to change the ways in which we work, and how we engage with the world because funding is scarce. Funding constraints concentrate the mind, but we have also known for decades that we are more than the common expectations people hold. • We have already found new ways for people to access our collections, such as making more records available online. And, this wider sense of public value already exists at the heart of Archives Inspire – a determination to realise more of our potential, coupled to the belief that archives matter – for our societies and our economies.
• In economic terms then, the archive is part Public Good and part Merit Good.
• Some of what we do is a pure public good. We offer value that is both non-excludable and non-rivalrous:
o Having non-excludable value means that archives can be considered in the same way as the criminal justice system. Everyone benefits from the system, and if it is funded, you cannot exclude anyone from receiving the benefits.
o An archive is also non-rivalrous. Its value doesn’t get diminished through its use. • We are also an economic **public good** in at least two respects:
o **Preservation** - by keeping records in the present we make it possible for people in the future to benefit from the archive.
o **Intellectual control** - by cataloguing our collections, we enable people to reference the records we hold. People can make claims based on records held in the archive, and point to a source.
• But the archive is also a **Merit Good**. There are things that we do that are simply beneficial for society. For instance, at the UK National Archives, we provide free access to our reading rooms, and, as I mentioned before, we provide ways for children to experience original evidence that complements their state education.
• Understanding all of this helps us be clear about how we deploy the funding we receive from Her Majesty’s Treasury. This is important because in real terms, our government funding is getting smaller. • We could just concentrate on delivering our core public task, be more efficient, and do things for less. But, if we stuck to that world view, we’d cease to realise the **value of the archive beyond what the law requires us to do.** The potential public value of the archive would go unmet.
• *Archives Inspire* says we will widen the public value of the archive. When we generate commercial income, for example, with projects such as the Arabian Gulf Digital Archive, it is to fund our wider public value.
• This is one of the reasons why we are looking to expand our revenue base by setting up a charitable arm, The National Archives’ Trust.
• This is really important when it comes to looking at, for instance, what we do with our website and charging. At present, we are also exploring introducing a subscription offer on our website – partly to raise money, but mainly to realise **more of our value** by having a more effective system for charging. This could grow the numbers of people that are using our collection, and **widen the amount of use they are making of it.** • It’s a difficult concept, but finding ways in which we can do this online is a huge opportunity for us and our audiences.
• So, what are the yardsticks for thinking about this? What is our public task? What has the taxpayer paid for? Where is the market demand? Is this something only we can do, or something other people can do? What should be free? What are our constraints? Can we identify the sweet spots – where we both widen our public value and generate income – as we have done with commercial digitisation?
• These are quite a complex set of things to think through, and being clear about the economics – the archive as a public good; the archive as a merit good – helps.
• It comes down to a **determination to maximise the public value of the archive**. That we have so much more to offer than our statutory obligations. In essence, it means thinking hard about the value we can provide for the children of today, and for them as the future researchers of archives that we hope they will be in 20 or 30 years. Conclusion
- This is a truly exciting time for archives. For those who care for them and for those who use them. The records, both physical and digital, held in archives around the UK and across the world can change people’s lives.
- There is no doubt in our minds that archives matter. The challenge for archivists is to ensure that the records of the past and the future not only survive, but thrive.
- By working in partnership, locally, national and globally as part of a broader archive ecology, archives can ensure that more and more people are connected and inspired by the records they look after.
- Our audiences are mostly aware of our most popular story – that we protect the records about the heritage of our nations. But our public value is so much wider than what people know and believe. It is up to us to act, to realise the enormity of the potential we can wield. • But digital technologies are fundamentally transforming the global archive community as we know it, and it will keep rapidly changing for the foreseeable future. The opportunities ahead are within our reach. Ultimately, together, we can help change the way people think about archives, now and forever.
End of speech
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34b51607fda34d98e473699dd0921d6418105b49 | Collection Development Policy for The National Archives’ Library
© Crown copyright 2015
You may re-use this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence or email [email protected]. Introduction
This policy is intended to evolve and develop in line with the strategic priorities of The National Archives (TNA), especially in areas of research and teaching. It will be reviewed regularly, in particular to keep up-to-date with technological advances in electronic publications such as e-books.
1. Library mission
The National Archive's Library provides a research level, publicly accessible information service to:
- aid interpretation, use and preservation of The National Archives' holdings;
- support the corporate decision-making, professional roles and research requirements of The National Archives;
- support the development of National Archives' staff.
It does this by the provision of published materials in appropriate media and by the provision of information systems and services that facilitate the exploitation of its materials. It also provides expert staff, including professionally qualified librarians, who are knowledgeable about the collection and its management.
2. Collection overview
The Library was founded at the time the Public Record Office was established in 1838. It incorporates two early collections; that of the Record Commission, which provided its original nucleus, and that of the State Paper Office, which was absorbed into the new Public Record Office building in Chancery Lane in 1854. In 2003 the Historical Manuscripts Commission (HMC) joined with the Public Record Office to form The National Archives. At that time HMC’s library collection came to Kew. The whole Library collection is listed on the online Library Catalogue.
The Library is a specialist library that is distinctive because it is a library collection within an archive. It is also a research level library, covering British history that is freely available to the public. Unlike similar libraries, the majority of the collection is on open access and can be browsed. The collection includes printed materials from the 16th century onwards, and continues to be developed and added to. The collection consists of primary published materials, for example directories from the 18th, 19th and 20th centuries and topographical publications published at a time when the study of antiquities, topography and genealogy was developing. It also includes secondary published sources that provide contextual information relevant to the subject areas covered by the public records, and many publications that reference the public records and can be used as additional finding aids.
The Library provides published resources for all TNA departments as required. Some departments house books and journals directly relevant to their business areas, for example Collection Care, but they are all accessible through the Library Catalogue.
3. Core collection definition
The National Archives' Library covers the following core areas:
3.1 Materials which directly facilitate access to the original records of central government, the law courts and the armed services held by The National Archives, from the 11th century onwards, especially where citations to documents held by The National Archives are provided. Such works include: works on the military forces in all aspects; historical monographs on politics and government, social and economic history, the intelligence agencies, trade and commerce, transport, the history and working of the English law courts, seals and palaeography.
3.2 Materials which directly facilitate the use of the records for research on British overseas policy, from the medieval period onwards, especially where citations to documents held by The National Archives are provided. Such works include: histories of British foreign policy and policy making bodies; imperial and colonial histories; histories of individual countries and regions.
3.3 Materials which directly facilitate the use of records for the study of personal and local history, such as guides to genealogical and family history or publications of local record offices, especially where citations to documents held by The National Archives are provided. 3.4 Materials which provide guidance to other repositories and their holdings in the British Isles and selected publications of national and other archives around the world, particularly those published guides, directories, reports and surveys required to sustain the work of the National Register of Archives.
3.5 Professional literature in archives and records management, which provide essential corporate and personal development information; public sector and other management in general; finance; human resource management; staff development; conservation; information technology and information studies in general.
4 Audiences
The Library is available for any user of The National Archives. It is available to onsite visitors on a reference basis. TNA staff may borrow material to support their daily business, teaching, learning and research needs.
5 General principles
5.1 We will align new acquisitions with TNA’s research priorities.
5.2 The Library collects printed or online published resources. It does not collect manuscripts or archives or maps, although there are a few examples of these within the existing collection.
5.3 The usual readership level is postgraduate. However, there will be exceptions where material is required or donated that is at a more general level but is still relevant to the collection.
5.4 As a general rule rare books (i.e. publications published before 1850) are not acquired and the rare book collection is not being added to other than from existing collections. However, if a book was identified as an essential addition to the collection for its content, acquisition would be considered, depending on cost, availability elsewhere, condition of the item and any other factors that may need to be considered.
5.5 Duplication will be avoided unless multiple copies are required between enquiry points or departments or usage of material warrants retaining multiple copies. Duplicate copies of material identified as part of the Heritage collection (see 9.1) will be retained.
5.6 Items for personal use, not meeting the core collection definition, will not be acquired.
5.7 Electronic resources are available for onsite access only to the public; remote access is available for staff to some resources. 5.8 Suggestions for purchase are welcomed from any reader or member of staff of The National Archives, but the final decision for selection rests with the Librarians.
5.9 The Library does not operate an Exchange programme.
6 Formats 6.1 Printed material is primarily collected in hardback format for long-term preservation reasons; paperback books will be acquired if hardback is not available.
6.2 The Library arranges books into three sizes: up to 30 cm in height is standard size; over-size is between 31 and 40 cm; and over-over-size over 40 cm.
6.3 Other printed formats include:
- pamphlets, including off-prints of journal articles – defined by the Library as an item where the spine is too thin for a spine label;
- journals or periodicals – publications received on subscription and published periodically, for example monthly, fortnightly, annually etc.;
- annuals – books published once a year such as Who’s Who or Whitaker’s Almanac.
6.4 The Library also acquires electronic publications including full-text databases, online reference sources, electronic journals and we are now beginning to add e-books. Currently technical, archiving and legal issues around access to electronic resources limit a whole-sale move towards electronic delivery of published materials. However, the long-term aim is to acquire more electronic material and to reduce the amount of printed material that is collected.
6.5 Although some material acquired in the past is held on CD-Rom this format is no longer collected because there are no means of providing access to the public. Where a printed book includes a CD-Rom, the CD is removed and stored in the Library office area but cannot be made publicly available. A note to this effect is added to the catalogue description of that book. 7 Language
The majority of the collection is in English, although a wide range of other languages are represented, especially European languages. As a general rule we do not collect material in languages using non-roman script such as Chinese, Japanese, and Arabic. However, if a publication was of particular significance for the collection, for example because of research using records held at The National Archives, then acquisition would be considered if it is possible to transcribe the publication details to create a bibliographic description for the Library catalogue.
8 Constraints
There are some constraints to acquiring comprehensively in any area.
8.1 Budget
The Library purchases material in the most appropriate and cost effective way, using framework agreements where possible. The Library budget is reviewed each year and is limited by overall TNA budget requirements.
8.2 Space
Growth space for the Library collection is finite. Material categorised under the Self-renewing or Finite categories in point 9 below, will be reviewed and withdrawn as appropriate to maintain space.
8.3 Data protection/copyright
For Copyright reasons photocopies of journal articles or books cannot be added to the Library collection unless they have been made for preservation reasons or to replace lost copies from the collection. Off-prints of journal articles can be added to the collection. Current directories received through society memberships are not added to the collection for data protection reasons, particularly if personal data is listed. 9 Donations
The Library benefits from donations of individual items, and occasional collections, and continues to welcome offers of gifts and donations in line with the Collection Development Policy. We do not accept bequests or material on deposit or loan. Where possible one copy of any book published in association with The National Archives will be donated to the Library. If further copies are required they will be purchased. In addition, copies of PhD theses by students on TNA’s Collaborative Doctoral Award scheme, will be donated to the Library.
Donations are accepted if they cover the core collection definitions set out in section 3 above. We generally do not accept personal memoirs or family histories of individuals, even where documents held by The National Archives have been cited. We cannot accept photocopies of publications that are still in copyright. We do not accept duplicate copies of publications already in the library collection, unless there are specific reasons for having multiple copies. The language of the item must fit with the policy described in section 7 above.
The following factors will be considered when determining the acceptance of donations:
- Value to the Library collection – does the item fit with the Collection development policy including any references to TNA documents;
- Intrinsic value – does the item have intrinsic value, for example is it rare or unusual;
- Collection care – is the material in a suitable physical condition to be added to the Library collection without incurring additional cost;
- Stock management – is there appropriate space to store the material;
- Cataloguing – is there resource for cataloguing large collections of material in particular;
- Gifts are accepted on the understanding that any unwanted material may be disposed of according to Library policy.
10 Collections
This document uses the types used by Leeds University Library and Bradford University Special Collections to categorise the collection.
10.1 Heritage. Collections, or clusters of collections, which are unique, distinctive and relevant to our mission. We are recognised as and expected to be specialists in these areas. These areas are our priority for collection management and collection development and are to be retained permanently. Completed publications no longer being acquired
- Material with State Paper Office ownership stamp – this originated with the State Paper Office, a forerunner of the Public Record Office, and forms part of the original library collection. Further work is required to identify this material and note the presence of a stamp on the bibliographic record.
- Record Commission publications – material acquired by or originating from the Record Commissions between 1800 and 1831, including Statutes of the Realm, and early Charter, Patent and Close Rolls.
- ‘Rare book collection’ – all material published up to 1800 plus some specific items beyond this date.
- Lists and Indexes publications – maintain one complete set in the Library. Other specific volumes held in reading rooms and enquiry points as required.
- Rolls Series – maintain one complete set.
- Annual reports of the Deputy Keeper and Keeper of the Public Record Office. For current annual reports see Current acquisitions below.
- Material listed on the English Short Title Catalogue as held by TNA. Further work is required to identify these.
- Annotated set of Historical Manuscript Commission (HMC) reports.
Current acquisitions
- Calendars – maintain one complete set of all Calendars of public records in the Library with duplicate volumes in the Map and Large Document Reading Room and Staff Reading Room as required.
- List and Index Society publications. One complete set is maintained in the Library. Additional copies will be acquired for the Map and Large Document Reading Room as required.
- Other material relating to the history of the Public Record Office, the Historical Manuscript Commission and the Office of Public Sector Information prior to them joining the Public Record Office to form The National Archives. This may include histories of these institutions or material owned by former members of staff and containing ownership marks and/or manuscript annotations.
- Local history/topography/cartography – this is one of TNA’s core collections, with many books having been acquired at the time of publication in the early 19th century. The subject is part of the Public History subject area which has its own subject team within Advice and Records Knowledge Department. We will continue to collect selectively in this area and will acquire all volumes of the Victoria County History as published, and all publications from the various English local record societies.
- Seals, Palaeography and Diplomatic.
- Military history – material relating to activities of the HM Forces.
- History of government departments including directories such as Army Lists or Foreign Office lists, official histories. • Publications relating to the administration of government and the courts – critical to understanding of how the records are organised throughout history. • PRO/TNA publications – ensure one copy of each publication is retained including previous editions. • History of public records and record keeping including early guides to the records such as those by Thomas Francis Sheppard, Samuel Robert Scargill-Bird and Montague Spencer Giuseppi. • Transcriptions or facsimiles of public records or other key historical documents, for example all facsimiles of Domesday Book. • Journals that directly relate to the records and may include transcriptions – Pipe Roll Society, Hakluyt Society, Navy Records Society, Camden Society, Harleian Society. • Annual reports of The National Archives. • Archival practice, digitisation and training in archival services delivery.
10.2 Legacy. Like Heritage collections, these materials are unique or distinctive. However they are a lower priority for collecting because they are less relevant to our mission, already collected by others with a stronger claim, or already complete with little scope for enhancement. They are to be retained for the foreseeable future because they are important materials which are well used, but we will only add where this is essential to enhance or interpret existing materials.
• Directories and Annuals such as Post Office Directories. • Statutes and Statutory Instruments. • Journals of House of Commons and House of Lords. • History of bibliography – catalogues of other libraries. • Sales catalogues for Archive Services Development.
10.3 Self-renewing. This is material intended to be self-renewing, to support our services to visitors and enquirers and/or to assist staff and volunteers in their work and research. Examples include reference works, working copies in remote offices, librarian and archivist textbooks, professional standards, manuals and reports. Superseded editions will be replaced as appropriate. Examples include:
• IT software manuals. • Family history series such as Gibson Guides. • Current language dictionaries.
10.4 Finite. Material which is no longer relevant. We aim wherever possible to de-accession this material, to enable us to concentrate resources on material which is relevant, and to allow it to be more useful in a different context. Material is de-accessioned in line with the Retention and Disposal policy. Examples include: • Duplicate copies no longer required. • Material damaged beyond repair or where costs of repair outweigh value of content. • Annual reports – annual reports are often donated by a range of national and international organisations. Those from other national archives, and from organisations of direct relevance to The National Archives, if not available online will be held for five years before being considered for disposal.
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a4a6b1561acbc4dd0aa0eaad4e560d3814edf925 | European Freight Licence
granted to
[ ]
Reference Number: UK 01 [YEAR] [XXXX]
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | | 1 |
| Part II - Interpretation | PAGE | |--------------------------|------| | | 2 |
| Part III - Revocation | PAGE | |--------------------------|------| | | 4 | Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by regulation 6 of the Railway (Licensing of Railway Undertakings) Regulations 2005 ("the Regulations"), hereby grants to [name of licensee], company registration number [number], ("the licence holder") a licence authorising the licence holder:
(a) to be the operator of trains being used on a network for the purpose of carrying goods by railway;
(b) to be the operator of trains being used on a network for a purpose preparatory to or incidental to or consequential on using a train as mentioned in (a) above; and
(c) to be the operator of trains being used on a network for the purpose of assisting other operators of railway assets.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked or suspended in accordance with the provisions of Part III or the Regulations.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of trains pursuant to this licence.
2. In interpreting this licence, headings shall be disregarded.
3. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
4. The provisions of section 149 of the Railways Act 1993 (as amended) (“the Act”) shall apply for the purposes of the service of any document pursuant to this licence.
5. Unless the context otherwise requires, terms and expressions defined in the Act, the Railways Act 2005, or the Regulations shall have the same meanings in this licence. Part III - Revocation
6. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing with the licence holder.
7. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator), revoke this licence by not less than three months' notice to the licence holder:
(a) if the licence holder has not commenced carrying on licensed activities within six months beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least six months;
(b) if the licence holder is convicted of an offence under section 146 of the Act or regulation 15 of the Regulations in making its application for this licence; or
(c) if a person obtains control of the licence holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
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a8b97d486935662f19b50fb9135ce2e1b5a77925 | European Passenger Licence
granted to
[ ]
Reference Number: UK 01 [YEAR] [XXXX]
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | | 1 |
| Part II - Interpretation | PAGE | |--------------------------|------| | | 2 |
| Part III - Revocation | PAGE | |--------------------------|------| | | 4 | Part I - Scope
1. The Office of Rail and Road (“ORR”), in exercise of the powers conferred by regulation 6 of the Railway (Licensing of Railway Undertakings) Regulations 2005 (“the Regulations”), hereby grants to [name of licensee], company registration number [number], (“the licence holder”) a licence authorising the licence holder:
(a) to be the operator of trains being used on a network for the purpose of carrying passengers by railway;
(b) to be the operator of trains being used on a network for a purpose preparatory to or incidental to or consequential on using a train as mentioned in (a) above; and
(c) to be the operator of trains being used on a network for the purpose of assisting other operators of railway assets.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked or suspended in accordance with the provisions of Part III or the Regulations.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of trains pursuant to this licence.
2. In interpreting this licence, headings shall be disregarded.
3. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
4. The provisions of section 149 of the Railways Act 1993 (as amended) (“the Act”) shall apply for the purposes of the service of any document pursuant to this licence.
5. Unless the context otherwise requires, terms and expressions defined in the Act, the Railways Act 2005 or the Regulations shall have the same meanings in this licence. Part III - Revocation
6. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing with the licence holder.
7. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator), revoke this licence by not less than three months' notice to the licence holder:
(a) if the licence holder has not commenced carrying on licensed activities within six months beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least six months;
(b) if the licence holder is convicted of an offence under section 146 of the Act or regulation 15 of the Regulations in making its application for this licence; or
(c) if a person obtains control of the licence holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
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7bda127e9309276dd9e3a31389ce531dae458527 | Statement of National Regulatory Provisions
(SNRP): Freight
granted to
[ ]
Reference Number:
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | Part II - Interpretation | 2 | | Part III - Conditions | 4 | | Condition 1: Insurance Against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 8: RSSB Membership | 6 | | Condition 9: Safety and standards | 7 | | Condition 10: Environmental Matters | 8 | | Condition 11: Payment of Fees | 9 | | Condition 12: Change of Control | 10 | | Condition 28: Rail Delivery Group | 11 | | Part IV - Revocation | 12 |
Note: Conditions 3 – 7 and 13 – 27 are not used in this SNRP. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by regulation 10 of the Railway (Licensing of Railway Undertakings) Regulations 2005 ("the Regulations"), hereby grants to [name of SNRP holder], company registration number [number], ("the SNRP holder") an SNRP including the Conditions set out in Part III.
2. This SNRP shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this SNRP:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the SNRP holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the SNRP holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the SNRP holder or of the voting power in the SNRP holder; or
(ii) such part of any issued share capital of the SNRP holder as would, if the whole of the income of the SNRP holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the SNRP holder or in any other circumstances, entitle him to receive 30% or more of the assets of the SNRP holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the SNRP holder in its capacity as operator of trains pursuant to its European licence.
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this SNRP to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this SNRP, headings shall be disregarded.
4. Where in this SNRP the SNRP holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the SNRP holder fails to comply with that obligation within that time limit.
5. Where in this SNRP there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this SNRP as if it were an Act.
7. The provisions of section 149 of the Railways Act 1993 (as amended) (“the Act”) shall apply for the purposes of the service of any document pursuant to this SNRP.
8. Unless the context otherwise requires, terms and expressions defined in the Act, the Railways Act 2005, or the Regulations shall have the same meanings in this SNRP. Part III - Conditions
Condition 1: Insurance Against Third Party Liability
01. The SNRP holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
02. The SNRP holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
03. Except with the consent of ORR, the SNRP holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangements:
(a) under which the SNRP holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 8: RSSB Membership
04. If the SNRP holder’s annual turnover has never exceeded £1 million and the SNRP holder is not a franchise operator, paragraphs 2 and 3 shall not have effect until the SNRP holder’s annual turnover exceeds £1 million for the first time. The SNRP holder shall provide ORR with such information in respect of its annual turnover as ORR may from time to time require.
05. With effect from the date of the coming into force of this SNRP, except where ORR consents otherwise, the SNRP holder shall:
(a) become and thereafter remain a member of RSSB;
(b) comply with its obligations under the Constitution Agreement and the articles of association of RSSB; and
(c) exercise its rights under the Constitution Agreement and the articles of association of RSSB so as to ensure that RSSB shall act in accordance with the Constitution Agreement.
06. With effect from the date of the coming into force of this SNRP, the SNRP holder shall comply with the Railway Group Standards Code prepared by RSSB.
07. When a SNRP holder first becomes subject to the obligations in paragraphs 2 and 3 his rights, obligations and liabilities associated with such membership shall commence on the same day, and the SNRP holder shall complete the formal and legal documentation associated with such membership within three months of that date.
08. In this Condition:
“franchise operator” includes an operator of last resort, under section 30 of the Act. Condition 9: Safety and standards
09. The SNRP holder shall comply with:
(a) such Railway Group Standards as are applicable to its licensed activities; and
(b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
10. The SNRP holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where:
(a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and
(b) it has adopted and complying with that measure.
11. In this Condition:
“Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and
“Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
12. The SNRP holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
13. The environmental arrangements shall:
(a) take due account of any relevant guidance issued by ORR;
(b) be effective within six months beginning with the day on which this SNRP comes into force; and
(c) be reviewed by the SNRP holder periodically, and otherwise as appropriate.
14. Nothing contained in paragraph 1 shall oblige the SNRP holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the SNRP holder.
15. The SNRP holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a current copy of the policy together with a summary of the operational objectives and management arrangements.
16. The SNRP holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
17. In respect of the year beginning on 1 April [current financial year] and in each subsequent year, the SNRP holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this SNRP, as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this SNRP or any class of SNRP of which ORR determines that this SNRP forms part.
18. The payment shall be rendered by the SNRP holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the SNRP holder of its amount. Condition 12: Change of Control
19. The SNRP holder shall, if any person obtains control of the SNRP holder, notify ORR as soon as practicable thereafter. Condition 28: Rail Delivery Group
20. The SNRP holder shall:
(a) become and thereafter remain a Licensed Member of RDG;
(b) comply with its obligations under the RDG Articles; and
(c) procure that any member of its Group that is entitled under the RDG Articles to become a Member of RDG:
(i) becomes and thereafter remains a Member of RDG; and
(ii) complies with its obligations under the RDG Articles.
21. In this Condition:
“Group” has the meaning ascribed to it in the RDG Articles;
“Licensed Member” has the meaning ascribed to it in the RDG Articles;
“Member” has the meaning ascribed to it in the RDG Articles;
“RDG” means the Rail Delivery Group (a company limited by guarantee and registered in England and Wales under number 08176197); and
“RDG Articles” means the articles of association of RDG. Part IV - Revocation
22. ORR may (after having consulted the appropriate franchising authority where the SNRP holder is a franchise operator) revoke this SNRP at any time if agreed in writing by the SNRP holder.
23. ORR may (after having consulted the appropriate franchising authority where the SNRP holder is a franchise operator) revoke this SNRP by not less than three months’ notice to the SNRP holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the SNRP holder of any Condition, and the SNRP holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the SNRP holder stating that this SNRP will be revoked pursuant to this term if the SNRP holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined;
(b) if the SNRP holder has not commenced carrying on licensed activities within six months beginning with the day on which this SNRP comes into force or if the SNRP holder ceases to carry on licensed activities for a continuous period of at least six months;
(c) if the SNRP holder is convicted of an offence under section 146 of the Act or regulation 15 of the Regulations in making its application for this SNRP; or
(d) if a person obtains control of the SNRP holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the SNRP holder stating that ORR proposes to revoke this SNRP in pursuance of this paragraph unless the person who has obtained control of the SNRP holder ceases to have control of the SNRP holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
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34b7d96bd3508119d5c30e92ac8a65cb92ca99eb | Light Maintenance Depot Licence
granted to
[ ]
Reference Number: UK 03 [YEAR] [XXXX]
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | Part II - Interpretation | 2 | | Part III - Conditions | 4 | | Condition 1: Insurance against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 9: Safety and standards | 6 | | Condition 10: Environmental Matters | 7 | | Condition 11: Payment of Fees | 8 | | Condition 12: Change of Control | 9 | | Condition 13: Non-Discrimination | 10 | | Condition 14: Emergency Access | 11 | | Condition 16: Changes to the Schedule | 12 | | Part IV - Revocation | 13 | | Schedule - List of Light Maintenance Depots | 15 |
Note: Conditions 3 – 8 and 15 are not used in this licence. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by section 8 of the Railways Act 1993 (as amended) ("the Act"), hereby grants to [name of licence holder] company registration number [number], ("the licence holder"), a licence authorising the licence holder:
(a) to be the operator of the light maintenance depots listed in the Schedule; and
(b) to be the operator of any train being used on a network for a purpose preparatory or incidental to, or consequential on, the provision of light maintenance services at any light maintenance depot listed in the Schedule
subject to the Conditions set out in Part III.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of light maintenance depots or trains pursuant to this licence.
“light maintenance depot” includes network insofar as any light maintenance depot is also a network.
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this licence to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this licence, headings shall be disregarded.
4. Where in this licence the licence holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the licence holder fails to comply with that obligation within that time limit.
5. Where in this licence there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
7. The provisions of section 149 of the Act shall apply for the purposes of the service of any document pursuant to this licence.
8. Unless the context otherwise requires, terms and expressions defined in the Act and the Railways Act 2005 shall have the same meaning in this licence. Part III - Conditions
Condition 1: Insurance against Third Party Liability
01. The licence holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
02. The licence holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
03. Except with the consent of ORR, the licence holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangement:
(a) under which the licence holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 9: Safety and standards
04. The licence holder shall comply with:
(a) such Railway Group Standards as are applicable to its licensed activities; and
(b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
05. The licence holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where:
(a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and
(b) it has adopted and is complying with that measure.
06. In this Condition:
“Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and
“Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
07. The licence holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
08. The environmental arrangements shall:
(a) take due account of any relevant guidance issued by ORR;
(b) be effective within six months beginning with the day on which this licence comes into force; and
(c) be reviewed by the licence holder periodically, and otherwise as appropriate.
09. Nothing contained in paragraph 1 shall oblige the licence holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the licence holder.
10. The licence holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a current copy of the policy together with a summary of the operational objectives and management arrangements.
11. The licence holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
12. In respect of the year beginning on 1 April [current financial year] and in each subsequent year, the licence holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this licence as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this licence or any class of licence of which ORR determines that this licence forms part.
13. The payment shall be rendered by the licence holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the licence holder of its amount. Condition 12: Change of Control
14. The licence holder shall, if any person obtains control of the licence holder, notify ORR as soon as practicable thereafter. Condition 13: Non-Discrimination
15. Except in so far as ORR may otherwise consent, the licence holder shall not in its licensed activities, or in carrying out any other function contemplated by this licence, unduly discriminate between particular persons or between any classes or descriptions of person. Condition 14: Emergency Access
16. During any emergency affecting the railway, the licence holder shall, to the extent that it is legally entitled to do so, grant to any person requesting it such permission to use any light maintenance depot of which the licence holder is the operator pursuant to this licence as is necessary or expedient to alleviate the effects of the emergency. Condition 16: Changes to the Schedule
17. If the licence holder serves notice on ORR requesting that it be authorised to operate an additional light maintenance depot, that light maintenance depot shall be added to the Schedule on the date ORR receives the notice.
18. If, within 30 days of receiving the notice referred to in paragraph 1, ORR serves notice on the licence holder that it objects to such authorisation, that light maintenance depot shall be removed from the Schedule on the date the licence holder receives the notice.
19. If the licence holder ceases to be the operator of any light maintenance depot listed in the Schedule, the licence holder shall, within 30 days, serve notice on ORR of such cessation. That light maintenance depot shall be removed from the Schedule on the date ORR receives the notice. Part IV - Revocation
20. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing by the licence holder.
21. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than three months' notice to the licence holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the licence holder of any Condition, and the licence holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the licence holder stating that this licence will be revoked pursuant to this term if the licence holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined;
(b) if the licence holder has not commenced carrying on licensed activities within one year beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least one year;
(c) if the licence holder is convicted of an offence under section 146 of the Act in making its application for this licence; or
(d) if a person obtains control of the licence holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
3. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than 10 years’ notice, such notice not to be given earlier than 25 years after the date this licence takes effect. Schedule - List of Light Maintenance Depots
[Depots to be listed individually]
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926c1a8bda8ced3a8a4ede7d49fe90783b0ad11a | NOTICE OF MODIFICATION
1. The companies listed in the schedule to this notice have been granted licences and statements of national regulatory provisions (SNRPs) to operate railway assets under section 8 of the Railways Act 1993 (the Act) or regulation 10 and schedule 4 of the Railway (Licensing of Railway Undertakings) Regulations 2005 (the Regulations).
2. In accordance with section 12(2) of the Act and regulation 13(2) of the Regulations, on 2 February 2006, the Office of Rail Regulation (ORR) gave notice of its proposal to modify certain licences and SNRPs. The notice required any representations or objections to the modification to be made on or before 2 March 2006.
3. ORR has considered the representations or objections which were received during the consultation period and which were not withdrawn. On 30 March 2007 we issued a notice of modification that affected 50 licence and SNRP holders.
4. The licence and SNRP holders listed in the schedule to this notice have consented to the proposed modifications since March 2007.
Modification
5. Under section 12(1) of the Act and regulation 13(1) of the Regulations and with the consent of the licence and SNRP holders, I hereby modify the licences and SNRPs listed in the schedule to this notice by making the modifications set out, with effect from today.
Yours sincerely
John Larkinson The ORR is modifying the licences and SNRPs set out in column [1-4] of Schedules 1 and 2 below in the following respects:
1. The text of the licences and SNRPs set out in column [4] below, held by the companies set out in columns [1] and [2] below, will be modified by the text of the model licences and model SNRPs referred to in column [5] below. The model licences and model SNRPs mentioned in column [5] are those originally published on the ORR website on 18 January 2006, with minor amendments made following consultation. A pdf of these model licences can now be viewed at: http://www.rail-reg.gov.uk/server/show/nav.1857
2. The company name (Column [1]) and company number (Column [2]) of the licence holder/SNRP holder will be inserted into the appropriate place in Part 1 - Scope of the new model licence/SNRP.
3. Where the licence was originally granted by the Secretary of State and it has not been transposed to an SNRP, references to the “Office of Rail Regulation” in Part I - Scope will be replaced with “the Secretary of State” and the first reference to “ORR” thereafter will be replaced with “the Office of Rail Regulation (“ORR”)”. In addition, for licences in which the Secretary of State currently retains revocation powers, references to “ORR” in Part IV - Revocation shall be replaced with references to “the Secretary of State”, references to “the appropriate franchising authority” shall be replaced with references to “ORR” and the phrase “where the licence holder is a franchise operator” shall be removed, wherever appropriate. Licences granted by the Secretary of State are identified with the symbol § in Column [3].
4. The dates on which the original licence was granted and came into force shall be inserted into Part I – Scope of the new model licence/SNRP where appropriate.
5. Where appropriate, the details of a Station or Light Maintenance Depot (LMD) authorised by a licence listed in column [4] shall be inserted into the Schedule of the new model licence listed in column [5].
6. In addition, ORR is modifying the licences and SNRPs set out in column [1-4] of Schedule 2 by the further specific modifications listed in column [6] of Schedule 2. In column [6], a reference to an “old” condition is a reference to a condition in the licence/SNRP listed in column [4].
7. Explanatory Notes are being added at the end of the relevant Station and LMD licences listed in Schedules 1 and 2. These detail how content previously in Part 1 of those licences is being moved to Condition 16 and Part IV. | Licence Holder | Company number | Date originally granted | Type of licence/SNRP | New model licence/SNRP | |--------------------------------------|----------------|-------------------------|----------------------|------------------------| | Direct Rail Services Limited | 03020822 | 14.09.1998 | LMD | Model LMD licence | | | | 12.12.1995 § | Non-passenger licence| Model non-passenger licence | | | | 01.12.2000 | Network | Model network licence | | | | 12.12.1995 | Freight SNRP | Model freight SNRP | | West Coast Train Care Limited | 03602374 | 19.02.1999 | LMD | Model LMD licence | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence | [6] New model licence/SNRP | |------------------------------------------|--------------------|------------------------------|--------------------------|-----------------------|---------------------------| | Direct Rail Services Limited | 03020822 | 09.10.1997§ | Passenger SNRP (Charter) | Model passenger SNRP | Omit model Condition 3: Through Tickets and Network Benefits. Replace model Condition 4: Timetabling with old condition 12: Timetabling. In this Condition replace “Railtrack PLC” with “Network Rail”. Omit model Condition 7: Liaison with the RPC and LTUC. Insert old Condition 10: Restrictions on Certain Activities by the Licence Holder as Condition 17: Restrictions on Activities. In this Condition replace “regulator” with “ORR” and “tram” with “train”. Condition 10 was inserted into the original licence on 9 October 1997 | | Tube Lines Limited (formerly Infraco JNP Limited) | 03923425 | 10.09.2002 | Non-passenger licence | Model non-passenger licence | Omit model Condition 8: RSSB Membership. |
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20f13a2597e78e05ff13617d404e728add2c646c | NOTICE OF MODIFICATION
The companies listed in Schedules 1 & 2 to this notice have been granted licences and Statements of National Regulatory Provisions (SNRPs) to operate railway assets under section 8 of the Railways Act 1993 (the Act) or regulation 10 and Schedule 4 of the Railway (Licensing of Railway Undertakings) Regulations 2005 (the Regulations).
In accordance with section 12(2) of the Act and regulation 13(2) of the Regulations, on 2 February 2006, the Office of Rail Regulation (ORR) gave notice of its proposal to modify certain licences and SNRPs. The notice required any representations or objections to the modification to be made on or before 2 March 2006.
ORR has considered the representations or objections which were received during the consultation period and which were not withdrawn.
The licence and SNRP holders listed in Schedules 1 & 2 to this notice have consented to the proposed modifications.
Modification
Under section 12(1) of the Act and regulation 13(1) of the Regulations and with the consent of the licence and SNRP holders, I hereby modify the licences and SNRPs listed in Schedules 1 & 2 to this notice by making the modifications set out, with effect from 30 March 2007.
Brian Kogan The ORR is modifying the licences and SNRPs set out in column [1-4] of Schedules 1 and 2 below in the following respects:
1. The text of the licences and SNRPs set out in column [4] below, held by the companies set out in columns [1] and [2] below, will be modified by the text of the model licences and model SNRPs referred to in column [5] below. The model licences and model SNRPs mentioned in column [5] are those originally published on the ORR website at http://www.rail-reg.gov.uk/server/show/nav.00100b001007 on 18 January 2006, with minor amendments made following consultation.
2. The company name (Column [1]) and company number (Column [2]) of the licence holder/SNRP holder will be inserted into the appropriate place in Part 1 - Scope of the new model licence/SNRP.
3. Where the licence was originally granted by the Secretary of State and it has not been transposed to an SNRP, references to the “Office of Rail Regulation” in Part I - Scope will be replaced with “the Secretary of State” and the first reference to “ORR” thereafter will be replaced with “the Office of Rail Regulation (“ORR”)”. In addition, for licences in which the Secretary of State currently retains revocation powers, references to “ORR” in Part IV - Revocation shall be replaced with references to “the Secretary of State”, references to “the appropriate franchising authority” shall be replaced with references to “ORR” and the phrase “where the licence holder is a franchise operator” shall be removed, wherever appropriate. Licences granted by the Secretary of State are identified with the symbol § in Column [3].
4. The dates on which the original licence was granted and came into force shall be inserted into Part I – Scope of the new model licence/SNRP where appropriate.
5. Where appropriate, the details of a Station or Light Maintenance Depot (LMD) authorised by a licence listed in column [4] shall be inserted into the Schedule of the new model licence listed in column [5].
6. In addition, the ORR is modifying the licences and SNRPs set out in column [1-4] of Schedule 2 by the further specific modifications listed in column [6] of Schedule 2. In column [6], a reference to an “old” condition is a reference to a condition in the licence/SNRP listed in column [4].
7. Explanatory Notes are being added at the end of the relevant Station and LMD licences listed in Schedules 1 and 2. These detail how content previously in Part 1 of those licences is being moved to Condition 16 and Part IV. | Licence Holder | Company number | Date originally granted | Type of licence/SNRP | New model licence/SNRP | |----------------------------------------------------|----------------|-------------------------|----------------------|------------------------| | Advenza Freight Limited | 04156372 | 20.10.2004 | Non-passenger licence| Model non-passenger licence | | | | 20.10.2004 | Freight SNRP | Model freight SNRP | | Amec Spie Rail (UK) Limited | 02995525 | 08.12.1995 | Non-passenger licence| Model non-passenger licence | | (previously Amec Rail Limited, then South West Infrastructure Maintenance Company Limited) | | 08.12 1995 | Network licence | Model network licence | | Amey Infrastructure Services Limited | 03612746 | 13.10.05 | Non-passenger licence| Model non-passenger licence | | | | 13.10.05 | Network licence | Model network licence | | Amey Rail Limited | 02995531 | 08.12 1995 | Non-passenger licence| Model non-passenger licence | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------| | Arriva Trains Wales/Trenau Arriva Cymru Limited | 04337645 | 08.12 1995 | Network licence | Model network licence | | | | 03.12.2003 | Passenger SNRP | Model passenger SNRP | | | | 03.12.2003 | LMD licence | Model LMD licence | | | | 03.12.2003 | Non-passenger licence | Model non-passenger licence | | | | 03.12.2003 | Freight SNRP | Model freight SNRP | | | | 03.12.2003 | Station licence | Model station licence | | Balfour Beatty Rail Infrastructure Services Limited (previously Balfour Beatty Rail Maintenance Limited) | 00772439 | 28.06.2000 | Network licence | Model network licence | | Balfour Beatty Rail Plant Limited | 01982627 | 28.06.2000 | Non-passenger licence | Model non-passenger licence | | | | 28.06.2000 | Network licence | Model network licence | | Bombardier Transportation UK Limited (previously ABB Daimler-Benz Transportation (Customer Support) Limited, then ABB) | 02235994 | 13.09 1996 | LMD licence | Model LMD licence | | Licence Holder | Company number | Date originally granted | Type of licence/SNRP | New model licence/SNRP | |-------------------------------------------------------------------------------|----------------|-------------------------|-----------------------------|------------------------| | Daimler-Benz Transportation (UK) Limited, then DaimlerChrysler Rail Systems (UK) Limited | | | | | | c2c Rail Limited (previously LTS Rail Limited) | 02938993 | 14.12.1994 | Passenger SNRP | Model passenger SNRP | | | | 14.12.1994 | LMD licence | Model LMD licence | | | | 14.12.1994 | Station licence | Model station licence | | Carillion Construction Limited | 00594581 | 07.03.2005 | Non-passenger licence | Model non-passenger licence | | | | 07.03.2005 | Network licence | Model network licence | | Central Trains Limited | 03007938 | 10.11.1995 | Passenger SNRP | Model passenger SNRP | | | | 10.11.1995 | LMD licence | Model LMD licence | | | | 10.11.1995 | Non-passenger licence | Model non-passenger licence | | | | 10.11.1995 | Station licence | Model station licence | | Chiltern Railway Company Limited | 03007939 | 28.04.1995 | Passenger SNRP | Model passenger SNRP | | | | 28.04.1995 | LMD licence | Model LMD licence | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |-----------------------------------|--------------------|-----------------------------|----------------------------------|-----------------------------------| | | | 16.09.1995 | Non-passenger licence | Model non-passenger licence | | | | 16.09.1995 | Freight SNRP | Model freight SNRP | | | | 28.04.1995 | Station licence | Model station licence | | CrossCountry Trains Limited | 03007937 | 10.11.1995 | Passenger SNRP | Model passenger SNRP | | | | 10.11.1995 | Non-passenger licence | Model non-passenger licence | | | | 10.11.1995 | Freight SNRP | Model freight SNRP | | Fastline Limited | 02995468 | 12.10.1995 | Non-passenger licence | Model non-passenger licence | | (previously Western Track Renewal | | | | | | Company Limited, then Jarvis Fastline Limited) | | | | | | | | 12.10.1995 | Network licence | Model network licence | | First Engineering Limited | 02999826 | 10.11.1995 | Non-passenger licence | Model non-passenger licence | | (previously Scotland Infrastructure Maintenance Company Limited) | | | | | | | | 10.11.1995 | Network licence | Model network licence | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |------------------------------------------|--------------------|-----------------------------|----------------------------------|---------------------------| | First ScotRail Limited | SC185018 | 11.10.2004 | Passenger SNRP | Model passenger SNRP | | | | 11.10.2004 | LMD licence | Model LMD licence | | | | 11.10.2004 | Non-passenger licence | Model non-passenger licence| | | | 11.10.2004 | Freight SNRP | Model freight SNRP | | | | 11.10.2004 | Station licence | Model station licence | | First/Keolis Transpennine Limited | 04113923 | 28.01.2004 | Passenger SNRP | Model passenger SNRP | | | | 30.01.2004 | Non-passenger licence | Model non-passenger licence| | | | 30.01.2004 | Freight SNRP | Model freight SNRP | | | | 28.01.2004 | Station licence | Model station licence | | Freightliner Limited | 03118392 | 09.11.1995 | Non-passenger licence | Model non-passenger licence| | (previously Freightliner (1995) Limited, Freightliners Limited) | | | Freight SNRP | Model freight SNRP | | Freightliner Heavy Haul Limited | 03831229 | 14.02.2003 | Non-passenger licence | Model non-passenger licence| | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |--------------------------------------------------------|--------------------|------------------------------|--------------------------------|---------------------------| | Gatwick Express Limited | 02912338§ | 28.11.2005 | Freight SNRP | Model freight SNRP | | | | 14.02.2003 | Network licence | Model network licence | | GB Railfreight Limited | 03707899 | 31.03.1994 | Passenger SNRP | Model passenger SNRP | | | | 31.03.1994 | LMD licence | Model LMD licence | | GrantRail Limited | 03184313 | 04.07.2000 | Non-passenger licence | Model non-passenger licence| | | | 04.07.2000 | Freight SNRP | Model freight SNRP | | Great Central Railway (Nottingham) Limited | 04277779 | 15.03.2001 | Network licence | Model network licence | | Great North Eastern Railway Limited (previously Intercity East Coast Limited) | 02938984 | 31.03.1995 | Passenger SNRP | Model passenger SNRP | | | | 31.03.1995 | LMD licence | Model LMD licence | | | | 31.03.1995 | Non-passenger licence | Model non-passenger licence| | | | 31.03.1995 | Freight SNRP | Model freight SNRP | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |--------------------------------------------------------|--------------------|------------------------------|--------------------------|---------------------------| | Harsco Track Technologies Limited | 00977100 | 31.03.1995 | Station licence | Model station licence | | Hull Trains Limited | 03715410 | 13.02.2004 | Non-passenger licence | Model non-passenger licence | | Jarvis Rail Limited | 02995419 | 14.09.2000 | Passenger SNRP | Model passenger SNRP | | (previously Northern Infrastructure Maintenance Company Limited) | | | | | | London Eastern Railway Limited | 04955356 | 02.02.1996 | Non-passenger licence | Model non-passenger licence | | | | 02.02.1996 | Network licence | Model network licence | | | | 26.03.2004 | Passenger SNRP | Model passenger SNRP | | | | 26.03.2004 | LMD licence | Model LMD licence | | | | 26.03.2004 | Non-passenger licence | Model non-passenger licence | | | | 26.03.2004 | Freight SNRP | Model freight SNRP | | | | 26.03.2004 | Station licence | Model station licence | | London & North Western Railway Company Limited | 02880012 | 05.03.1999 | LMD licence | Model LMD licence | | Maintrain Limited | 02918124 | 31.12.1998 | LMD licence | Model LMD licence | | Licence Holder | Company number | Date originally granted | Type of licence/SNRP | New model licence/SNRP | |----------------------------------------------------|----------------|-------------------------|----------------------------|------------------------| | Midland Main Line Limited | 03007934 | 31.03.1995 | Passenger SNRP | Model passenger SNRP | | | | 31.03.1995 | Non-passenger licence | Model non-passenger licence | | | | 31.03.1995 | Freight SNRP | Model freight SNRP | | | | 31.03.1995 | Station licence | Model station licence | | New Southern Railway Limited (previously Network Southcentral, then South Central Limited, then Connex South Central Limited) | 03010919 | 31.03.1995 | Passenger SNRP | Model passenger SNRP | | | | 31.03.1995 | LMD licence | Model LMD licence | | | | 31.03.1995 | Station licence | Model station licence | | Northern Rail Limited | 04619954 | 26.11.2004 | Passenger SNRP | Model passenger SNRP | | | | 26.11.2004 | Station licence | Model Station licence | | | | 26.11.2004 | LMD licence | Model LMD licence | | | | 26.11.2004 | Non-passenger licence | Model non-passenger licence | | | | 26.11.2004 | Freight SNRP | Model freight SNRP | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of licence/SNRP | [5] New model licence/SNRP | |-------------------------------------------|--------------------|-----------------------------|--------------------------|---------------------------| | Pre Metro Operations Limited | 03867712 | 03.04.2003 | Passenger licence | Model passenger licence | | | | 03.04.2003 | LMD licence | Model LMD licence | | Pro-Rail Limited | 01314819 | 18.01.2001 | LMD licence | Model LMD licence | | Seco-Rail Limited | 02805908 | 27.01.2005 | Non-passenger licence | Model non-passenger licence | | Siemens Plc | 00727817 | 05.03.2003 | LMD licence | Model LMD licence | | Silverlink Train Services Limited | 03007935 | 10.11.1995 | Passenger SNRP | Model passenger SNRP | | (previously North London Railways Limited)| | 10.11.1995 | LMD licence | Model LMD licence | | | | 10.11.1995 | Station licence | Model station licence | | South Eastern Trains Limited | 03666306 | 28.11.2005 | Passenger SNRP | Model passenger SNRP | | Tyne and Wear Passenger Transport Executive| Public body | 15.03.2002 | Passenger licence | Model passenger licence | | Licence Holder | Company number | Date originally granted | Type of licence/SNRP | New model licence/SNRP | |----------------------------------------------------|----------------|-------------------------|----------------------------|------------------------------| | Wensleydale Railway PLC | 04093919 | 23.04.2003 | Passenger licence | Model passenger Licence | | | | 23.04.2003 | LMD licence | Model LMD licence | | | | 23.04.2003 | Non-passenger licence | Model non-passenger licence | | West Coast Railway Company Limited | 03066109 | 11.05.2005 | Non-passenger licence | Model non-passenger licence | | | | 11.05.2005 | Freight SNRP | Model freight SNRP | | West Coast Trains Limited (previously Intercity West Coast Limited) | 03007940 | 28.04.1995 | Passenger SNRP | Model passenger SNRP | | | | 28.04.1995 | LMD licence | Model LMD licence | | | | 28.04.1995 | Non-passenger licence | Model non-passenger licence | | | | 28.04.1995 | Freight SNRP | Model freight SNRP | | | | 28.04.1995 | Station licence | Model station licence |
## Schedule 2
| [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |---------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | English Welsh & Scottish Railway Limited\
(previously Transrail Freight Limited) | 02938988 | 31.03.1995 | Non-passenger licence | Model non-passenger licence | Insert old Condition 11: Information on Rolling stock and Prices as Condition 19\
Insert old Condition 12: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | Freight SNRP | Model freight SNRP | | | | Insert old Condition 11: Information on Rolling stock and Prices as Condition 19\
Insert old Condition 12: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions | | Licence Holder | Company number | Date originally granted | Type of Licence/ SNRP | New model licence/SNRP | Further specific changes | |----------------|----------------|-------------------------|-----------------------|------------------------|--------------------------| | English Welsh & Scottish International Railway Limited (previously Railfreight Distribution Limited) | 03232475 | 27.08.1999 | Freight SNRP | Model freight SNRP | Insert old Condition 11: Information on Rolling stock and Prices as Condition 19: Information on Rolling stock and Prices. Insert old Condition 12: Transactions as Condition 20: Transactions | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|----------------------------| | | | 11.10.1996 | Non-passenger licence | Model non-passenger licence | Insert old Condition 12: Information on Rolling stock and Prices as new Condition 19: Information on Rolling stock and Prices. Insert old Condition 13: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | | | 11.10.1996 | Freight SNRP | Model freight SNRP | Insert old Condition 12: Information on Rolling stock and Prices as new Condition 19: Information on Rolling stock and Prices. Insert old Condition 13: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | | | 11.10.1996 | Network licence | Model network licence | Insert old Condition 11: Information on Rolling stock and Prices as new Condition 19: Information on Rolling stock and Prices. Insert old Condition 12: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |-----------------------------------|--------------------|-----------------------------|--------------------------|---------------------------|---------------------------------------------------------------------------------------------| | EUROSTAR (UK) Limited | 02462001 | 24.09.1998 | Passenger SNRP | Model passenger SNRP | Omit model Condition 3: Through Tickets and Network Benefits. | | (previously European Passenger Services Limited) | | | | | Omit model Condition 4: Timetabling. | | | | | | | Replace model Condition 5: Provision of Services for Disabled People, with old Condition 3: Provision of Services for Disabled People. | | | | | | | Replace model Condition 6: Complaints Procedure, with old Condition 4: Complaints Handling Procedure. | | | | | | | Omit model Condition 8: RSSB Membership. | | | | | | | Omit model Condition 9: Railway Group Standards. | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | | | 31.03.1994 § | LMD licence | Model LMD licence | Replace model scope with old scope with the following amendments: | | | | | | | In paragraph 1 delete the wording ‘...hereof (“the Conditions”).’ | | | | | | | In paragraph 2 delete the wording ‘...the provisions of the Schedule hereto...’ and replace with ‘...Part IV...’ | | | | | | | Replace model Condition 12: Change of Control with old Condition 10: Change of Control. | | | | | | | Omit model Condition 13: Non-Discrimination | | | | | | | Omit model Condition 16: Changes to the Schedule | | | | | | | Omit paragraph 3 from model Part IV – Revocation | | | | | | | Omit ‘Schedule – List of Light Maintenance Depots’ | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|----------------------------| | | | 31.03.1994 § | Station licence | Model station licence | Replace model scope with old scope with the following amendments: | | | | | | | In paragraph 1 delete the wording ‘...Paragraph III hereof (“the Conditions”).’ and replace with ‘...Part III.’ | | | | | | | In paragraph 2 delete the wording ‘...the provisions of the Schedule hereto...’ and replace with ‘...Part IV...’ | | | | | | | Replace model Condition 5: Provision of Services for Disabled People, with old Condition 4: Provision of Services for Disabled People. | | | | | | | Replace model Condition 6: Complaints Procedure, with old Condition 5: Complaints Handling Procedure. | | | | | | | In model Condition 7: Liaison with RPC and LTUC replace the text ‘Part I of the Act’ with ‘the Channel Tunnel Act 1987’ wherever it appears. | | | | | | | Replace model Condition 12: Change of Control with old Condition 12: Change of Control. | | | | | | | Omit model Condition 13: Non-Discrimination. | | | | | | | Omit model Condition 15: Co-operation with Transport for London | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | Glasgow Prestwick Airport Limited (previously PIK Limited, Prestwick International Airport Limited and Glasgow Prestwick International Airport Limited) | SC135362 | 02.09.1994 | Station licence | Model station licence | Omit model Condition 16: Changes to the Schedule\
Omit paragraph 3 from model licence Part IV – Revocation\
Omit ‘Schedule – List of Stations’\
Omit model Condition 15: Co-operation with Transport for London. | | Licence Holder | Company number | Date originally granted | Type of Licence/ SNRP | New model licence/SNRP | Further specific changes | |--------------------------------------|----------------|-------------------------|-----------------------|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------| | Heathrow Express Operating Company Limited | 03145133 | 15.07.1997 § | Passenger licence | Model passenger licence | In Part 1 - Scope insert in Paragraph 1(a) | | | | | | | (a) "[... network] comprising the railway line running between Paddington Station in London and Tunnel Portal [for...]" | | | | | | | In Part 1 - Scope insert at the end of paragraph 2: | | | | | | | "...or until 23 June 2028, whichever is the sooner." | | | | | | | Omit model Condition 3: Through Tickets and Network Benefits. | | | | | | | Omit model Condition 7: Liaison with the RPC and LTUC. | | | | | | | Insert old Condition 14: Assignment as Condition 18: Assignment | | | | | | | Replace model Condition 12: Change of Control with old Condition 15: Change of Control. | | | | | | | Insert old Condition 16: Non-stop Services as Condition 21: Non-stop Services | | | | | | | Omit paragraph 3 from model Part IV - Revocation | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |-----------------------------------|--------------------|-----------------------------|--------------------------|---------------------------|-----------------------------------------------------------------------------------------------| | Merseyrail Electrics 2002 Limited | 04356933 | 17.07.2003 | Passenger Licence | Model passenger licence | Insert old Condition 18: Assignment as Condition 18: Assignment. In that Condition insert the following text into Paragraph 4 “...[awarded by] Merseyside Passenger Transport Executive or [the assignee]...” | | | | 17.07.2003 | LMD Licence | Model LMD licence | Insert old Condition 14: Assignment as Condition 18 Assignment. In that Condition insert the following text into Paragraph 4 “...[awarded by] Merseyside Passenger Transport Executive or [the assignee]...” | | | | 17.07.2003 | Non-passenger licence | Model non-passenger licence | Insert old Condition 12: Assignment as new Condition 18: Assignment. In that Condition insert the following text into Paragraph 4 “...[awarded by] Merseyside Passenger Transport Executive or [the assignee]...” | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | | | 17.07.2003 | Station licence | Model station licence | Insert old Condition 19: Assignment as Condition 18: Assignment. In that Condition insert the following text into Paragraph 4 “…[awarded by] Merseyside Passenger Transport Executive or [the assignee]…” Insert old Condition 6: Display of information and signing as Condition 24: Display of information and signing. In that Condition replace “approved by the Secretary of State” with “required by the Secretary of State”. | | | | 23.12.2005 | Liverpool South Parkway Station Licence | Model station licence | Insert old Condition 18: Assignment as Condition 18: Assignment. Insert old Condition 5: Display of information and signing as Condition 24: Display of information and signing | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/ SNRP | [5] New model licence/SNRP | [6] Further specific changes | |-----------------------------------|--------------------|-----------------------------|---------------------------|---------------------------|------------------------------| | Rail Express Systems Limited | 02938991 | 31.03.1995 | Passenger SNRP (Charter) | Model passenger SNRP | Omit model Condition 3: Through Tickets and network Benefits. | | | | | | | Omit model Condition 4: Timetabling. | | | | | | | Omit model Condition 6: Complaints Procedure. | | | | | | | Omit model Condition 7: Liaison with the RPC and LTUC. | | | | | | | Insert old Condition 9: Restrictions on Certain Activities by the Licence Holder as Condition 17: Restrictions on Activities. In that Condition replace “regulator” with “ORR”. | | | | | | | Insert old Condition 13: Information on Rolling Stock and Prices as Condition 19: Information on Rolling Stock and Prices. | | | | | | | Insert old Condition 14: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |--------------------|---------------------|-----------------------------|--------------------------|---------------------------|-----------------------------| | | | 31.03.1995 | Non-passenger licence | Model non-passenger licence | Insert old Condition 12: Information on Rolling Stock and Prices as new Condition 19: Information on Rolling Stock and Prices. Insert old Condition 13: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | | | 31.03.1995 | Freight SNRP | Model freight SNRP | Insert old Condition 12: Information on Rolling stock and Prices as new Condition 19: Information on Rolling Stock and Prices. Insert old Condition 13: Transactions entered into by the licence holder or a relevant business with or for the benefit of associated companies or other businesses or activities of the licence holder as Condition 20: Transactions. | | Licence Holder | Company number | Date originally granted | Type of Licence/ SNRP | New model licence/SNRP | Further specific changes | |--------------------------------|----------------|-------------------------|-----------------------|------------------------|----------------------------------------------------------------------------------------------------------------------------------------------------------| | Siemens Plc | 00727817 | 30.11.2005 | LMD Licence | Model LMD licence | Insert old Condition 13: Assignment as Condition 18: Assignment. | | Tyne and Wear Passenger Transport Executive | Public body | 26.03.2002 | Station licence | Model station licence | Omit model Condition 15: Co-operation with Transport for London. | | Wensleydale Railway Plc | 04093919 | 23.04.2003 | Network licence | Model network licence | Insert old Condition 5: Stewardship of the Licence Holder’s Network as Condition 23: Stewardship. Insert old Condition 11: Restriction on Use of Certain Information as Condition 26: Restriction on Use of Certain Information. | | [1] Licence Holder | [2] Company number | [3] Date originally granted | [4] Type of Licence/SNRP | [5] New model licence/SNRP | [6] Further specific changes | |-----------------------------------|--------------------|-----------------------------|--------------------------|---------------------------|-----------------------------------------------------------------------------------------------| | West Coast Railway Company Limited | 03066109 | 17.06.1998 | Passenger SNRP (Charter) | Model passenger SNRP | Omit model Condition 3: Through Tickets and Network Benefits. Replace model Condition 4: Timetabling with old Condition 13: Timetabling. In that Condition replace “Railtrack PLC” with “Network Rail”. Insert old Condition 11: Restrictions on Certain Activities by the Licence Holder as Condition 17: Restrictions on Activities. In that Condition replace “regulator” with “ORR” and “tram” with “train”. |
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29b9d6ef90af1af7c2e21bee13e9cd43d2cc9223 | Non-Passenger Train Licence
granted to
[ ]
Reference Number: UK 03 [YEAR] [XXXX]
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | | 1 |
| Part II - Interpretation | PAGE | |--------------------------|------| | | 2 |
| Part III - Conditions | PAGE | |-----------------------|------| | Condition 1: Insurance Against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 8: RSSB Membership | 6 | | Condition 9: Safety and standards | 7 | | Condition 10: Environmental Matters | 8 | | Condition 11: Payment of Fees | 9 | | Condition 12: Change of Control | 10 |
| Part IV - Revocation | PAGE | |----------------------|------| | | 11 |
Note: Conditions 3 – 7 are not used in this licence. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by section 8 of the Railways Act 1993 (as amended) ("the Act"), hereby grants to [name of licensee], company registration number [number], ("the licence holder") a licence authorising the licence holder:
(a) to be the operator of trains being used on a network otherwise than for the purpose of carrying passengers by railway;
(b) to be the operator of trains being used on a network for a purpose preparatory or incidental to, or consequential on, using a train as mentioned in (a) above; and
(c) to be the operator of trains being used on a network for the purpose of assisting other operators of railway assets
subject to the Conditions set out in Part III.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of trains pursuant to this licence.
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this licence to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this licence, headings shall be disregarded.
4. Where in this licence the licence holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the licence holder fails to comply with that obligation within that time limit.
5. Where in this licence there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
7. The provisions of section 149 of the Act shall apply for the purposes of the service of any document pursuant to this licence.
8. Unless the context otherwise requires, terms and expressions defined in the Act and the Railways Act 2005 shall have the same meanings in this licence. Part III - Conditions
Condition 1: Insurance Against Third Party Liability
01. The licence holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
02. The licence holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
03. Except with the consent of ORR, the licence holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangements:
(a) under which the licence holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 8: RSSB Membership
04. If the licence holder’s annual turnover has never exceeded £1 million and the licence holder is not a franchise operator, paragraphs 2 and 3 shall not have effect until the licence holder’s annual turnover exceeds £1 million for the first time. The licence holder shall provide ORR with such information in respect of its annual turnover as ORR may from time to time require.
05. With effect from the date of the coming into force of this licence, except where ORR consents otherwise, the licence holder shall: (a) become and thereafter remain a member of RSSB; (b) comply with its obligations under the Constitution Agreement and the articles of association of RSSB; and (c) exercise its rights under the Constitution Agreement and the articles of association of RSSB so as to ensure that RSSB shall act in accordance with the Constitution Agreement.
06. With effect from the date of the coming into force of this licence, the licence holder shall comply with the Railway Group Standards Code prepared by RSSB.
07. When a licence holder first becomes subject to the obligations in paragraphs 2 and 3 his rights, obligations and liabilities associated with such membership shall commence on the same day, and the licence holder shall complete the formal and legal documentation associated with such membership within three months of that date.
08. In this Condition: “franchise operator” includes an operator of last resort, under section 30 of the Act. Condition 9: Safety and standards
09. The licence holder shall comply with:
(a) such Railway Group Standards as are applicable to its licensed activities; and
(b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
10. The licence holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where:
(a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and
(b) it has adopted and is complying with that measure.
11. In this Condition:
“Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and
“Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
12. The licence holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
13. The environmental arrangements shall:
(a) take due account of any relevant guidance issued by ORR;
(b) be effective within six months beginning with the day on which this licence comes into force; and
(c) be reviewed by the licence holder periodically, and otherwise as appropriate.
14. Nothing contained in paragraph 1 shall oblige the licence holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the licence holder.
15. The licence holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a current copy of the policy together with a summary of the operational objectives and management arrangements.
16. The licence holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
17. In respect of the year beginning on 1 April [current financial year] and in each subsequent year, the licence holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this licence, as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this licence or any class of licence of which ORR determines that this licence forms part.
18. The payment shall be rendered by the licence holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the licence holder of its amount. Condition 12: Change of Control
19. The licence holder shall, if any person obtains control of the licence holder, notify ORR as soon as practicable thereafter. Part IV - Revocation
20. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing by the licence holder.
21. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than three months notice to the licence holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the licence holder of any Condition, and the licence holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the licence holder stating that this licence will be revoked pursuant to this term if the licence holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined;
(b) if the licence holder has not commenced carrying on licensed activities within one year beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least one year;
(c) if the licence holder is convicted of an offence under section 146 of the Act in making its application for this licence; or
(d) if a person obtains control of the licence holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
3. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than 10 years’ notice, such notice not to be given earlier than 25 years after the date this licence takes effect.
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b659ec510d8ab2ef3b9444923f44a75704c0ceb9 | Network Licence
granted to
[ ]
Reference Number: UK 03 [YEAR] [XXXX]
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | | 1 |
| Part II - Interpretation | PAGE | |--------------------------|------| | | 2 |
| Part III - Conditions | PAGE | |-----------------------|------| | Condition 1: Insurance Against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 9: Safety and standards | 6 | | Condition 10: Environmental Matters | 7 | | Condition 11: Payment of Fees | 8 | | Condition 12: Change of Control | 9 | | Condition 13: Non-Discrimination | 10 | | Condition 14: Emergency Access | 11 |
| Part IV - Revocation | PAGE | |----------------------|------| | | 12 |
| Schedule - List of Networks | PAGE | |-----------------------------|------| | | 14 |
Note: Conditions 3 – 8 are not used in this licence. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by section 8 of the Railways Act 1993 (as amended) ("the Act"), hereby grants to [name of licensee], company registration number [number], a licence authorising the licence holder:
(a) to be the operator of a network of the kinds specified in the Schedule;
(b) to be the operator of a train being used on any such network for any purpose comprised in the operation of that network; and
(c) to be the operator of a train being used on any such network for a purpose preparatory or incidental to, or consequential on, using a train as mentioned in paragraph (b) above
subject to the Conditions set out in Part III.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of a network or trains pursuant to this licence; and
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this licence to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this licence, headings shall be disregarded.
4. Where in this licence the licence holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the licence holder fails to comply with that obligation within that time limit.
5. Where in this licence there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
7. The provisions of section 149 of the Act shall apply for the purposes of the service of any document pursuant to this licence.
8. Unless the context otherwise requires, terms and expressions defined in the Act and the Railways Act 2005 shall, have the same meanings in this licence. Part III - Conditions
Condition 1: Insurance Against Third Party Liability
01. The licence holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
02. The licence holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
03. Except with the consent of ORR, the licence holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangements:
(a) under which the licence holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 9: Safety and standards
04. The licence holder shall comply with:
(a) such Railway Group Standards as are applicable to its licensed activities; and
(b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
05. The licence holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where:
(a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and
(b) it has adopted and is complying with that measure.
06. In this Condition:
“Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and
“Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
07. The licence holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
08. The environmental arrangements shall: (a) take due account of any relevant guidance issued by ORR; (b) be effective within six months beginning with the day on which this licence comes into force; and (c) be reviewed by the licence holder periodically, and otherwise as appropriate.
09. Nothing contained in paragraph 1 shall oblige the licence holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the licence holder.
10. The licence holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a copy of the policy together with a summary of the operational objectives and management arrangements.
11. The licence holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
12. In respect of the year beginning on 1 April [current financial year] and in each subsequent year, the licence holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this licence, as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this licence or any class of licence of which ORR determines that this licence forms part.
13. The payment shall be rendered by the licence holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the licence holder of its amount. Condition 12: Change of Control
14. The licence holder shall, if any person obtains control of the licence holder, notify ORR as soon as practicable thereafter. Condition 13: Non-Discrimination
15. Except in so far as ORR may otherwise consent, the licence holder shall not in its licensed activities, or in carrying out any other function contemplated by this licence, unduly discriminate between particular persons or between any classes or descriptions of person. Condition 14: Emergency Access
16. During any emergency affecting the railway, the licence holder shall, to the extent that it is legally entitled to do so, grant to any person requesting it such permission to use any network of which the licence holder is the operator pursuant to this licence as is necessary or expedient to alleviate the effects of the emergency. Part IV - Revocation
17. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing by the licence holder.
18. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than three months' notice to the licence holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the licence holder of any Condition, and the licence holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the licence holder stating that this licence will be revoked pursuant to this term if the licence holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined; or
(b) if the licence holder has not commenced carrying on licensed activities within one year beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least one year; or
(c) if the licence holder is convicted of an offence under section 146 of the Act in making its application for this licence; or
(d) if any person obtains control of the licence holder and:
(i) ORR has not approved that obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
3. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than 10 years' notice, such notice not to be given earlier than 25 years after the date this licence takes effect. Schedule - List of Networks
4. Networks comprising marshalling yards, holding sidings and recess sidings;
5. Every network comprised in a railway goods terminal;
6. Every network which connects a light maintenance depot or track within a light maintenance depot to any part of a network operated by a person other than the licence holder;
7. Every network which connects a network operated by another person to a network operated by that person or by a third person;
8. Every network which is situated within a harbour or harbour area; and
9. Every network which connects a network situated on premises used for the purposes of: (a) an industrial undertaking; (b) an undertaking engaged in the generation of electrical energy; or (c) a mine or quarry
to a network operated by another person.
7. Network of a type not covered by paragraphs 1 to 6 above, when specified by the licence holder in a notice given to ORR and in respect of which ORR does not give to the licence holder, within 30 days of receiving the notice, a notice objecting to the licence holder being so authorised.
In this Schedule:
“harbour” and “harbour area” have the same meaning as in the Dangerous Substances in Harbour Areas Regulations 1987; and
“mine” and “quarry” have the same meaning as in the Mines and Quarries Act 1954.
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1a3f4df0717aaf96b534dfd2ebbe41824da56b85 | Passenger Train Licence
granted to
[ ]
Reference Number:
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | Part II - Interpretation | 2 | | Part III - Conditions | 4 | | Condition 1: Insurance Against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 3: Through Tickets and Network Benefits | 6 | | Condition 4: Information for Passengers | 7 | | Condition 5: Accessible Travel Policy | 9 | | Condition 6: Complaints Handling | 11 | | Condition 7: Liaison with the PC and LTUC | 14 | | Condition 8: RSSB Membership | 15 | | Condition 9: Safety and standards | 16 | | Condition 10: Environmental Matters | 17 | | Condition 11: Payment of Fees | 18 | | Condition 12: Change of Control | 19 | | Condition 28: Rail Delivery Group | 20 | | Part IV - Revocation | 21 |
Note: Conditions 13-27 are not used in this licence. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by section 8 of the Railways Act 1993 (as amended) ("the Act"), hereby grants to [name of licensee], company registration number [number], ("the licence holder") a licence authorising the licence holder:
(a) to be the operator of trains being used on a network for the purpose of carrying passengers by railway;
(b) to be the operator of trains being used on a network for a purpose preparatory or incidental to, or consequential on, using a train as mentioned in (a) above; and
(c) to be the operator of trains being used on a network for the purpose of assisting other operators of railway assets
subject to the Conditions set out in Part III.
2. This licence shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this licence:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the licence holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the licence holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the licence holder or of the voting power in the licence holder; or
(ii) such part of any issued share capital of the licence holder as would, if the whole of the income of the licence holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the licence holder or in any other circumstances, entitle him to receive 30% or more of the assets of the licence holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the licence holder in its capacity as operator of trains pursuant to this licence.
“LTUC” means the London Transport Users Committee and any successor to LTUC which performs the same functions.
“the PC” means the Passengers’ Council and any successor or delegated body which performs the function of the PC.
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this licence to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this licence, headings shall be disregarded.
4. Where in this licence the licence holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the licence holder fails to comply with that obligation within that time limit.
5. Where in this licence there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this licence as if it were an Act.
7. The provisions of section 149 of the Act shall apply for the purposes of the service of any document pursuant to this licence.
8. Unless the context otherwise requires, terms and expressions defined in the Act and the Railways Act 2005 shall have the same meanings in this licence. Part III - Conditions
Condition 1: Insurance Against Third Party Liability
1. The licence holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
2. The licence holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
3. Except with the consent of ORR, the licence holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangements:
(a) under which the licence holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 3: Through Tickets and Network Benefits
4. The licence holder shall, except in so far as the Secretary of State may otherwise consent, be a party to and comply with such arrangements (as amended from time to time) relating to:
(a) stations at which, and the journeys in respect of which, through tickets, and tickets from any station specified in or under such arrangements to any other such station, shall be sold and honoured;
(b) operation of a telephone enquiry bureau relating to railway passenger services;
(c) settlement of amounts due to or from the licence holder in respect of tickets within sub-paragraph (a); and
(d) conditions of carriage in respect of through ticket
as shall have been approved by the Secretary of State. Condition 4: Information for Passengers
Purpose
1. The purpose is to secure the provision of appropriate, accurate and timely information to enable railway passengers and prospective passengers to plan and make their journeys with a reasonable degree of assurance, including when there is disruption.
General duty
2. The licence holder shall achieve the purpose to the greatest extent reasonably practicable having regard to all relevant circumstances, including the funding available.
Specific obligations
3. The following obligations in this Condition are without prejudice to the generality of the general duty in paragraph 2 and compliance with these obligations shall not be regarded as exhausting that general duty. In fulfilling these obligations the licence holder shall at all times comply with the general duty in paragraph 2.
Planning services
4. The licence holder shall cooperate, as necessary, with Network Rail and other train operators to enable Network Rail to undertake appropriate planning of train services and to establish or change appropriate timetables, including when there is disruption.
5. In particular, the licence holder shall:
(a) provide Network Rail with such information about the licence holder’s licensed activities as may be reasonably necessary for Network Rail to fulfil its obligations relating to timetabling in its network licence;
(b) participate constructively in any timetabling consultation carried out by Network Rail;
(c) use reasonable endeavours to resolve promptly any timetabling disputes; and
(d) respond expeditiously to any timetabling matter which Network Rail reasonably considers to be urgent. Code(s) of practice and improvement plan(s)
6. The licence holder shall, unless ORR otherwise consents, publish one or more code(s) of practice or other documents setting out the principles and processes by which it will comply with the general duty in paragraph 2.
7. Where the licence holder considers, or is directed by ORR, that improvements to its arrangements for the provision of information to railway passengers and prospective passengers are necessary or desirable to enable it better to fulfil the general duty in paragraph 2, it shall develop, publish and deliver a plan, which sets out the improvements it intends to make and the dates by which such improvements will be made.
8. The licence holder shall, from time to time and when so directed by ORR, review and, if necessary, revise, following consultation, anything published under paragraph 6 and any plan under paragraph 7 so that they may better fulfil the general duty in paragraph 2.
9. ORR shall not make any direction under paragraphs 7 or 8 without first consulting the licence holder.
Provision of information to intermediaries
10. The licence holder shall as soon as reasonably practicable:
(a) provide to the holders of passenger and station licences; and
(b) provide to all timetable information providers on request reasonable access to appropriate, accurate and timely information to enable each on request to provide passengers with all relevant information to plan their journeys including, so far as reasonably practicable, the fare or fares and any restrictions applicable.
11. In this Condition:
“Network Rail” means Network Rail Infrastructure Limited (a company registered in England and Wales under number 02904587), and its successors and assigns. Condition 5: Accessible Travel Policy
1. The licence holder shall establish and thereafter comply with:
(a) a statement of policy; and
(b) a detailed body of arrangements, procedures, services and other benefits to be implemented or provided by the licence holder, designed to protect the interests of people who are disabled in their use of trains operated by the licence holder and to facilitate such use (together the “ATP”).
2. In establishing the ATP and in making any change to it, the licence holder shall have due regard to the code of practice published by the Secretary of State pursuant to section 71B of the Act.
3. The licence holder shall not establish, or make any material changes (save in respect of paragraph 4(b)), to the ATP unless and until:
(a) the PC and, where appropriate, LTUC has been consulted; and
(b) the licence holder has submitted the ATP, or (as the case may be) the proposed change, to ORR and ORR has approved it.
4. Where ORR requires the licence holder to carry out a review of the ATP or any part of it or the manner in which it has been implemented, with a view to determining whether any change should be made to it, the licence holder shall:
(a) promptly carry out a review and submit a written report to ORR setting out the results or conclusions; and
(b) make such changes to the ATP, or the manner in which it is implemented, as ORR may reasonably require after ORR has received a report under paragraph 4(a) and consulted the licence holder, the PC and, where appropriate, LTUC.
5. The licence holder shall:
(a) send a copy of the ATP and of any change to it to ORR and the PC and, where appropriate, LTUC; (b) in a place of reasonable prominence at each station at which trains operated by the licence holder are scheduled to call, display or procure the display of a notice giving the address from which a current copy of the statement may be obtained; and
(c) make available free of charge a current copy of the statement to any person who requests it.
06. Nothing in this Condition shall oblige the licence holder to undertake any action that entails excessive cost, taking into account all the circumstances including the nature and scale of licensed activities. Condition 6: Complaints Handling
07. The licence holder shall establish and thereafter comply with a procedure for handling complaints relating to licensed activities from its customers and potential customers (the “Complaints Procedure”).
08. The licence holder shall not establish, or make any material change (save in respect of paragraph 3(b)), to the Complaints Procedure unless and until:
(a) the PC and, where appropriate, LTUC has been consulted; and
(b) the licence holder has submitted the Complaints Procedure, or (as the case may be) the proposed change, to ORR and ORR has approved it.
09. Where ORR requires the licence holder to carry out a review of the Complaints Procedure or any part of it or the manner in which it has been implemented, with a view to determining whether any change should be made to it, the licence holder shall:
(a) promptly carry out a review and submit a written report to ORR setting out the results or conclusions; and
(b) make such changes to the Complaints Procedure, or the manner in which it is implemented, as ORR may reasonably require after ORR has received a report under paragraph 3(a) and consulted the licence holder, the PC and, where appropriate, LTUC.
10. The licence holder shall:
(a) send a copy of the Complaints Procedure and of any change to it to ORR and the PC and, where appropriate, LTUC;
(b) in a place of reasonable prominence at each station at which trains operated by the licence holder are scheduled to call, display or procure the display of a notice giving the address from which a current copy of the Complaints Procedure may be obtained; and
(c) make available free of charge a current copy of the Complaints Procedure to any person who requests it.
11. Alternative Dispute Resolution:
(a) The licence holder shall become and thereafter remain, a member of the Relevant ADR Scheme;
(b) the licence holder shall comply with its obligations under the Relevant ADR Scheme; and
(c) if the Relevant ADR Scheme, at any time, ceases to be Compliant, the licence holder must:
(i) within 14 days after becoming aware that the Relevant ADR Scheme is no longer Compliant, notify ORR of that fact;
(ii) within no more than 28 days after becoming aware that the Relevant ADR Scheme is no longer Compliant, notify ORR of the arrangements it has put in place to ensure that the interests of passengers are not adversely affected and must, if so directed by ORR at any time, revise those arrangements to take account of any concerns ORR reasonably raises about the protection of passenger interests; and
(iii) if the Relevant ADR Scheme continues to be non-Compliant for more than 6 months:
- take all such steps as are reasonably practicable, including working together with other members of the Relevant ADR Scheme, and Rail Delivery Group, as appropriate, to identify another alternative dispute resolution scheme which is Compliant; and
- notify such scheme to ORR within not more than 12 months (or such longer period as ORR may agree) after the date on which the Relevant ADR Scheme ceased to be Compliant.
6. For the purposes of this Condition:
“Relevant ADR Scheme” means:
- the alternative dispute resolution scheme procured by Rail Delivery Group (the Rail Ombudsman) or, as the case may be, any Successor Scheme. “Successor Scheme” means:
- such other alternative dispute resolution scheme as is notified to ORR by the licence holder under sub-paragraph (c)(iii) above, and is accepted by ORR as providing suitable protection for the interests of passengers.
“Compliant”, in relation to the Relevant ADR Scheme, means:
- that the scheme is approved by the Designated Competent Authority and meets the requirements of ORR’s Guidance in respect of an alternative dispute resolution scheme.
“Designated Competent Authority” means:
- the relevant Designated Competent Authority under The Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015.
“ORR’s Guidance” means:
- ORR’s Guidance on the Complaints Handling Procedures as amended from time to time. Condition 7: Liaison with the PC and LTUC
1. Whenever reasonably requested to do so by the PC and LTUC (as relevant) the licence holder shall meet with the PC and LTUC (as relevant) to discuss and review such matters as the PC and LTUC (as relevant) may wish to consider in connection with its functions under Part I of the Act. The licence holder shall not under this Condition be obliged to attend more than two meetings with the PC and LTUC (as relevant) in any calendar year.
2. The licence holder shall provide the PC and LTUC (as relevant) with such information as satisfies all the following conditions:
(a) the PC and LTUC (as relevant) reasonably requests the information for the proper performance of its functions under Part I of the Act;
(b) no undue burden is imposed on the licence holder in procuring or furnishing the information; and
(c) the information would normally be available to the licence holder, unless the PC and LTUC (as relevant) considers the information essential to enable it to exercise its functions under Part I of the Act.
3. In every calendar year in which the licence holder meets with the PC and, where appropriate, LTUC pursuant to paragraph 1, the licence holder shall be represented by one or more senior executives of the licence holder in at least one meeting with the PC and LTUC (separately or jointly).
4. Where the licence holder also holds another licence each number specified as a maximum or minimum in this Condition shall apply jointly to meetings under this Condition and to meetings under any corresponding condition in that other licence.
5. Where:
(a) the licence holder and the PC or LTUC, or both disagree as to the reasonableness of a request made to the licence holder by the PC or LTUC, or both under paragraph 1 or paragraph 2;
(b) either party refers the dispute to the Secretary of State; and
(c) the Secretary of State determines that the request is reasonable
the licence holder shall promptly thereafter comply with the request. Condition 8: RSSB Membership
01. If the licence holder’s annual turnover has never exceeded £1 million and the licence holder is not a franchise operator, paragraphs 2 and 3 shall not have effect until the licence holder’s annual turnover exceeds £1 million for the first time. The licence holder shall provide ORR with such information in respect of its annual turnover as ORR may from time to time require.
02. With effect from the date of the coming into force of this licence, except where ORR consents otherwise; the licence holder shall:
(a) become and thereafter remain a member of RSSB;
(b) comply with its obligations under the Constitution Agreement and the articles of association of RSSB; and
(c) exercise its rights under the Constitution Agreement and the articles of association of RSSB so as to ensure that RSSB shall act in accordance with the Constitution Agreement.
03. With effect from the date of the coming into force of this licence, the licence holder shall comply with the Railway Group Standards Code prepared by RSSB.
04. When a licence holder first becomes subject to the obligations in paragraphs 2 and 3 his rights, obligations and liabilities associated with such membership shall commence on the same day, and the licence holder shall complete the formal and legal documentation associated with such membership within three months of that date.
05. In this Condition:
“franchise operator” includes an operator of last resort, under section 30 of the Act. Condition 9: Safety and standards
06. The licence holder shall comply with:
(a) such Railway Group Standards as are applicable to its licensed activities; and
(b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
07. The licence holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where:
(a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and
(b) it has adopted and is complying with that measure.
08. In this Condition:
“Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and
“Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
09. The licence holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
10. The environmental arrangements shall:
(a) take due account of any relevant guidance issued by ORR;
(b) be effective within six months beginning with the day on which this licence comes into force; and
(c) be reviewed by the licence holder periodically, and otherwise as appropriate.
11. Nothing contained in paragraph 1 shall oblige the licence holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the licence holder.
12. The licence holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a current copy of the policy together with a summary of the operational objectives and management arrangements.
13. The licence holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
14. In respect of the year beginning on 1 April [current financial year] and in each subsequent year, the licence holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this licence as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this licence or any class of licence of which ORR determines that this licence forms part.
15. The payment shall be rendered by the licence holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the licence holder of its amount. Condition 12: Change of Control
16. The licence holder shall, if any person obtains control of the licence holder, notify ORR as soon as practicable thereafter. Condition 28: Rail Delivery Group
17. The licence holder shall:
(a) become and thereafter remain a Licensed Member of RDG;
(b) comply with its obligations under the RDG Articles; and
(c) procure that any member of its Group that is entitled under the RDG Articles to become a Member of RDG:
(i) becomes and thereafter remains a Member of RDG; and
(ii) complies with its obligations under the RDG Articles.
18. In this Condition:
“Group” has the meaning ascribed to it in the RDG Articles;
“Licensed Member” has the meaning ascribed to it in the RDG Articles;
“Member” has the meaning ascribed to it in the RDG Articles;
“RDG” means the Rail Delivery Group (a company limited by guarantee and registered in England and Wales under number 08176197); and
“RDG Articles” means the articles of association of RDG. Part IV - Revocation
19. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence at any time if agreed in writing by the licence holder.
20. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than three months’ notice to the licence holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the licence holder of any Condition, and the licence holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the licence holder stating that this licence will be revoked pursuant to this term if the licence holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined;
(b) if the licence holder has not commenced carrying on licensed activities within one year beginning with the day on which this licence comes into force or if the licence holder ceases to carry on licensed activities for a continuous period of at least one year;
(c) if the licence holder is convicted of an offence under section 146 of the Act in making its application for this licence; or
(d) if a person obtains control of the licence holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the licence holder stating that ORR proposes to revoke this licence in pursuance of this paragraph unless the person who has obtained control of the licence holder ceases to have control of the licence holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
3. ORR may (after having consulted the appropriate franchising authority where the licence holder is a franchise operator) revoke this licence by not less than 10 years’ notice, such notice not to be given earlier than 25 years after the date this licence takes effect.
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eccfd0f5f0b0f15d5baf4060ce626f61424f462f | Statement of National Regulatory Provisions
(SNRP): Passenger
granted to
[ ]
Reference Number:
# Table of contents
| Part I - Scope | PAGE | |----------------|------| | Part II - Interpretation | 2 | | Part III - Conditions | 4 | | Condition 1: Insurance Against Third Party Liability | 4 | | Condition 2: Claims Allocation and Handling | 5 | | Condition 3: Passenger Rights, Through Tickets and Network Benefits | 6 | | Condition 4: Information for Passengers | 7 | | Condition 5: Accessible Travel Policy | 9 | | Condition 6: Complaints Handling | 11 | | Condition 7: Liaison with the PC and LTUC | 14 | | Condition 8: RSSB Membership | 15 | | Condition 9: Safety and standards | 16 | | Condition 10: Environmental Matters | 17 | | Condition 11: Payment of Fees | 18 | | Condition 12: Change of Control | 19 | | Condition 28: Rail Delivery Group | 20 | | Part IV - Revocation | 21 |
Note: Conditions 13-27 are not used in this SNRP. Part I - Scope
1. The Office of Rail and Road ("ORR"), in exercise of the powers conferred by regulation 10 of the Railway (Licensing of Railway Undertakings) Regulations 2005 ("the Regulations"), hereby grants to [name of SNRP holder], company registration number [number], ("the SNRP holder") an SNRP including the Conditions set out in Part III.
2. This SNRP shall come into force on [date] and shall continue in force unless and until revoked in accordance with Part IV.
[Date] Signed by authority of the Office of Rail and Road Part II - Interpretation
1. In this SNRP:
“comply” is to be interpreted in accordance with ORR’s most recently published licensing guidance.
“control” (a) A person is taken to have control of the SNRP holder if he exercises, or is able to exercise or is entitled to acquire, direct or indirect control over the SNRP holder’s affairs, and in particular if he possesses or is entitled to acquire:
(i) 30% or more of any share capital or issued share capital of the SNRP holder or of the voting power in the SNRP holder; or
(ii) such part of any issued share capital of the SNRP holder as would, if the whole of the income of the SNRP holder were in fact distributed among the participators (without regard to any rights which he or any other person has as a loan creditor), entitle him to receive 30% or more of the amount so distributed; or
(iii) such rights as would, in the event of the winding-up of the SNRP holder or in any other circumstances, entitle him to receive 30% or more of the assets of the SNRP holder which would then be available for distribution among the participators.
(b) Subsections (4) to (6) of section 416 of the Income and Corporation Taxes Act 1988, and the legislative provisions referred to in those subsections, apply to the interpretation of paragraph (a) in the same way that they apply to the interpretation of subsection (2) of section 416 of that Act. “licensed activities” means things authorised to be done by the SNRP holder in its capacity as operator of trains pursuant to its European licence.
“LTUC” means the London Transport Users Committee and any successor to LTUC which performs the same functions.
“the PRO Regulation” means Regulation (EC) No.1371/2007 of the European Parliament and of the Council of 23 October 2007 on rail passengers’ rights and obligations.
“the PC” means the Passengers’ Council and any successor or delegated body which performs the function of the PC.
“RSSB” means Rail Safety and Standards Board Limited (a company limited by guarantee and registered in England and Wales under number 04655675), and its successors and assigns.
2. Any reference in this SNRP to a numbered paragraph is a reference to the paragraph bearing that number in the Condition in which the reference occurs.
3. In interpreting this SNRP, headings shall be disregarded.
4. Where in this SNRP the SNRP holder is required to comply with any obligation within a specified time limit, that obligation shall be deemed to continue after that time limit if the SNRP holder fails to comply with that obligation within that time limit.
5. Where in this SNRP there is a provision for ORR or the Secretary of State to give consent, such consent may be given subject to conditions.
6. The Interpretation Act 1978 shall apply to this SNRP as if it were an Act.
7. The provisions of section 149 of the Railways Act 1993 (as amended) (“the Act”) shall apply for the purposes of the service of any document pursuant to this SNRP.
8. Unless the context otherwise requires, terms and expressions defined in the Act, the Railways Act 2005, or the Regulations shall have the same meanings in this SNRP. Part III - Conditions
Condition 1: Insurance Against Third Party Liability
1. The SNRP holder shall, in respect of licensed activities, maintain insurance against third party liabilities in accordance with any relevant ORR general or specific approval, as amended from time to time. Condition 2: Claims Allocation and Handling
2. The SNRP holder shall, except in so far as ORR may otherwise consent, at all times be a party to and comply with such agreements or arrangements (as amended from time to time) relating to:
(a) the handling of claims against operators of railway assets; and
(b) the allocation of liabilities among operators of railway assets
as may have been approved by ORR.
3. Except with the consent of ORR, the SNRP holder shall not, in relation to any of the agreements or arrangements described in paragraph 1 (the “relevant claims handling arrangements”), enter into any agreement or arrangement with any other party to the relevant claims handling arrangements:
(a) under which the SNRP holder agrees not to exercise any rights which it may have under any of the relevant claims handling arrangements; or
(b) varying the relevant claims handling arrangements
other than as provided for under the terms of the relevant claims handling arrangements. Condition 3: Passenger Rights, Through Tickets and Network Benefits
4. The SNRP holder shall, except in so far as the Secretary of State may otherwise consent, be a party to and comply with such arrangements (as amended from time to time) relating to:
(a) stations at which, and the journeys in respect of which, through tickets, and tickets from any station specified in or under such arrangements to any other such station, shall be sold and honoured;
(b) operation of a telephone enquiry bureau relating to railway passenger services;
(c) settlement of amounts due to or from the SNRP holder in respect of tickets within sub-paragraph (a); and
(d) conditions of carriage in respect of through tickets and the PRO Regulation, as shall have been approved by the Secretary of State or are required to ensure arrangements reflect the provisions of the PRO Regulation listed in paragraph 2.
5. The SNRP holder shall comply with articles 4-10, 15-18 and 28-29 of the PRO Regulation. Condition 4: Information for Passengers
Purpose
1. The purpose is to secure the provision of appropriate, accurate and timely information to enable railway passengers and prospective passengers to plan and make their journeys with a reasonable degree of assurance, including when there is disruption.
General duty
2. The SNRP holder shall achieve the purpose to the greatest extent reasonably practicable having regard to all relevant circumstances, including the funding available.
Specific obligations
3. The following obligations in this Condition are without prejudice to the generality of the general duty in paragraph 2 and compliance with these obligations shall not be regarded as exhausting that general duty. In fulfilling these obligations the SNRP holder shall at all times comply with the general duty in paragraph 2.
Planning services
4. The SNRP holder shall cooperate, as necessary, with Network Rail and other train operators to enable Network Rail to undertake appropriate planning of train services and to establish or change appropriate timetables, including when there is disruption.
5. In particular, the SNRP holder shall:
(a) provide Network Rail with such information about the SNRP holder’s licensed activities as may be reasonably necessary for Network Rail to fulfil its obligations relating to timetabling in its network licence;
(b) participate constructively in any timetabling consultation carried out by Network Rail;
(c) use reasonable endeavours to resolve promptly any timetabling disputes; and
(d) respond expeditiously to any timetabling matter which Network Rail reasonably considers to be urgent. Code(s) of practice and improvement plan(s)
6. The SNRP holder shall, unless ORR otherwise consents, publish one or more code(s) of practice or other documents setting out the principles and processes by which it will comply with the general duty in paragraph 2.
7. Where the SNRP holder considers, or is directed by ORR, that improvements to its arrangements for the provision of information to railway passengers and prospective passengers are necessary or desirable to enable it better to fulfil the general duty in paragraph 2, it shall develop, publish and deliver a plan, which sets out the improvements it intends to make and the dates by which such improvements will be made.
8. The SNRP holder shall, from time to time and when so directed by ORR, review and, if necessary, revise, following consultation, anything published under paragraph 6 and any plan under paragraph 7 so that they may better fulfil the general duty in paragraph 2.
9. ORR shall not make any direction under paragraphs 7 or 8 without first consulting the SNRP holder.
Provision of information to intermediaries
10. The SNRP holder shall as soon as reasonably practicable:
(a) provide to the holders of passenger and station licences; and
(b) provide to all timetable information providers on request reasonable access to appropriate, accurate and timely information to enable each on request to provide passengers with all relevant information to plan their journeys including, so far as reasonably practicable, the fare or fares and any restrictions applicable.
11. In this Condition:
"Network Rail" means Network Rail Infrastructure Limited (a company registered in England and Wales under number 02904587), and its successors and assigns. Condition 5: Accessible Travel Policy
1. The SNRP holder shall establish and thereafter comply with:
(a) a statement of policy; and
(b) a detailed body of arrangements, procedures, services and other benefits to be implemented or provided by the SNRP holder, designed to protect the interests of people who are disabled in their use of trains operated by the SNRP holder and to facilitate such use (together the “ATP”).
2. In establishing the ATP and in making any change to it, the SNRP holder shall have due regard to the code of practice published by the Secretary of State pursuant to section 71B of the Act and to articles 19 to 24 of the PRO Regulation.
3. The SNRP holder shall not establish, or make any material changes (save in respect of paragraph 4(b), to the ATP unless and until:
(a) the PC and, where appropriate, LTUC has been consulted; and
(b) the SNRP holder has submitted the ATP, or (as the case may be) the proposed change, to ORR and ORR has approved it.
4. Where ORR requires the SNRP holder to carry out a review of the ATP or any part of it or the manner in which it has been implemented, with a view to determining whether any change should be made to it, the SNRP holder shall:
(a) promptly carry out a review and submit a written report to ORR setting out the results or conclusions; and
(b) make such changes to the ATP, or the manner in which it is implemented, as ORR may reasonably require after ORR has received a report under paragraph 4(a) and consulted the SNRP holder, the PC and, where appropriate, LTUC.
5. The SNRP holder shall:
(a) send a copy of the ATP and of any change to it to ORR and the PC and, where appropriate, LTUC; (b) in a place of reasonable prominence at each station at which trains operated by the SNRP holder are scheduled to call, display or procure the display of a notice giving the address from which a current copy of the statement may be obtained; and
(c) make available free of charge a current copy of the statement to any person who requests it.
06. Nothing in this Condition shall oblige the SNRP holder to undertake any action that entails excessive cost, taking into account all the circumstances including the nature and scale of licensed activities. Condition 6: Complaints Handling
07. The SNRP holder shall establish and thereafter comply with a procedure for handling complaints relating to licensed activities from its customers and potential customers and shall comply with article 27 of the PRO Regulation (the “Complaints Procedure”).
08. The SNRP holder shall not establish, or make any material change (save in respect of paragraph 3(b)), to the Complaints Procedure unless and until: (a) the PC and, where appropriate, LTUC has been consulted; and (b) the SNRP holder has submitted the Complaints Procedure, or (as the case may be) the proposed change, to ORR and ORR has approved it.
09. Where ORR requires the SNRP holder to carry out a review of the Complaints Procedure or any part of it or the manner in which it has been implemented, with a view to determining whether any change should be made to it, the SNRP holder shall: (a) promptly carry out a review and submit a written report to ORR setting out the results or conclusions; and (b) make such changes to the Complaints Procedure, or the manner in which it is implemented, as ORR may reasonably require after ORR has received a report under paragraph 3(a) and consulted the SNRP holder, the PC and, where appropriate, LTUC.
10. The SNRP holder shall: (a) send a copy of the Complaints Procedure and of any change to it to ORR and the PC and, where appropriate, LTUC; (b) in a place of reasonable prominence at each station at which trains operated by the SNRP holder are scheduled to call, display or procure the display of a notice giving the address from which a current copy of the Complaints Procedure may be obtained; and (c) make available free of charge a current copy of the Complaints Procedure to any person who requests it.
11. Alternative Dispute Resolution:
(a) The SNRP holder shall become and thereafter remain, a member of the Relevant ADR Scheme;
(b) the SNRP holder shall comply with its obligations under the Relevant ADR Scheme; and
(c) if the Relevant ADR Scheme, at any time, ceases to be Compliant, the SNRP holder must:
(i) within 14 days after becoming aware that the Relevant ADR Scheme is no longer Compliant, notify ORR of that fact;
(ii) within no more than 28 days after becoming aware that the Relevant ADR Scheme is no longer Compliant, notify ORR of the arrangements it has put in place to ensure that the interests of passengers are not adversely affected and must, if so directed by ORR at any time, revise those arrangements to take account of any concerns ORR reasonably raises about the protection of passenger interests; and
(iii) if the Relevant ADR Scheme continues to be non-Compliant for more than 6 months:
- take all such steps as are reasonably practicable, including working together with other members of the Relevant ADR Scheme, and Rail Delivery Group, as appropriate, to identify another alternative dispute resolution scheme which is Compliant; and
- notify such scheme to ORR within not more than 12 months (or such longer period as ORR may agree) after the date on which the Relevant ADR Scheme ceased to be Compliant.
6. For the purposes of this Condition:
"Relevant ADR Scheme" means:
- the alternative dispute resolution scheme procured by Rail Delivery Group (the Rail Ombudsman) or, as the case may be, any Successor Scheme. “Successor Scheme” means:
- such other alternative dispute resolution scheme as is notified to ORR by the SNRP holder under sub-paragraph (c)(iii) above, and is accepted by ORR as providing suitable protection for the interests of passengers.
“Compliant”, in relation to the Relevant ADR Scheme, means:
- that the scheme is approved by the Designated Competent Authority and meets the requirements of ORR’s Guidance in respect of an alternative dispute resolution scheme.
“Designated Competent Authority” means:
- the relevant Designated Competent Authority under The Alternative Dispute Resolution for Consumer Disputes (Competent Authorities and Information) Regulations 2015.
“ORR's Guidance” means:
- ORR's Guidance on the Complaints Handling Procedures as amended from time to time. Condition 7: Liaison with the PC and LTUC
1. Whenever reasonably requested to do so by the PC and LTUC (as relevant), the SNRP holder shall meet with the PC or LTUC to discuss and review such matters as the PC and LTUC (as relevant) may wish to consider in connection with its functions under Part I of the Act including the handling of complaints made about an alleged infringement of the PRO Regulation. The SNRP holder shall not under this Condition be obliged to attend more than two meetings with PC and LTUC (as relevant) in any calendar year.
2. The SNRP holder shall provide the PC and LTUC (as relevant) with such information as satisfies all the following conditions:
(a) the PC and LTUC (as relevant) reasonably requests the information for the proper performance of its functions under Part I of the Act;
(b) no undue burden is imposed on the SNRP holder in procuring or furnishing the information; and
(c) the information would normally be available to the SNRP holder, unless the PC and LTUC (as relevant) considers the information essential to enable it to exercise its functions under Part I of the Act.
3. In every calendar year in which the SNRP holder meets with the PC and, where appropriate, LTUC pursuant to paragraph 1, the SNRP holder shall be represented by one or more senior executives of the SNRP holder in at least one meeting with the PC and LTUC (separately or jointly).
4. Where the SNRP holder also holds another SNRP, each number specified as a maximum or minimum in this Condition shall apply jointly to meetings under this Condition and to meetings under any corresponding condition in that other SNRP.
5. Where:
(a) the SNRP holder and the PC or LTUC, or both disagree as to the reasonableness of a request made to the SNRP holder by the PC or LTUC, or both under paragraph 1 or paragraph 2;
(b) either party refers the dispute to the Secretary of State; and
(c) the Secretary of State determines that the request is reasonable,
the SNRP holder shall promptly thereafter comply with the request. Condition 8: RSSB Membership
01. If the SNRP holder’s annual turnover has never exceeded £1 million and the SNRP holder is not a franchise operator, paragraphs 2 and 3 shall not have effect until the SNRP holder’s annual turnover exceeds £1 million for the first time. The SNRP holder shall provide ORR with such information in respect of its annual turnover as ORR may from time to time require.
02. With effect from the date of the coming into force of this SNRP, except where ORR consents otherwise, the SNRP holder shall: (a) become and thereafter remain a member of RSSB; (b) comply with its obligations under the Constitution Agreement and the articles of association of RSSB; and (c) exercise its rights under the Constitution Agreement and the articles of association of RSSB so as to ensure that RSSB shall act in accordance with the Constitution Agreement.
03. With effect from the date of the coming into force of this SNRP, the SNRP holder shall comply with the Railway Group Standards Code prepared by RSSB.
04. When a SNRP holder first becomes subject to the obligations in paragraphs 2 and 3 his rights, obligations and liabilities associated with such membership shall commence on the same day, and the SNRP holder shall complete the formal and legal documentation associated with such membership within three months of that date.
05. In this Condition: “franchise operator” includes an operator of last resort, under section 30 of the Act. Condition 9: Safety and standards
06. The SNRP holder shall comply with: (a) such Railway Group Standards as are applicable to its licensed activities; and (b) subject to paragraph 2, such Rail Industry Standards (or parts thereof) as are applicable to its licensed activities.
07. The SNRP holder is not required to comply with an applicable Rail Industry Standard (or part thereof) where: (a) it has, following consultation with such persons as it considers are likely to be affected, identified an equally effective measure which will achieve the purpose of the standard; and (b) it has adopted and is complying with that measure.
08. In this Condition: “Railway Group Standards” means standards authorised pursuant to the Railway Group Standards Code prepared by RSSB; and “Rail Industry Standards” has the meaning set out in the Standards Manual, established by RSSB. Condition 10: Environmental Matters
09. The SNRP holder shall establish a written policy designed to protect the environment from the effect of licensed activities, together with operational objectives and management arrangements (together “the environmental arrangements”).
10. The environmental arrangements shall:
(a) take due account of any relevant guidance issued by ORR;
(b) be effective within six months beginning with the day on which this SNRP comes into force; and
(c) be reviewed by the SNRP holder periodically, and otherwise as appropriate.
11. Nothing contained in paragraph 1 shall oblige the SNRP holder to undertake any action that entails excessive cost taking into account all the circumstances, including the nature and scale of operations of the type carried out by the SNRP holder.
12. The SNRP holder shall, upon establishment and any material modification of the environmental arrangements, promptly send ORR a current copy of the policy together with a summary of the operational objectives and management arrangements.
13. The SNRP holder shall act with regard to the policy and operational objectives and use its reasonable endeavours to operate the management arrangements effectively. Condition 11: Payment of Fees
14. In respect of the year beginning on 1 April [year] and in each subsequent year, the SNRP holder shall render to ORR a payment which is the aggregate of the following amounts:
(a) the annual fee applicable to this SNRP as determined by ORR; and
(b) an amount which shall represent a fair proportion as determined by ORR of the amount estimated by ORR (in consultation with the Competition and Markets Authority) as having been incurred in the calendar year immediately preceding the 1 April in question by the Competition and Markets Authority in connection with references made to it under section 13 of the Act with respect to this SNRP or any class of SNRP of which ORR determines that this SNRP forms part,
15. The payment shall be rendered by the SNRP holder within such time as ORR may require, being not less than 30 days beginning with the day on which ORR gives notice to the SNRP holder of its amount. Condition 12: Change of Control
16. The SNRP holder shall, if any person obtains control of the SNRP holder, notify ORR as soon as practicable thereafter. Condition 28: Rail Delivery Group
17. The SNRP holder shall: (a) become and thereafter remain a Licensed Member of RDG; (b) comply with its obligations under the RDG Articles; and (c) procure that any member of its Group that is entitled under the RDG Articles to become a Member of RDG: (i) becomes and thereafter remains a Member of RDG; and (ii) complies with its obligations under the RDG Articles.
18. In this Condition: “Group” has the meaning ascribed to it in the RDG Articles; “Licensed Member” has the meaning ascribed to it in the RDG Articles; “Member” has the meaning ascribed to it in the RDG Articles; “RDG” means the Rail Delivery Group (a company limited by guarantee and registered in England and Wales under number 08176197); and “RDG Articles” means the articles of association of RDG. Part IV - Revocation
19. ORR may (after having consulted the appropriate franchising authority where the SNRP holder is a franchise operator) revoke this SNRP at any time if agreed in writing by the SNRP holder.
20. ORR may (after having consulted the appropriate franchising authority where the SNRP holder is a franchise operator) revoke this SNRP by not less than three months’ notice to the SNRP holder:
(a) if a final order has been made, or a provisional order has been confirmed under section 55 of the Act, in respect of any contravention or apprehended contravention by the SNRP holder of any Condition, and the SNRP holder does not comply with the order within a period of three months beginning with the day on which ORR gives notice to the SNRP holder stating that this SNRP will be revoked pursuant to this term if the SNRP holder does not so comply; provided that ORR shall not give any such notice before the expiration of the period within which an application could be made under section 57 of the Act in relation to the order in question or before any proceedings relating to any such application are finally determined;
(b) if the SNRP holder has not commenced carrying on licensed activities within six months beginning with the day on which this SNRP comes into force or if the SNRP holder ceases to carry on licensed activities for a continuous period of at least six months;
(c) if the SNRP holder is convicted of an offence under section 146 of the Act or regulation 15 of the Regulations in making its application for this SNRP; or
(d) if a person obtains control of the SNRP holder and:
(i) ORR has not approved such obtaining of control;
(ii) within one month of that obtaining of control coming to the notice of ORR, ORR serves notice on the SNRP holder stating that ORR proposes to revoke this SNRP in pursuance of this paragraph unless the person who has obtained control of the SNRP holder ceases to have control of the SNRP holder within the period of three months beginning with the day of service of the notice; and
(iii) that cessation of control does not take place within that period.
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4932c3b6067a07b908cfac9983c6307177837d87 | Office of Rail Regulation Minutes of the 85th Board meeting on 19 June 2012 (09:45 – 16.30) in Room 1, ORR offices, One Kemble Street, London
Board present:
Non-executive directors: Anna Walker (chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole and Steve Walker.
Executive directors: Richard Price (chief executive), Michael Beswick, Ian Prosser, and Cathryn Ross.
In attendance, all items: John Larkinson (acting director, RPP), Juliet Lazarus (legal adviser), Ken Young (director, external affairs), Melvyn Neate, Independent member of ORR Audit Committee, Gary Taylor (asst. board secretary)
In attendance, specific items: Carl Hetherington, Head of regulatory finance (items 5 and 10), Annette Egginton, Head of Competition and consumer policy (item 6), David Keay, Head of Inspection, Railway Operations (Item 8), Sandra Jenner, Change Advisor (Items 9 and 14), Paul McMahon, Deputy Director RME (Items 10-12), Gordon Cole, Principal financial analyst (Items 10-12).
Item 1: Welcome and apologies for absence
1. Anna Walker welcomed everyone to the meeting, in particular, Melvyn Neate, our new independent member of the Audit Committee. Apologies for absence were received from Sam McClelland Hodgson.
Item 2: Declarations of interest
2. There were no interests declared relevant to the agenda.
Item 3: HLOS update and DfT guidance to ORR
3. Following the update received at the May Board on the development of the HLOS, John Larkinson provided a further progress report. This included highlighting the linkages between the development of the DfT and Transport Scotland (TS) HLOS, the Secretary of State guidance to ORR and the upcoming outputs framework consultation.
Paragraphs 4-14 have been redacted as they concern policy development
15. In conclusion we agreed that the Chief Executive and John would consider a handling strategy to ensure that the messages are relayed to DfT at the highest level.
- **Board 19.06.2012 Action A:** Secretariat to provide Board members with copies of the DfT and TS HLOS.
- **Board 19.06.2012 Action C:** Executive to clarify DfT guidance to ensure there was a common understanding.
- **Board 19.06.12 Action D:** We also agreed that we needed to be clearer on what was meant by “Value for Money” both in relation to the HLOS and DfT Guidance. The executive should bring recommendations back to the Board Item 4: August consultation on the outputs that NR will be required to deliver
16. We considered the latest position in relation to our Outputs consultation document. We noted that the document would be published shortly after the publications of the TS and DfT HLOS.
*Paragraphs 17-18 have been redacted as they concern policy development*
19. We agreed that the consultation document would be circulated to Board members for comment. We agreed that if there were significant concerns we may need to return for a further discussion in July.
- **Board 19.06.2012 Action E:** Consultation document to be amended – including:
- section 5 table to be brought to the front end of the document to add additional context.
- Issues we were clear we needed to continue to have regulated targets on should be grouped together at the beginning of the document and our reasons for this clearly stated (e.g. on depots, stations and network capability).
- **Board 19.06.2012 Action F:** Executive team to ensure a step change in all aspects of asset management and achieve whole life cost approach.
- **Board 19.06.2012 Action G:** Executive to ensure consultation document covers our position on five areas in relation to outputs – Network Rail and suppliers (Mike Lloyd to feed into this), innovation and ROSCOs, environment issues and customer and passenger satisfaction and asset management.
Item 5: Consultation on detailed financial framework issues
20. We considered an update on the latest position on the upcoming consultation on the detailed financial framework issues.
*Paragraphs 21-25 have been redacted as relating to policy discussion*
26. In terms of process we agreed that the draft consultation document would be circulated to Board members for further comments before being formally signed off by Richard and Anna.
27. We thanked Carl for his helpful slides and for his willingness to brief NEDs on these complex issues.
- **Board 19.06.2012 Action I:** Draft consultation document to be circulated to Board members for further comment and signed off by Richard and Anna.
- **Board 19.06.2012 Action J:** Carl to arrange briefing sessions with NEDs (on request).
Item 6: Transparency
28. Ken Young and Annette Egginton presented the latest developments of our transparency work and the upcoming consultation. Ken highlighted that the consultation and work around TOC benchmarking were key parts of our overall transparency programme.
*Paragraphs 29-32 have been redacted as they concern policy development*
**Board 19.06.2012 Action K:** The Board agreed that the wording was comprehensive and were content for the document to be published at the end of July following sign off from Richard.
**Board 19.06.2012 Action L:** The Board agreed a short consultancy piece of work/external review to look at best practice in transparency in other sectors, what best practice would look like for ORR and to establish what resources are required to achieve best practice. This should be updated in parallel with the consultation.
**Board 19.06.2012 Action M:** A further Board discussion on transparency to be scheduled on Board forward agenda in light of the comments received from the consultation exercise.
**Board 19.06.2012 Action N:** Further discussion to be scheduled at a future Board meeting to discuss third party access to information.
**Item 7: RDG arrangements**
33. We considered an update on the arrangements for formalising the Rail Delivery Group (RDG). Michael confirmed that the approach to formalising RDG had been discussed with DfT who were keen for the group to be formalised.
34. We were supportive of formalisation but were keen to see RDG’s terms of reference to ensure that it was not taking accountability away from licensed operators. Michael confirmed that RDG was clear that it will not be taking over any licenced operator obligations and this will be clearly stated as part of its constitution.
35. We discussed the issues around our role on competition and RDG’s role. We agreed that it would be important for the consultation to explain that the creation of the RDG was “without prejudice to anything under competition law”.
36. We agreed that it would be useful to invite Tim O’Toole, as chair of RDG, to a future Board session to discuss RDG and its role. As part of this discussion we agreed that it would be useful to have further clarity on how RDG would interact with the RSSB. We noted that the RSSB would shortly begin a strategic review.
**Board 19.06.2012 Action O:** Secretariat to arrange/invite Tim O’Toole to Board session to discuss RDG and its role.
**Board 19.06.2012 Action P:** SRC/Board to hold further discussion on how RDG consider safety related issues and the relationship with RSSB.
**Item 8: Annual Health and Safety report**
37. We noted the key messages from the Annual Health and Safety report for 2011-12.
38. We considered that on many of the safety measures highlighted through the report, safety on Britain’s railways continues to improve. Concerns were raised around a number of areas where improvements are still necessary including, management maturity, development of TPWS/ERTMS and platform train interface. We also noted that ORR’s enforcement action remains high.
39. Following discussion, we agreed that consideration needed to be given to the handling of level crossing data given the high profile media coverage of incidents. Ian agreed to consider this.
40. We thanked Ian and his team for producing a comprehensive report. Ian confirmed that the document would be shared with RSSB and RAIB before being signed off by Richard and Anna in advance of being published by the middle of July.
**Board 19.06.2012 Action Q:** Final version of the 11-12 H&S report to be cleared by Richard and Anna – following sense check by EA. Draft report to be shown to RAIB + RSSB before it is published.
**Item 9: Progress update from Sandra Jenner, Change advisor**
41. We considered an update from Sandra on the work undertaken to date. *Paragraphs 42-44 have been redacted as they contain sensitive information.*
42. Sandra confirmed that she was currently compiling an action plan with priorities and owners to take the work forward. An update would be provided to the Board in due course.
- **Board 19.06.2012 Action R:** RP and SJ to take action, as discussed, to solve the issues around HR/recruitment and provide update to the Board in July. The Board should get a better flow of management information including on recruitment issues. Further work was needed on analysing our current skills capability and the skills ORR would need for the future given its changing role.
- **Board 19.06.2012 Action S:** Detailed progress update to be provided to Board in September.
- **Board 19.06.2012 Action T:** DG to discuss resourcing in more detail to assess the short, medium and long term resourcing needs of the organisation and provide update in September
**Item 10: Assessing Network Rail’s efficiency**
*This section redacted as it relates to policy development.*
**Item 11: Network Rail’s MIP**
52. We noted the draft letter from Richard to Steve Russell, Chair of Network Rail’s Remuneration Committee on the MIP. We confirmed that we were content with the content of the letter.
53. We discussed the arrangements in place for the Network Rail members meeting. We agreed that we would need to have a clear message on progress on the MIP for this. Cathryn confirmed that the letter to Steve Russell would be sent to members in advance of the meeting. We agreed that this would be a useful substantive backdrop to our meeting.
54. Cathryn confirmed that specific proposals for Board consideration were currently being worked up • **Board 19.06.2012 Action W**: Briefing to be provided to NEDs in advance of NR members meeting.
**Item 12:** *this item has been redacted as it relates to a commercial issue*
**Item 13:** **Chair’s report**
57. We noted that the Chair’s report for mid-May to mid-June would be circulated to Board members through correspondence.
• **Board 19.06.2012 Action Y**: Secretariat to circulate Chair’s report to Board members through correspondence.
**Item 14:** **Chief executive’s overview and monthly data pack**
58. We discussed the Chief Executive’s overview and monthly data which set out the key issues for ORR in relation to internal and external activities. In particular the executive provided updates on recent safety activities; including data on our enforcement, inspections and our progress against RAIB recommendations.
59. We also received updates provided on our current progress on senior staff recruitment.
60. We noted the safety information included in the overview. No significant issues were raised.
61. We received an update on the response to the *A Greater Role for ORR Regulating Passenger Franchisees in England & Wales* ConDoc. The response to DfT was currently being drafted. We agreed that Anna and Richard could sign off the final response on behalf of the Board.
62. Cathryn Ross provided an update on freight issues. The consultation document relating to the freight variable usage charge had recently been published. Responses to this consultation have been negative, as expected. NEDs were likely to be asked for their views by the freight industry. A Q&A and lines to take has been prepared and will be circulated to NEDs.
63. Ian Prosser provided an update on the arrangements for the Olympics. In summary Ian confirmed that the integrated transport communications system had been successfully tested. Ian confirmed that ORR’s internal arrangements are in place should an incident occur during the Olympics. Ken confirmed that an integrated communications programme is in place to handle any media related issues. We noted that the Olympics related risk currently on the High level risk register would need to be updated to reflect the current situation. Ian agreed to update.
64. We noted the proposed response (which had previously been discussed by the Board) to the DfT localism consultation and were content.
65. In relation to the consultation on fares and ticketing, we agreed that a draft response would be circulated to Board members for comments by 22 July 2012.
66. Richard confirmed that an approach to shortening and sharpening the production of Board papers will be put in place for the production of the July Board papers.
67. In addition, we endorsed Richard’s proposed business planning and assurance process and reporting cycle to the Board, which would commence as part of the CE’s overview in July.
68. We discussed the Management data pack (MDP). we agreed that it would be useful to include the JPIP targets in the PPM information. We also agreed to include targets dates for when Network Rail will make progress on actions highlighted on the regulatory escalator.
69. We congratulated Ken and Elaine Horton on successfully producing the Annual Report and resource accounts to time.
- **Board 19.06.2012 Action Z**: Board agreed that they were content for Anna and Richard to sign off the response to the DfT ConDoc.
- **Board 19.06.2012 Action AA**: High Level Risk Register to be updated following discussion on Olympics.
- **Board 19.06.2012 Action AB**: MDP for July to be amended in line with discussion to include JPIP targets in the PPM information.
**Item 15: Board forward programme and draft dates 2013**
70. We noted that the Board forward programme would be updated following the Board awayday and circulated to Board members in correspondence.
- **Board 19.06.2012 Action AC**: Secretariat to circulate Board forward programme to Board members for comment.
**Item 16: Approval of minutes of Board meetings of 22 May 2012 for publication**
71. The minutes of formal board meeting on 22 May 2012 would be circulated to Board members for comment through correspondence.
- **Board 19.06.2012 Action AD**: Minutes from May meeting to be circulated for approval through correspondence
**Item 17: Matters arising (not taken elsewhere on the agenda)**
72. We noted the progress against actions from our previous meetings; a number of actions had been completed since May and further updates were noted on those still outstanding.
**Item 18: Committee meetings:**
73. We noted that at the recent RIAC meeting discussions focused on the Strategic Elements Project (StEP), PR13 related safety issues and the committee’s ToR.
**Item 19: Any other business**
74. Cathryn confirmed that she had prepared the draft Secretary of State paper which had been requested following a recent meeting. The draft would be circulated to Board members for comments by 22 June 2012. • **Board 19.06.2012 Action AE:** Cathryn to circulate draft Secretary of State Letter to Board members.
**Item 20: Meeting review**
75. We agreed that the first half of the meeting had been well managed and produced extremely positive discussions. We agreed that we would need to work on ensuring that this high standard of discussion continues for the entirety of the next meeting in July.
Anna Walker\
Chair\
Minutes approved by the Board on 24 July 2012
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4fd1272123afddac541b716ba92e10d9e0d9a5f0 | Office of Rail Regulation
Minutes of the 92nd Board meeting on 19 March 2013 (10:00 – 16:00) in Room 1, ORR offices, One Kemble Street, London
Board present:
Non-executive directors: Anna Walker (Chair) (items 1-6), Tracey Barlow, Peter Bucks, Mark Fairbairn Mike Lloyd, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Michael Beswick (Director, Rail Policy), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Richard Emmott (Interim Director, External Affairs), Juliet Lazarus (Director, Legal Services), Tess Sanford (Board Secretary), and Gary Taylor (Assistant. Board Secretary).
In attendance, specific items: John Larkinson (PR13 programme Director) items 3, 4 and 5, Nigel Fisher (Head of performance, information and analysis), Paul Hadley (Head of Operations), Andrew Wallace (Head of Planning and Operations), Colin Greenslade (Head of Strategy, Planning and System Safety), Chris Fieldsend (Industry Planning manager), Mervyn Carter (Senior engineer), Carl Hetherington (Deputy Director, RME), Jonathan Hulme (Financial analyst), Rob Mills (Senior Economist), Joe Quill (Competition Economist), and Dan Brown (Director, Strategy)
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. Apologies were received from Stephen Nelson (non-executive director). The Chair confirmed that she would need to leave the meeting at 13:00. Tracey Barlow would chair the remainder of the meeting.
Item 2: Declarations of interest
2. Peter Bucks declared that he was undertaking some financial consultancy for CAA, but this was not thought to be relevant to the matters in hand.
Item 3: Outputs
3. John Larkinson presented this item which set out a suite of recommendations for Board decision as part of the overall package of outputs for CP5.
4. The decisions made against individual recommendations and the additional work required where a decision has not finally been made are set out in an annex to these minutes (attached to the record but not for publication as it relates to work which is in hand and will be captured in the published document).
5. It was recognized that we need to be aware of our legal framework and our relevant section 4 duties when looking at the overall package. John confirmed that this will be an important consideration and the balance between the duties that has been assumed in reaching the executive recommendations will be highlighted as part of the overall package discussion scheduled at the April Board meeting.
6. In order to regulate Network Rail (NR) the regime for CP5 includes outputs, enablers and indicators. Failure to deliver outputs will usually be a licence breach. ‘Enablers’ and ‘indicators’ have the same status as each other although they tell us about different types of things – enablers are about NR’s improving capability in key “transformational” areas in order to achieve the desired outcomes, and indicators are about tracking underlying risk. We agreed that we need to have a clear expectation of how we would react should an indicator or enabler go off trajectory. We agreed that we need to ensure that we are clear on:
- what will we measure;
- our expectations for each measure;
- actions if performance is off track; and
- the incentives we will attach to each.
[The rest of this section has been redacted from the published minutes as it relates to policy development]
**Item 4: Efficiency reporting in CP5**
26. Carl Hetherington presented this item, which set out the proposed approach to assessing financial performance in CP5. Carl confirmed that a consultation exercise would take place to seek views in advance of a decision being made in October 2013. Carl also stressed that this item was about measuring Network Rail’s financial outperformance and not about how the measure is used to make decisions, e.g. for route-level efficiency benefit sharing (REBS) or the MIP.
27. Cathryn Ross emphasised that this work was important for a number of reasons, including:
- The need to simplify the current arrangements for efficiency monitoring;
- Building on the lessons from CP4;
- Establishing the linkages between outputs and financial performance; and
- The close link to our strategic objectives.
[paragraphs 28-32 have been redacted from the published minutes as they relate to policy development]
33. We thanked Carl for the informative discussion. We agreed that the issues discussed were now in a position to be highlighted through the consultation.
**Board 19.03.2013 Action vii:** Carl to speak to Stephen Nelson to discuss points raised in advance of the Board meeting, Peter Bucks to discuss debt indexation and the Chair to gain any other views.
**Board 19.03.2013 Action viii:** The Board agreed to consult on measuring Network Rail’s total financial performance in CP5. Board to return to the issue of how it measures financial performance for REBs and the MIP as part of decisions on the CP5 package. Both actions: Carl Hetherington.
**Item 5: Decisions on the performance and possessions regimes CP5 (schedules 4 & 8)**
34. John Larkinson and Rob Mills presented this item which set out recommendations in relation to the schedules 4 and 8 possessions and performance regimes.
[The rest of this section has been redacted from published minutes as it relates to policy development] Item 6: Preparations for upcoming Board sessions – Network Rail and ATOC
39. The Chief Executive highlighted the draft agendas for the upcoming joint Board sessions with ATOC and Network Rail.
ATOC 10 April 2013
40. The session would be used to recap on the safety issues raised at the last joint Board session and to discuss the future regulatory approach using a bespoke version of the Long Term, Regulatory Statement (LTRS) as a starting point for discussion. We agreed that this version of the LTRS would be shared with Board members as part of the briefing for the meeting. We also agreed that we should have a pre-meeting.
Network Rail dinner: 11 April 2013
[Some text has been redacted from this section as it relates to policy development]
41. This session would focus on the following:
- Long term vision for Network Rail and regulation. [ ]
- What will be different in CP5 and CP6. [ ]
42. We discussed the arrangements for the meeting. It was agreed that a round table discussion would be beneficial in ensuring a better quality of conversation.
Board 19.03.2013 Action xi: ATOC agenda timings to be revised to reflect shorter discussion on safety.
Board 19.03.2013 Action xii: LTRS (ATOC meeting version) to be sent to Board members for initial views
Board 19.03.2013 Action xiii: Board members to be provided with briefing for both NR and ATOC meetings.
Board 19.03.2013 Action xiv: Pre meeting session to be scheduled in advance of ATOC and NR meetings.
Item 7: Monthly Safety report / issues to advise the Board
43. Ian Prosser raised the following safety points:
Earthworks
44. A number of failures relating to structures and earthworks have been picked up on the Precursor Indicator Model in Q2. Ian confirmed that he had produced a report on earthworks related issues which would be circulated to all Board members. Ian highlighted that there was recognition by Network Rail that these issues need to be addressed and they have developed work banks for first 2 years of CP5. Work with Network Rail and ORR’s inspectors will continue through a detailed inspection programme over the next 12 months. Broken rails
45. In response to issues on London North East, Ian confirmed that Network Rail have put in place a resourced delivery plan which ORR’s inspectors will continue to review on a monthly basis.
46. Similarly, issues affecting broken rails on the Sussex route have resulted in Network Rail placing additional resources to inspect and maintain rails. Ian will continue to keep the Board informed.
Train/platform interface 47. Ian confirmed that a workshop in conjunction with RSSBB on the industry wide best practice approach to platform train interface is taking place shortly.
Board 19.03.2013 Action xv: IP to circulate his report on earthworks to the Board Board 19.03.2013 Action xvi: IP to update the Board on the effectiveness of NR’s response to broken rails.
Item 8: Business plan 2013-14 – Sign off 48. Dan Brown presented the draft 2013-14 Business Plan document for sign off by the Board. 49. We agreed that the document was well presented and comprehensive. It was noted that we need to have a clearer understanding around the use of our broader competition act powers and demonstrate where we have used them previously and where we will use them in 2013-14. Cathryn confirmed that this can be captured and will be shared with the Board when completed. 50. We discussed the likely resource challenges facing the organisation during 2013-14. Cathryn confirmed that there were significant challenges in the areas of consumer policy and the work to prepare for PR18 which would begin during 2013. We agreed that the Board should be aware of these issues and programme discussion when appropriate. 51. The Board were content to sign off the 2013-14 Business plan and congratulated Dan and the team for producing a quality document. Dan agreed to contact those Board members not present to establish whether they have any significant comments.
Board 19.03.2013 Action xvii: ORR’s competition activity needs to be highlighted and demonstrate how and when we use these powers. (Relevant to ORR’s broader competition powers). To be shared with the Board in due course. Board 19.03.2013 Action xviii: Cathryn highlighted the challenges in 13-14 around consumer policy and starting the work on PR18. We agreed that these issues should be factored on to the Board forward agenda for discussion. Board 19.03.2013 Action xix: Dan to contact those NEDs who were not in attendance to seek any outstanding comments on the draft Business Plan. Item 9: Annual report and resource accounts – update
52. Richard Emmott provided a brief progress report on the production of the Annual Report and Resource accounts. We noted the timescales and welcomed the progress made to date.
53. The potential for the Report to trigger a hearing with the Transport Select Committee was identified. This is a statutory accountability document and its treatment should reflect that importance, although it will be issued at a time when most attention will be focused on the draft determination. It must set out ORR’s achievements during 2012-13 alongside the financial content.
Item 10: Report back from the March Audit Committee
54. Tracey Barlow (chair of ORR’s Audit Committee) provided a summary of the discussions held on 7 March 2013:
- The committee welcomed the report from John Larkinson which looked at how ORR gains assurance from its financial models. The committee felt that it would be useful for the Board to have sight of the report. The Chief Executive would speak to the Chair to establish how best to do this.
- The committee discussed risk management and how this links to ORR’s new business management system. A report will be discussed at the May Audit Committee meeting.
55. We noted that the Board had not received an update from recent Remuneration Committee meetings. We agreed that this should be discussed with the RemCo chair and considered for future meetings.
Board 19.03.2013 Action xx: Consider providing a RemCo report to the Board
Item 11: Report back from March Safety Regulation Committee meeting of 18 March 2013
56. Steve Walker (Chair of SRC) provided a brief summary of the discussions held at the SRC meeting on 18 March:
- Len Porter (Chief Executive, RSSB), and Anson Jack (Deputy Chief Executive, RSSB) attended to discuss RSSB’s strategic review.
- Following a discussion on system safety the committee reviewed the relevant section of the Health and Safety Strategy. It was agreed that some revisions should be made. Steve confirmed that as part of the six monthly Board review of health and safety (due to be discussed in June) a revised executive summary of the strategy would be provided. It was agreed that the use of a traffic light scorecard for each strand would help to understand progress. It would be important for the Board to discuss system safety at that six monthly session.
- Approach and progress to date on our work on risk based regulation.
- A suggested programme of health and safety training for Board members was discussed. The Board supported the initiative.
57. We agreed to Steve’s suggestion that the Board should see the SRC forward programme paper taken at each meeting. Board 19.03.2013 Action xxi: Health and Safety training for Board members to be scheduled.
Board 19.03.2013 Action xxii: As part of future SRC reports to the Board, we agreed that the SRC forward programme paper should be circulated to Board members.
Board 19.03.2013 Action xxiii: include system safety on the agenda for June Board meeting.
Item 12: Chair’s report
58. We noted the Chair’s report. The report included the Board objectives for 2012-13. Concerns were raised that many of the objectives were being carried forward to 2013-14 without suitable actions to address these. The Board Secretary confirmed that the 2013-14 Board objectives were currently being drafted and will include actions to ensure completion where possible.
59. We agreed that any specific comments on the report would be provided to the Board Secretariat or directly to the Chair.
Board 19.03.2013 Action xxiv: Comments on Chair’s report to be provided to Tess or directly to the Chair after the Board meeting.
Board 19.03.2013 Action xxv: Board Secretary to draft and circulate Board objectives for 2013-14.
Item 13: CE’s overview report
[This section has been redacted from the published minutes as it contains sensitive information about regulatory and enforcement matters.]
Item 14: Board forward programme
62. The Board forward programme was noted. We briefly discussed arrangements for the June Board visit to Glasgow and suggested that there could be an optional site visit for the morning of 24 June. The Board Secretariat agreed to discuss the arrangements in more detail with the Chair and provide the Board with an outline of the schedule of events as soon as possible.
Board 19.03.2013 Action xxvii: Suggestions for June visit to Scotland to be considered and discussed with the Chair and schedule circulated to Board members.
Item 15: Approval of minutes of Board meeting held on 26 February 2013
63. The draft minutes of the meeting held on 26 February 2013 were noted. No comments were raised on the content, however it was noted that the minutes were very detailed.
Item 16: Matters arising not taken elsewhere on the agenda
64. The updates on the outstanding Board actions were noted. Item 17: Any other business
65. We discussed the latest position on freight. The Chief Executive confirmed that we are continuing dialogue over a number of issues including the freight specific charge, Network Rail consultation on charges and the current biomass consultation.
66. We noted that we had received a letter from Keith Brown (Scottish Transport Minister) who had requested assurance that ORR had considered the Transport Scotland guidance when making decisions in relation to freight. We agreed that the response to this letter would be shared with Board members. We noted again the importance of understanding the overall picture around freight and what the likely impact of our decisions would be on the sector before finalising the complete package for CP5.
67. Invitations to an ATOC open day had been sent to NEDs and some Directors. We agreed that the Board Secretariat team should coordinate a response to the invitation.
Board 19.03.2013 Action xxviii: Coordination of ATOC open day invitations and responses to be provided by Board Secretariat team.
Board 19.03.2013 Action xxix: Keith Brown letter to be circulated to Board members.
Item 18: Meeting review
68. We agreed that the discussion on Outputs had been productive with a significant number of decisions although it had run over time.
Below the line items
Item 19: RM3 assurance paper
69. The paper was noted and we agreed that it would be important to have a further Board discussion. Ian suggested that this could be picked up as part of the six monthly review of health and safety.
Board 19.03.2013 Action xxx: RM3 discussion to be scheduled on Board forward programme.
Item 20: Staff observers at Board meetings
70. The proposal to invite staff observers to future Board meetings was discussed. We noted the Chair’s comments about the importance of improving our own transparency if we were to promote it across the industry. We suggested that the proposal could be revisited as part of the wider transparency agenda, but given the volume and complexity of board business to be dealt with on PR13 it was not sensible to begin this initiative now. The Board Secretary agreed to schedule further consideration at an appropriate time.
Board 19.03.2013 Action xxxi: Further discussion on the proposal for staff observers at Board meetings to be scheduled. Anna Walker Chair Minutes approved by the Board on 30 April 2013
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f252556044aa06a5596f153355280d524089c392 | Minutes of the first session of the 93rd Board meeting on 29 April 2013 (14:00 – 18:30) in Room 1, ORR offices, One Kemble Street, London
Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Michael Beswick (Director, Rail Policy), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Dan Brown (Director, Strategy), Richard Emmott (Interim Director, External Affairs), Carl Hetherington (Deputy Director, RME), John Larkinson (PR13 programme Director, Juliet Lazarus (Director, Legal Services), Tess Sanford (Board Secretary), and Gary Taylor (Assistant. Board Secretary).
In attendance, specific items: Richard Gusanie (PR13 project manager), Andrew Wallace (Head of Planning and Operations), Sue Johnston (Deputy Director, RSD), Chris Fieldsend (Industry Planning manager), Jonathan Hulme (Financial analyst), Richard Fitter (Financial Analyst)
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. There were no apologies for absence.
Item 2: Declarations of interest 2. There were no declarations of interest.
Item 3: PR13 – decisions relating to the content of the draft determination 3. Richard Price introduced the item. The Board had spent a great deal of time discussing and debating elements of the CP5 package both in Board meetings and through the PR13 Committee (PRC). The executive had listened carefully to all of those discussions and held extensive debates internally. They believed that the package presented met the Board’s intentions and struck a good balance between setting tough targets and allowing sufficient flexibility for Network Rail (NR) to manage its business and to deliver additional benefits through good management. The proposal still included a number of scoped options where the Board’s judgement would be sought and applied. In particular the Board would be clearly shown areas where the evidence was not good enough to support a strong recommendation or where the executive had not reached consensus on a recommendation, and they would be asked to reach judgements. There was a day and a half of meetings scheduled and it was important that decisions were reached so that the timetable for publication could be met. Overall it was a robust, well developed package and he commended it to the Board.
1 item 8 from 30 April agenda was brought forward for discussion at the evening session on 29 April and the discussion is recorded here. 4. John Larkin explained how he would take the Board through the agenda. He had confidence that the overall package would stand up well to scrutiny but it was important that the Board took this opportunity to test and challenge the proposals as this would be the last chance to do so before the final run of the financial model which would populate the draft determination document. To that end, all the project leads would be available to answer any questions from the Board on the detail of the proposal or the process that had led to a particular recommendation.
5. The Section 4 duties and the guidance from the Secretary of State and the Scottish Minister had been circulated with the Board papers as a refresher for Board members. At each significant point John would explain how the Executive had applied the duties and guidance in reaching their recommendations.
6. Cathryn Ross reminded the Board that they were required to consider the framework of ministerial guidance and S4 duties, but that they were constrained in some other areas - such as by the Access and Management Regulations.
[The rest of this section has been redacted from the published minutes because it relates to the formulation of policy]
EVENING SESSION
Item 8 of the Board agenda from 30 April
Network Rail Performance and REMCO letter
71. Alan Price explained that ORR wrote each year to NRs Remuneration committee with our initial assessment of NRs performance for the year so they could take this into account when considering management performance. A draft had been circulated with the Board papers.
Paragraphs 72-75 to be redacted as they contain sensitive information
Redaction ends
76. The Chair and Chief Executive should agree a revised draft and the Chair should sign the letter. It should be copied to the Board.
Board 29.04.2013 Action ii: Revised letter to NR Chair to be circulated to the Board after sending.
Anna Walker Chair
Minutes approved by the Board on 21 May 2013
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15c7b04c33d7507475e5d4330c89d7c22eab2140 | Office of Rail Regulation
Minutes of the 93rd Board meeting on 30 April 2013 (09:00 – 17:00) in Room 1, ORR offices, One Kemble Street, London
Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Michael Beswick (Director, Rail Policy), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Dan Brown (Director, Strategy), Richard Emmott (Interim Director, External Affairs), Juliet Lazarus (Director, Legal Services), Tess Sanford (Board Secretary), and Gary Taylor (Assistant Board Secretary).
In attendance, specific items: John Larkinson (PR13 programme Director) items 4 and 5, Sue Johnston (Deputy Director, Railway Safety), Graham Richards (Deputy Director, RPP), Nigel Fisher (Head of performance, information and analysis), Andrew Wallace (Head of Planning and Operations), Chris Fieldsend (Industry Planning manager), Carl Hetherington (Deputy Director, RME), Jonathan Hulme (Financial analyst) Richard Fitter (Financial Analyst),
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting.
Item 2: Declarations of interest 2. Mike Lloyd confirmed that due to other commitments he will be standing down as an ORR Non-Executive Director at the end of October. On behalf of the Board the Chair thanked Mike for his considerable contribution to the work of the Board during his term and particularly for agreeing to see the PR13 process through.
Item 3: Monthly Safety report / issues to advise the Board 3. Ian Prosser raised the following safety points:
- Following the update in March, Ian reported that track quality and broken rails in the Sussex area remained a concern. Ian confirmed that ORR’s inspectors continued to monitor this issue closely.
- Despite the continuation in improvements to workforce safety Ian reported that improvement notices had recently been issued in relation to incidents involving road rail vehicle operation and adjacent line working. Network Rail has confirmed that initiatives are ongoing to make the necessary improvements.
- Statistics have shown that level crossing fatalities have risen over the last 12 months; however this was the first time none of these fatalities had been attributed to industry failings.
- Work had been completed in carrying out the RM3 assessment of Network Rail.
- The proposed extensions to Manchester Metro Link had recently been approved by ORR.
4. Following discussion it was agreed that it was crucial to capture the key safety issues in our annual performance letter to Network Rail. Safety performance had continued to improve but the overall level of safety risk remained high with a number of areas requiring improvement. We agreed that this links to the overall package of decisions for PR13 and that the messages included in the annual performance letter should set the scene for our Draft Determination (DD) and prefigure our position on the shaping of expenditure for areas such as maintenance, enhancement and renewals.
5. We agreed that the Chief Executive and Ian Prosser, with input from Steve Walker, would look at ensuring that the annual performance letter was balanced but raised the concerns we have, particularly in the areas of asset management, asset knowledge, renewals and maintenance.
Board 30.04.13 Action i: Tell safety story clearly in annual assessment, including the areas where there has been a real improvement. The Chief Executive would work with Ian Prosser, with input from Steve Walker.
Items 4 and 5: PR13 policy Decisions
6. John Larkinson presented this item which set out a suite of recommendations for Board decision as part of the overall package of PR13 policy decisions - to be included as part of the published DD document.
7. We considered the importance of remembering our legal framework and our relevant section 4 duties when looking at the overall package of decisions. For each topic John would provide the Board with a summary of the relevant section 4 duties for consideration.
Paragraphs 8-49 and related action points have been redacted from the published minute as they relate to policy development.
50. We agreed that that further analysis was required in two key areas.
- We asked for work to be carried out to assess where we are on achieving the published McNulty savings. As part of this we agreed that it would be important to make clear responsibilities for each area for achieving these savings.
- It was agreed that it would be useful to understand where there was scope for NR outperformance and those areas which were considered to be particularly challenging.
51. John agreed to produce these additional areas of clarification for Board understanding. It was agreed that these would be circulated to the Board though correspondence.
52. We agreed that the determination offers an appropriate balanced package for Network Rail.
53. In conclusion we thanked John and the PR13 team for the comprehensive and informative discussion.
Item 6: Draft Determination Handling Strategy
54. Richard Emmott prepared a draft handling strategy for the publication of the Draft Determination.
55. Following the discussions around the overall package for the DD, Richard agreed to revise the handling strategy to pick up many of the points raised on the key messages we need to tell. Following these revisions, Richard would circulate to all Board members for comments.
**Board 30.04.13 Action vii: Richard Emmott to circulate revised Handling strategy to Board members for comment**
**Item 7: Update on Freight**
56. We noted the presentation which set out the issues on freight, passenger franchises and open access and the associated charges. Cathryn confirmed that the presentation covered two key areas – firstly to provide background briefing on the latest issues. Secondly the slides provide a skeleton of the May Periodic Review Committee paper which will be discussed on 9 May 2013.
**Briefing points**
57. We noted that discussions around freight and charges were still taking place. Cathryn assured the Board that the team were handling these issues and will provide a comprehensive update at the PRC meeting.
58. We noted that the Rail Freight Operators Association (RFOA) had provided analysis of the charges and had placed significant emphasis around the capacity charge. We discussed the calculation of charges. Cathryn confirmed that NR has responsibility for calculating charges. We noted that RFOA had raised a concern that they had not had enough time to prepare a response to NR’s consultation but that staff did not feel this was justified as they had been involved in many of the discussions and meetings.
59. We asked whether the capacity charge should be included as CDI charges (Costs Directly Incurred) Cathryn confirmed that this issue would be picked up at the May PRC meeting. *Some text has been redacted as it may relate to legal professional privilege \[*\]
**PRC slides – skeleton for 9 May meeting**
60. Cathryn confirmed that it would be important to consider the legal framework as well as to discuss our position on our statutory duties and guidance. We also agreed that it would be important to consider the overall PR13 package and overall impact on freight. Ensuring consistency of approach between freight, passenger and open access traffic would be important to meet the legal obligation to avoid discrimination.
61. We agreed with the suggested outline of the slide pack. As part of the analysis, we agreed that it would be important to pick up the following additional pieces of information:
- analysis on the impact of proposed changes on the Scottish coal industry and the overall freight sector.
- the impact on the profitability of freight operators and shift to road haulage to assess any modal shifts. Handling will be an important area for consideration. Cathryn confirmed that this will be included in discussions around handling for the recommendations and the other options available for decision.
We agreed that a draft of the slide pack would be shared with the Chair as soon as possible and in advance of circulation to PRC members.
**Board 30.04.13 Action viii:** Impact analysis on Scottish Coal industry to be provided as part of May PRC paper
**Board 30.04.13 Action ix:** Draft paper to be provided to Chair for comments as soon as possible.
**Item 8: Network Rail performance**
[discussed at dinner on 29 April and included in the note of that meeting]
**Board 30.04.13 Action x:** Final letter to be circulated to Board members
**Item 9: CE’s Assurance and accountability report – Quarter 4**
Due to time constraints we agreed to defer this item to the May Board meeting.
**Board 30.04.13 Action xi:** CE’s accountability report to be included on May Board agenda.
**Item 10: SCS pay policy**
At this point, the SCS members present asked whether it was appropriate to remain in the meeting for this discussion. The Chair and non-executives agreed that they could stay.
We noted the proposed SCS pay policy which had been discussed and agreed by the Remuneration Committee on 22 April 2013. Following consideration we agreed with the suggested approach.
**Item 11: Chair’s report**
The Chair highlighted the following:
Following a recent meeting, Transport Scotland explained that after the independence vote, Scotland hopes to repatriate network regulation to Scotland and combine all regulators in a single organisation. They are keen for ORR to help them in thinking through the issues with factual information. We agreed with the recommendation provided that discussions are factual.
David Currie (new Chair Competition and Market Authority) had been present at the recent Regulatory Chairs meeting. Following discussion we agreed that we should schedule a discussion on ORR’s competition powers at our July meeting.
Following a number of high level European meetings, we agreed that we should schedule a discussion at the July Board meeting to discuss progress and challenges to our European objectives.
We noted the Board objectives for 2013-14. We agreed that the objectives should be sharper and focus on key success measures. The Board Secretary agreed to revise and circulate to Board members. Board 30.04.13 Action xii: Strategic discussion on Europe to be included on Board forward programme Board 30.04.13 Action xiii: Discussion on ORR’s use of competition powers to be included on Board forward programme Board 30.04.13 Action xiv: Board objectives to be redrafted and circulated for comments.
Item 12: CE’s overview report
73. The Chief Executive highlighted the following:
74. Positive meeting had recently taken place with Paul Deighton (Commercial Secretary, HM Treasury) and a programme of engagement with HM Treasury is currently being developed.
75. The final budget figures for 2012-13 showed an overall underspend of 3%. The consultancy budget had been used effectively during the period.
Item 13: Board forward programme
76. The Board forward programme was noted. No comments were received.
Item 14: Approval of minutes of Board meeting held on 19 March 2013
77. The draft minutes of the meeting held on 26 February 2013 were noted and agreed subject to one further redaction. Board 30.04.13 Action xv: finalise redaction.
Item 15: Matters arising not taken elsewhere on the agenda
78. The updates on the outstanding Board actions were noted.
Item 16: Any other business
79. No items were raised.
Item 17: Meeting review
80. We agreed that the discussion on the package of PR13 decisions had been productive with a significant number of decisions. We congratulated the team for the careful preparation work and very creditable performances when handling scrutiny and testing questions which had enabled us to take decisions with a high degree of confidence in the options before us.
Anna Walker Chair Minutes approved by the Board on 21 May 2013
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5c65fbd8d3b9bb038daff988b48aa75c403b8167 | Office of Rail Regulation
Minutes of the 94th Board meeting on 21 May 2013 (09:00 – 14:00) in Room 1, ORR offices, One Kemble Street, London
Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Michael Beswick (Director, Rail Policy), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Richard Emmott (Director, External Affairs), Juliet Lazarus (Director, Legal Services), Tess Sanford (Board Secretary), and Gary Taylor (Assistant Board Secretary).
In attendance, specific items: Dan Brown (Director of Strategy) (items 1-4), Alasdair Frew (Head of Corporate Communications), John Larkinson (PR13 programme Director) (items 4-6), Carl Hetherington (Deputy Director, RME), Gordon Cole (Principal financial analyst)
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. There were no apologies for absence.
Item 2: Declarations of interest
2. None.
Item 3: Monthly Safety report / issues to advise the Board
3. Ian Prosser raised the following safety points:
- Following the update in April, Ian reported that track quality and broken rails issues in the Sussex area had improved but continued to remain a concern. Ian would keep Board members updated.
- The yearly assessment of Network Rail safety performance using the RM3 assurance model shows that there is improvement in a number of safety areas. Ian confirmed that improvements in overall safety culture were still required.
- The recent rise in Signals Passed at Danger (SPADs) had now reduced. Ian reported that the industry had carried out research to assess whether there were any trends to explain this rise without any definitive conclusions. Ian confirmed that ORR will continue to monitor.
- We noted that the data for level crossing fatalities showed an increase in fatalities inside vehicles while the Precursor Indicator Model (PIM) showed a downward trend. There were a number of factors which affected this. Mike Lloyd would discuss this with Ian outside of the meeting. We discussed further the process for inspection at level crossing incidents. Following discussion Michael Beswick suggested that discussions with Peter Rayner (NR) should take place. Ian agreed that he would ask David Keay to contact Peter.
- We discussed the impact of severe weather on the PIM. Ian agreed to circulate a report which highlights the issues and the approach being adopted by Network Rail to address this.
6. We discussed a recent incident involving a runaway Road Rail Vehicle which was highlighted in the useful summary of prohibition notices which Ian had shared with the Chair. Ian confirmed that work was ongoing in this area and Network Rail has made some improvements to braking systems to address this. Ian confirmed that this was an area where ORR would continue to monitor. We agreed that it would be useful for all Board members to receive the summary of prohibition notices. Ian agreed to circulate this summary to all members in the future.
**Board 21.05.13 Action i:** Mike Lloyd to discuss the data on level crossing fatalities with Ian Prosser off line.
**Board 21.05.13 Action ii:** Weather impacts report to be circulated by Ian to Board members
**Board 21.05.13 Action iii:** Agreed that Ian would circulate summary of prohibition notices to Board members for information.
**Item 4: Freight: Cumulative impact of changes to access charges**
7. Cathryn Ross presented this item which provided the Board with a number of detailed options for final decision.
8. Cathryn provided a reminder of our previous discussions on 9 May 2013 highlighting that we had discussed the move towards cost reflective charging and how best to mitigate the effects. We also discussed the framework of charges which relate to costs directly incurred (CDI) and mark ups. We agreed that we wanted a CDI cap which was more cost reflective.
*The rest of this item has been redacted as it relates to policy development*
**Item 5: Draft Determination Executive Summary**
16. John Larkinson presented the draft determination executive summary for Board consideration and comment. John confirmed that the first draft had been seen by both the Department for Transport and Transport Scotland. John also confirmed that an initial discussion has been held with David Higgins (CEO Network Rail) and other relevant points shared with selected contacts at NR. The final cut of the document would be completed by the end of May with further internal comments.
17. Board members made the following comments:
- The summary was crucial as it highlighted the significant points of our PR13 story. We agreed that refinements would be made to highlight those key points but stressed the importance of making the summary concise and to the point to ensure that the document does not become too long and detailed which could result in loss of impact.
- the consideration given to our section 4 duties should be explained
- Presentation should be improved – including presenting key facts in info-graphics.
- We discussed the status of the McNulty study projected efficiencies. We agreed that ORR’s analysis was now better and more current than McNulty’s and that we should explain this and make clear that we had confidence in it. We agreed that the tone of the executive summary was appropriately measured. We agreed that more clarity was needed on transparency, passengers and the continuous improvements we expected in safety.
John thanked everyone for their comments. We noted that a revised executive summary document would be circulated to Board members week commencing 27 May for final comments.
**Board 21.05.13 Action vi:** John Larkinson to revise DD Executive summary and circulate to Board members for comments.
**Item 6: Draft Determination Handling Strategy**
Richard Emmott presented this paper which set out the draft handling strategy for the publication of the Draft Determination.
Richard highlighted the following points:
- The sequencing of the publications was crucial to ensure that the messaging is aligned and consistent. We agreed that the language used will stress that robust but balanced assessments have been made.
- A segmented approach to the way in which the document is published will be adopted to ensure that the messages are delivered effectively to the variety of audiences we will be targeting.
- The PR13 microsite will be developed with greater use of social media to direct web traffic to the microsite.
- No press conference will be held. Pre briefings will take place. On 11 June embargoed briefing will be provided to members of the trade press. Staff will also be briefed at an all staff session.
- Work is ongoing to develop the approach to handle the post publication questions.
We thanked Richard and welcomed the opportunity to review the revised document through correspondence.
**Board 21.05.13 Action vii** Richard Emmott to circulate strategy to Board members for information.
**Item 7: MIP Structure**
We noted the paper which set out the arrangements for the NR Management Incentive Plan (MIP) for the final two years of CP4 and the first year of CP5. The remainder of this section has been redacted from the published minutes as it relates to policy development.
*Item 8 has been redacted from the published minutes in its entirety as it contains sensitive information relating to regulatory policy formulation*
**Item 9: Review of High Level Risk Register**
We noted the latest version of ORR’s High Level Risk Register (HLRR). The following points were raised: 29. Tracey Barlow confirmed that the Audit Committee received a substantial report on how the high level risks were linked to activity in ORR’s new business management system. The committee have asked for the format of the HLRR to be revised to better reflect the new approach to managing risk.
30. We suggested that the HLRR should include a risk on Europe as there are significant risks facing ORR and the British rail industry. The Chair agreed to circulate a note from her recent meetings in Brussels.
31. We agreed that the Board needed to own ORR’s high level risks and that we should therefore continue to review risk quarterly with an annual discussion to focus on a review of risks.
**Board 21.05.13 Action y:** The Chair agreed to ask Agnès Bonnet to produce and circulate note of recent discussions in Brussels.
**Item 10: CE’s Assurance and accountability report – Quarter 4**
32. The Chief Executive presented this report which provided an end of year assessment against our activities for 2012-13.
33. There was agreement that significant progress had been made in a number of areas. We did recognise that there were some workstreams which did not progress as significantly as planned – these included our work on consumers, competition, transparency and Europe – but overall it had been a very busy year and much had been achieved. The Chief Executive confirmed that this work would be addressed during 2013-14.
**Item 11: Chair’s report**
34. The Chair’s report was noted. The Chair confirmed that the Board objectives for 2013-14 would be circulated to Board members shortly for clearance through correspondence.
**Board 21.05.13 Action xi:** The Chair and Board Secretary to review Board objectives for 13-14 and send to Board members for clearance through correspondence.
**Item 12: CE’s overview report**
35. The Chief Executive’s report was noted. No comments were made.
**Item 13: Report back from the May Audit Committee**
36. Tracey Barlow highlighted the following:
- The NAO provided the Audit Completion Report on the 2012-13 financial statement audit; the 2012-13 financial statements are anticipated to be certified with an unqualified audit opinion, without modification.
- The Draft Internal Audit Annual Report 2012/13 was noted. From 12 audits carried out in 2012/13, no “nil assurance” opinions were issued and three “limited assurance” opinions were issued. All agreed management actions were implemented by 30 April 2013.
- We noted ORR’s annual report and resource accounts 2012-13. A small number of minor amendments were suggested and Elaine Horton agreed to incorporate these amendments before the annual report and resource accounts are taken to the Board.
**Item 14: Board forward programme**
37. The Board forward programme was noted. No comments were received.
**Item 15: Approval of minutes of Board meetings held on 29 and 30 April 2013**
38. The draft minutes of the meetings held on 29 and 30 April 2013 were noted and agreed.
**Item 16: Matters arising not taken elsewhere on the agenda**
39. The updates on the outstanding Board actions were noted.
**Item 17: Any other business**
40. We noted the recent correspondence received from David Higgins to the Chief Executive in relation to NR’s expectations for the Draft Determination. It was agreed that Board members would receive a draft of the Chief Executive’s reply to provide any comments in advance of it being sent. It was important that the Chief Executive was able to rely on the Board’s support for his response.
**Board 21.05.13 Action xii** Draft response to recent David Higgins letters to be sent to Board members for comment.
**Item 18: Meeting review**
41. We agreed that the meeting had been constructive and well-structured to allow significant time to discuss the substantive items on the agenda.
Anna Walker Chair Minutes approved by the Board on 25 July 2013
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51bef1a2b9576c9f514c8e26419110e981291377 | Office of Rail Regulation Minutes of the 95th Board meeting on 25 June 2013 (09:00 – 14:30), Hilton Hotel, Glasgow
Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O'Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Daniel Brown (Director of Strategy) Alasdair Frew (Head of Corporate Communications, External Affairs), Juliet Lazarus (Director, Legal Services), Alastair Gilchrist (Director, Corporate Operations), Tess Sanford (Board Secretary), and Gary Taylor (Assistant Board Secretary).
In attendance, specific items: John Larkinson (PR13 programme Director) (item 3), John Gillespie (Safety Policy and Central Regulation Division), Iain Ferguson (Manager, Industry Risk), Neil Anderson (Inspector), Nigel Fisher (Head of performance, Information and analysis), Jay Lindop (Analysis and research manager), Sam McClelland Hodgson (manager, Licensing and Network regulation), John Holmes (Senior Economist), Annette Egginton (Head of Competition and Consumer policy).
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. Apologies for absence were received from Richard Emmott.
Item 2: Declarations of interest
2. None.
Item 3: PR13 update
3. John Larkinson reported that overall there had been a positive response to the published draft determination. John confirmed that the Board would be provided with a final determination run in plan in July. This will set out the key dates and milestones in the build up towards publishing the final determination on 31 October 2013.
4. The July update would also provide the Board with an update on possible changes to the draft determination since publication. This will include new data and policy issues that looked as though they would emerge from the consultation. John highlighted that there were a number of issues to be discussed with the Board by September 2013. We agreed that these issues should include:
- Network Rail's desire to demonstrate profitability;
- Impacts on customers from schedules 4 and 8;
- Governance of funds including how access for all fund links to our DPPP role
- Climate change resilience;
- Innovation;
- Comparisons to other regulators’ calculations of the cost of capital; and • Clarity on our CP5 approach to the assessment of efficiency, both for MIP purposes and the annual financial assessment
5. We discussed HS2 and agreed that it would be important to schedule a Board discussion on the impact of HS2. The Board Secretary agreed to schedule a discussion to take place in September.
6. We thanked John for the update. The Board thanked John and the PR13 team for the considerable and impressive work undertaken by the team to produce the draft determination document.
Board 25.06.2013 Action i: HS2 discussion to be scheduled on the Board agenda for October.
Board 25.06.2013 Action ii: July discussion on European matters should include an update on channel tunnel regulation
Item 4: Monthly Safety report / issues to advise the Board
7. Ian Prosser raised the following safety points: • Three level crossing fatalities occurred in April 2013. A number of issues have been discussed with Network Rail (NR) around half barrier crossings. Work is ongoing to address these. • Improvements has been made on broken rails in the Sussex route as the result of the deployment of additional resources and improved planning. • We discussed the outstanding RAIB recommendations. Ian reported that significant progress had been made in closing a number of these. • We noted that DB Schenker had gained access to the Channel Tunnel. We agreed that the July Board discussion on Europe should include an update on Channel Tunnel regulation.
Board 25.06.2013 Action iii: European paper to include a summary of DB Schenker gaining access to the Channel Tunnel and tunnel regulation generally
Item 5: Annual Health and Safety report
08. Ian Prosser presented ORR’s draft 2012-13 annual health and safety report.
09. We agreed that the key messages of the report should reflect the concerns that the Board had discussed during 2012-13. This included workforce safety, workbanks/maintenance, slips and trips, the deteriorating trends in the PIM, earthworks and the impact of climate change, and level crossings. We agreed that we should highlight that we continue to monitor closely where improvements are required. The report also needed to pick up the position of SPADs (signals passed at danger), our view on the safety of pacers and RRVs (road/rail vehicles).
10. We asked about the possibility of having disaggregated safety data by route during CP5 as this would enable the matching of maintenance spend to safety performance – which would offer valuable intelligence. Ian confirmed that limited route data was currently available at present on track quality but further information would be available in CP5. Ian suggested that work between NR and Rail Safety and Standards Board (RSSB) had started to disaggregate the safety risk model. We agreed that we should insist on disaggregated data for CP5. We agreed that we should return to this issue once this work has been completed.
11. We discussed system risk and agreed that we should have a further discussion to ensure all Board members have a clear and consistent understanding of what system risks are in the railway context and what the indicators are in relation to this. We agreed that this should be picked up as part of the upcoming programme of Board health and safety training which will take place later this year.
12. We agreed it was important to be clear that the total of 28 enforcement notices issued should be identified as significant.
13. We agreed that Ian would assess whether there was more proactive inspection work which could be undertaken on heritage railway.
14. Ian thanked everyone for their comments and agreed to update the report accordingly. We agreed that we would share the report with RAIB and RSSB for comments. We also agreed that the Chair, the Chief Executive and Steve Walker (as Chair of SRC) would review the final draft before publication on 17 July.
15. Ian highlighted that the RSSB annual safety report was about to be published. We agreed that Board members would receive the report electronically and in hard copy.
**Board 25.06.2013 Action iv:** Route specific data to be shared with the Board when available
**Board 25.06.2013 Action v:** We agreed that the draft ORR annual Health and Safety report should be shared with RSSB and RAIB for comments.
**Board 25.06.2013 Action vi:** RSSB annual report to be sent to Board members - hard copies and electronically
**Board 25.06.2013 Action vii:** Final draft of the ORR annual health and safety report to be shared with the Chair, Chief Executive and Steve Walker before publication.
**Board 25.06.2013 Action viii:** Sources of assurances and how this is taken into account should be picked up as part of the programme of Board health and safety training along with training on railway systems.
**Item 6: Safety Assurance – RM3**
16. We noted the paper which set out how ORR uses the RM3 model to support the discharge of our regulatory functions.
17. We agreed with the recommendation that there should be a review of the RM3 model. We agreed that the review should be formal, consultative and independent. We agreed that it would also be important to get the views of stakeholders and duty holders. It was agreed that this would also be an opportunity to benchmark the model against international best practice models. As part of the review we also agreed that it was important to assess all of ORR’s sources for gathering safety data to understand whether there are any significant gaps.
18. It was agreed that a further discussion around the scope and purpose of the review of RM3 should be taken at the SRC meeting on 22 July. John Gillespie agreed to prepare a paper to focus the discussion. Board 25.06.2013 Action ix: Purpose and proposals for the review of RM3 to be further discussed at the July SRC meeting. (To include international benchmarking)
Item 7: Safety considerations arising from the Mid Staffs Public Inquiry report
19. We noted this paper which set out relevant lessons for ORR as a regulator from the Mid Staffs public inquiry report.
20. We discussed the role of the ORR Board and the frequency of safety discussions. We discussed the various methodologies used to identify safety trends and agreed that these should be further discussed as part of the programme of Board level safety training.
21. We discussed the relationship with RAIB and RSSB. We agreed that work was constructive and recognised that further closer working was required to ensure that the needs of passengers are addressed.
22. We discussed regulatory targets for safety performance and whether the pursuit of outputs as set as part of the final determination for CP5 could negatively affect safety performance. We agreed that the published draft determination did consider safety as an integral part of the overall package. We agreed that it would be important for our inspectors to monitor and highlight any areas where the pursuit of outputs has a negative effect on safety performance.
Item 8: Performance – Long Distance and South East recovery plans
23. Alan Price presented this item which set out our investigation of Network Rail’s (NR) long distance (LD) and London and South East (LSE) sector performance in 2012-13.
Paragraphs 24-25 have been redacted as they contain regulatory enforcement material
26. As a result we agreed that a case to answer letter should be sent to Robin Gisby at Network Rail. This letter would set out our findings and next steps. In parallel to this we agreed that the Chair would discuss the issues with Richard Parry Jones (NR Chair) to raise our concerns. We would return to this issue at the July Board to hear the outcome of the Chairs’ discussion and the response from NR to the case top answer letter
Board 25.06.2013 Action x: Case to answer letter to be sent to NR with a final decision to be taken by the Board in July.
Board 25.06.2013 Action xi: In parallel to the case to answer letter, the Chair agreed to discuss these issues with RPJ over the phone and follow this up with a letter.
Item 9: Update on Competition landscape
27. Cathryn Ross provided an update on the competition landscape and the proposed changes to competition powers.
28. Cathryn reported that the Enterprise and Regulatory Reform Act (ERRA). The ERRA created the Competition and Markets Authority by merging the Office of Fair Trading and the Competition Commission. The CMA will be the body responsible for investigations of anti-competitive behaviour under the Competition Act 1998.
29. We recognised that are a number of strategic threats and opportunities arising from the changing competition landscape. We were pleased to see that the new framework provides us with a platform to promote the objectives of economic regulation. We would also have the opportunity to engage with CMA and to increase our own internal expertise by closer working with other regulators as part of the enhanced concurrency arrangements.
30. We noted the areas of work which will be brought to the Board over the coming months. This included holding a proposal for a competition Board workshop. It was agreed that this would be a useful exercise to feed into the development of the 2014-15 Business Plan.
31. We noted that David Currie, CMA chair, will be attending our Board meeting in November.
**Item 10: Consumers – Follow up from May workshop**
32. We noted the paper which presented a draft consumer narrative for Board consideration. The paper also provided an update on work following the Board consumer workshop which took place in May.
33. Cathryn presented the narrative and suggested that it was about addressing barriers that prevent the rail industry responding to consumers and therefore creating a successful and sustainable railway in years to come. It put a lot of emphasis on working with others (TOCs, Passenger Focus etc.) and changing how we worked as an office. It also meant understanding the outcomes experienced by consumers and shaping our role to improve this wherever appropriate. We agreed that the draft narrative was a positive step and provided better clarity around our role in this area. The proposal was to report annually on what we had done for consumers. It was agreed that the narrative should include clear outputs and messages around what we want to be delivered.
34. We noted the programme of work. We agreed that there was a lot of activity to be completed in a short period of time. To enhance our credibility in this area we agreed that it would be beneficial to deliver some early successes. We agreed that further work was required to develop the work programme further to include clear targets with dates and resource levels which highlighted the difference we aimed to make. It was agreed that the programme should also segment customers so that the Board could discuss options on which to concentrate.
35. We discussed the arrangements for resourcing this work during 2013-14. We agreed that it would be crucial to have the right levels of resource both in terms of quantum, but also in terms of skill set and experience. With this in mind we asked the executive team to provide the Board with an update in September on the plan and what resources and expertise will be needed to deliver our plan effectively. Board 25.06.2013 Action xii: Consumer work programme to be updated (dates/resources) and brought back to the Board in October
Board 25.06.2013 Action xiii: Consideration of the appropriate level of resources to be discussed by the Board in October.
Item 11: Draft Long Term Regulatory Statement
36. Daniel Brown provided an update on the process for producing the Long Term Regulatory Statement (LTRS).
37. Dan confirmed that a draft had been shared with HM Treasury, DfT and Transport Scotland. Comments have been received and the document is continuing to be updated with these comments. We agreed that it would be useful to set up a conference call with available Board members to provide comments on the draft document.
38. We discussed the communications strategy for the publication of the document. Alastair Frew confirmed that this was currently being developed and would be shared with Board members in advance of the LTRS being published.
39. We noted that an announcement on the Spending Review was taking place shortly. We suggested that this announcement might include references to relevant infrastructure projects and have implications for the LTRS. Dan agreed to monitor the announcement and update the Board if necessary.
40. We thanked Dan for the considerable work undertaken to produce the draft LTRS. We agreed that following the conference call meeting and any other comments from Board members in correspondence, the chair and chief executive would sign off the LTRS for publication.
Board 25.06.2013 Action xiv: One hour telephone discussion to be set up to further discuss LTRS
Board 25.06.2013 Action xv: Short note if any of George Osborne’s announcement affects the LTRS
Board 25.06.2013 Action xvi: Communications plan to be developed and circulated to Board members.
Board 25.06.2013 Action xvii: We agreed that the Chair and Chief Executive would sign off the LTRS document.
Item 12: ORR capability and Organisational Development programme
41. Alastair Gilchrist presented this item which provided an update on the organisational development programme.
42. Alastair reported that there had been a positive response from staff to the eight programmes of work with positive levels and engagement demonstrated by the results from the quarterly staff pulse survey.
43. We discussed the need to address the concerns raised from staff in the annual survey that there was an unclear understanding of the Board’s vision. We agreed that this was an important issue to resolve. As a result we suggested that we should have a discussion at the July Board meeting. We also agreed that further thought needed to be given to ensuring ORR had the right commercial skills.
**Board 25.06.2013 Action xviii:** Discussion on the Board’s vision to be scheduled for the July Board meeting.
**Item 13: Chair’s report**
44. No items were raised by the Chair.
**Item 14: CE’s overview report**
45. The Chief Executive’s report was noted. We noted the letter from HM Treasury asking ORR, along with other regulators - to agree to a 5% saving in 2015-16 over our 2014-15 baseline budget. Following discussion we agreed with the suggested response which reserved our position as a Board to set a budget which allowed us to meet our statutory responsibilities but acknowledged our intention to work toward a reducing resource envelope.
**Board 25.06.2013 Action xix:** The Board agreed with the proposed letter to HMT and was content for the letter to be sent.
**Item 15: Board forward programme**
46. The Board forward programme was noted. No comments were received.
**Item 16: Approval of minutes of Board meetings held on 21 May 2013**
47. The draft minutes of the meetings held on 21 May 2013 were noted and agreed.
**Item 17: Matters arising not taken elsewhere on the agenda**
48. The updates on the outstanding Board actions were noted.
**Item 18: Any other business**
49. No items were raised.
**Item 19: Meeting review**
50. We agreed that the meeting had been productive. Concerns were raised around the volume of paper work generated for the meeting. We understood that this was driven by the issues discussed; however we agreed that we would look for ways to further reduce paper work for future Board meetings. Below the line items
Item 20: Committee review reports
51. We noted the Board committee reports. We agreed that chairs' of each committee would provide a summary of work undertaken in 2012-13 and a forward look at the July Board meeting.
Item 21: SRC forward look
52. We noted the SRC forward look. No comments were raised.
Anna Walker Chair Minutes approved by the Board on 23 July 2013
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75491a22b53eb0ac463c4b8cd8aec6e24888cf72 | Office of Rail Regulation Minutes of the 96th Board meeting Session 1 on 22 July 2013 (14:00 – 17:30), ORR offices, One Kemble Street, London – Room 1
Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O'Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Daniel Brown (Director of Strategy) Sue Johnston (Deputy Director, Railway Safety), Giles Buckenham (Deputy Director, Legal Services), Tess Sanford (Board Secretary), and Gary Taylor (Assistant Board Secretary).
In attendance, specific items: Ian Prosser (Director, Railway Safety) (item 7) John Larkinson (PR13 programme Director) (item 3), Carl Hetherington (item 3), Graham Richards (item 3), Annette Egginton (Head of Competition and Consumer policy) (item 4).
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. Apologies for absence were received from Ian Prosser and Juliet Lazarus (Mr Prosser attended part of the meeting by phone).
Item 2: Declarations of interest
2. None.
Item 3: PR13 – Final Determination run in plan and policy issues
3. John Larkinson presented the key milestones and dates for the build up towards publication of the Final Determination document on 31 October. John also highlighted the key policy issues which need to be discussed by the Board during September and October.
Paragraphs 4-5 have been redacted as relating to policy development
6. We noted the key dates for Board discussions on remaining PR13 issues. John highlighted that Network Rail would be presenting their views on the draft determination on 3 September. John confirmed that detailed briefing would be provided to ORR Board members in good time. We agreed that it was important for the Board Secretariat to confirm timings of the NR session as soon as possible.
7. We noted the considerable amount of work which had been carried out by colleagues across the organisation to complete work consulting on charges and contracts by 12 July. This was detailed, complex and comprehensive work and we congratulated colleagues on completing this work to tight timescales. We discussed whether a regulator should be required to get involved at this level of detail. John confirmed that there was a requirement stated in the railways act, however, we should look at the case for changes to ensure that we did not have to get into as much detail for future reviews. Board 22.07.2013 Action i: In relation to the considerable amount of detailed work undertaken on individual licences as part of the implementation - we agreed to look at changes so we could remove ourselves from the detail in the future.
Board 22.07.2013 Action ii: We agreed that we require the calculus for the range of adjusted WACC clearly set out in October so Board members fully understand how it is arrived at.
Board 22.07.2013 Action iii: We agreed that it would be important to for the Board to look at assumptions and management of inflation - to remind ourselves how we made the decision and to look at how we communicate it.
Board 22.07.2013 Action iv: We agreed that it would be useful for the Board to have a reminder of the whole package of decisions made and the reasons why
Board 22.07.2013 Action v: We agreed that we would circulate the Christian Woolmar article on Schedule 4 and 8 payments to Board members.
Board 22.07.2013 Action vi: Impact of HS2 - need to consider this further - including the impact beyond CP5.
Board 22.07.2013 Action vii: Secretariat to firm up timings for the NR PR13 presentation to the Board on 3 September.
Item 4: Transparency
08. Richard Emmott presented this paper which set out ORR’s proposed approach to transparency during 2013-14 as well as a draft of ORR’s transparency statement.
09. Richard demonstrated that significant progress had been made over the last 12 months including the publication of the GB Rail financial report, and standard data releases such as station usage figures. This has been supported by a better use of social media to draw attention to the release of information. Richard recognised that there is more work to be done and highlighted the following areas of focus during 2013-14. This included: • The publication of quality CP5 data by route level; • An improved GB Rail financial publication next year building on the feedback we have received. • Establish a whole-industry scorecard and publish in the Monitor annually. • Further develop the approach to Real Time Train Information with the proposal to establish a stakeholder group with an independent chair.
10. We noted the progress made and agreed that this had been a positive step change in our approach. We made the following comments on the content of the transparency statement: • it should clearly explain why ORR considers the drive towards greater transparency to add value. • it should explain ORR’s role and the specific actions we plan to take in the short and long term. Particularly looking at what we hope to achieve during CP5. • it should focus on the beneficiaries of our transparency work – customers, tax payers and suppliers –recognising that there were a number of overlaps between these groups. • it should consider market failures – looking at transparency as a model to address gaps which the market had failed to provide.
11. We thanked Richard Emmott and Annette Egginton for the paper. We agreed that the transparency statement would be revised following the comments received and delegated to the Chair and Chief Executive to sign off.
**Board 22.07.2013 Action viii:** Rework paper in line with comments. **Board 22.07.2013 Action ix:** The Board delegated sign off for the transparency statement to the Chair and Chief Executive.
**Item 5: CE’s accountability report – Q1**
12. The Chief Executive presented this report which used the outputs from ORR’s Business management system to provide a summary of ORR’s progress against our 2013-14 Business Plan. We noted the revised format of the quarterly report and agreed that it looked good. The Business Plan would need to be part of the report in some way. The paper had only been tabled at the meeting and any further comments were therefore sought in correspondence.
13. We highlighted the following key points:
- the presentation of the current risk scores were unclear. Future reports should use the summary page currently included in the high level risk register or something similar.
- it would be useful for future reports to assess progress against the strategic objectives, not each directorate.
- it would be useful to include an update against the specific business plan activities to ensure that the Board is able to monitor the overall progress against these milestones.
- the report should be available to all staff to view on ORRacle.
14. We discussed the current cross office work being undertaken to look at our approach to the civils programme as well as enhancements. In considering our approach we agreed that we should address the points set out in the guidance from the Secretary of State for doing more to add value for money on enhancements and ensure there were enough resources in place to achieve this.
15. In conclusion we agreed that the new approach was promising. The Chief Executive agreed to circulate a prompt to all Board members to provide feedback on the structure of the report and to provide any further suggestions for improvement.
**Board 22.07.2013 Action x:** Comments from Board members required on format - The Chief Executive agreed to send email to prompt comments.
**Board 22.07.2013 Action xi:** We agreed that the SoS guidance should be considered when reviewing our priorities and levels of resourcing for the work on civils and enhancements.
**Item 6: Board Committee review of effectiveness**
16. The Board Secretary presented the findings and recommendations arising from the review of ORR’s Board committees.
17. We noted the recommendations in turn and made the following significant comments:
- We agreed that it would be important for committee chairs to provide an oral report to the Board to understand the significant areas of interest/concern that the Board should be aware of. The Committee annual reports should also provide an assessment against the remit of each committee rather than a report of proceedings.
- We agreed with the proposal for the introduction of a nominations committee. The Terms of Reference would be discussed at the committee's first meeting and resubmitted for Board approval.
- Providing clarity around the SRC terms of reference was agreed. We stressed the need to ensure that we clarify the function of the committee as this was currently not clear. We agreed that the Chair, Chief Executive, Board Secretary and Steve Walker would have a further discussion to focus on the SRC terms of reference.
Following discussion we agreed with the recommendations and tasked the Board Secretary to implement these in accordance with the suggested timescales. We noted the scope for further improving our governance and the work planned to take this forward.
**Board 22.07.2013 Action xii:** The Chair, Chief Executive, Board Secretary and Steve Walker to discuss SRC ToR
**Board 22.07.2013 Action xiii:** Agreed with recommendations in the report and agreed with timescales for work to take place and implementation.
**Item 7: Briefing for Board discussions with the Trade Unions and Richard Parry Jones**
19. We discussed the next day's Board discussions with Trades Union representatives (to hear their views on ORR's draft determination) and the chair of NR, Richard Parry Jones who had agreed to talk to us about the NR Board's plans for improving performance.
Anna Walker Chair Minutes approved by the Board on 17 September 2013
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fd702b546480284bc9c01afa7be14dd79fb95339 | Office of Rail Regulation Minutes of the 96th Board meeting Session 2 on 23 July 2013 (09:00 – 15:30), ORR offices, One Kemble Street, London – Room 2 Board present:
Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items except Item 6: Daniel Brown (Director of Strategy) Sue Johnston (Deputy Director, RSD), Juliet Lazarus (Director Legal Services), and Gary Taylor (Assistant Board Secretary). Tess Sanford (Board Secretary) in attendance for all items
In attendance, specific items: John Larkinson (PR13 programme Director) (item 4 and 5), Carl Hetherington (Item 4), Mark Morris (item 4), Amanda Clark (item 4), Richard Parry Jones and Jon Haskins Head of Regulatory Compliance and Reporting at Network Rail (Item 6), Nigel Fisher, Samantha McClelland Hodgson, Jay Lindop (Item 7), Brian Kogan, Ian Williams, Paul Hadley (Item 8), Annette Egginton (Item 9). Mick Whelan (ASLEF), Manuel Cortes (TSSA), Elly Baker, TSSA, Bob Crowe RMT, Mick Cash, RMT, Peter Pinkney, RMT (item 5)
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. Apologies for absence were received from Ian Prosser.
Item 2: Declarations of interest 2. None.
Item 3: Monthly Health and Safety Report 3. Sue Johnston highlighted the following safety issues: 4. NR had not met their commitments on staff numbers in delivery units and this meant that workbanks were continuing to grow. We discussed the limitations on safety inspectors who were required to find specific material risks, and could not therefore use safety enforcement to require NR to reduce the size of the workbanks. We discussed whether there were economic regulatory tools that we could use as it was clear that the asset base was suffering from the lack of preventative maintenance. 5. Reporting against close call monitoring was now underway. Significant regional differences suggested that it was still not capturing all incidents in some areas – this was likely to be caused by issues around contractors’ staff. Where it was being done properly, management were finding the information helpful. 6. In response to a question about a specific recent incident on a crossing, Sue reported that NR are planning to do a major review of risk on level crossings. This meant that their historic level crossing risk assessments (which were of varying age and quality) would not be reviewed individually. Item 4: Network Rail – Overall financial performance
7. Carl Hetherington presented this item which set out recommendations for financial adjustments to be made to Network Rail’s financial performance for 2012-13 to be included in the Annual Assessment of Network Rail’s financial performance to be published on 12 September 2013.
Paragraphs 8-13 have been redacted as they relate to policy development
14. In summary there was broad agreement with the suggested approach. However we did feel that further clarity around the range of numbers was needed to ensure that we understood the proposed total adjustment figure and the reasons for it – and for differences between us and Network Rail. We agreed that a clear rationale should be produced which included lines to take with Network Rail on these issues. We agreed that this should be done through correspondence to Board members in August.
Board 23.07.2013 Action i: We agreed that it was important to get the messaging right on FVA. These messages need to be at 2 levels - at CE level (press etc.) and NR level.
Board 23.07.2013 Action ii: These messages and steps need to be written up and circulated to Board members through correspondence.
Board 23.07.2013 Action iii: We agreed that we need to have a clear understanding of the risks around publication and how these will be managed.
Item 5: Trade Union representations – Feedback on ORR’s Draft Determination
15. We welcomed Peter Pinkney (President), Robert Crow (General Secretary) and Mick Cash (Assistant General Secretary) from the Rail Maritime and Transport (RMT), Manuel Cortes (General Secretary) and Elly Baker (Senior Regional Organiser) from the Transport Salaried Staff Association (TSSA) and Mick Whelan (General Secretary) from the Amalgamated Society of Locomotive Engineers and Firemen (ASLEF) to provide their feedback on ORR’s draft determination.
16. In summary the following points were raised and discussed in detail:
17. Concerns were raised over the casualisation of the industry with the increase of zero hour contracts for workers. Sue Johnston said that ORR recognised the potential safety consequences and have started to discuss with Network Rail. The Chair stressed that the draft determination did not result in the need for casual working in the industry.
18. Road related incidents due to rail workers undertaking long hours were raised as a concern. We agreed that fatigue management was an issue which the ORR has worked with the industry to address. Sue highlighted the recent published reports by both the RSSB and ORR and work in this area will continue.
19. Network Rail’s failure to manage the effects of severe weather conditions – most notably poor drainage and management of vegetation was highlighted. The Chief Executive agreed and said that the rate of progress made by NR to mitigate these risks was disappointing. We noted that the draft determination has provided for an additional £500m should Network Rail demonstrate that they have mitigated these risks effectively. Regulatory targets for the management of assets have also been included. The Chair confirmed ongoing concerns over climate change and severe weather as it has a severe impact on infrastructure. ORR has highlighted this issue in the draft determination and Network Rail have been asked to develop a plan to address these concerns in advance of publishing the final determination document in October.
20. Concerns were raised that the pace of change needed within Network Rail was unmanageable and would put safety standards at risk. The Chief Executive highlighted that the draft determination has a major focus on safety with input at all levels from safety colleagues from across the industry. Additional funds have been assigned to closing level crossings alongside additional funds assigned to address worker safety issues and civil structures.
21. Concerns were raised over the low levels of preventive maintenance. We explained that we have allowed for more money to ensure that a programme of maintenance is established to address the risks during the control period.
22. We discussed the comparisons for staff costs which were referred to in the draft determination (although they were not used in any calculation). John Larkinson agreed that he could discuss this with the Trade Unions to provide greater clarity on this.
23. We thanked the Trade Union representatives for their views. The Chair confirmed that the closing date for consultation responses was 4 September 2013.
Board 23.07.2013 Action xv: John Larkinson to offer to discuss staff costs comparators with the Trade Union groups
Item 6: Richard Parry Jones (Chairman, Network Rail) presentation to the ORR Board
24. [Richard Parry Jones (RPJ) and Jon Haskins joined the meeting.]
25. Anna Walker represented to him the very serious concerns of the ORR Board about Network Rail’s performance. It was clear that performance was not improving and that there were serious operational issues in delivering appropriate levels of maintenance and renewal work. ORR’s Board had invited him to attend the meeting so that we could be sure that we had done everything possible to tell the NR Board about the depth of our concerns.
26. We heard RPJ’s account of the structures for scrutiny and challenge that the NR Board used to hold their executive to account. He assured us that he did understand and to a large extent shared our concerns. During a wide ranging discussion he mentioned some issues where the two boards did not agree:
- The level of weather resilience appropriate for the network;
- Asset reliability targets in CP4 (which had no rational basis);
- The need to decouple performance and capacity.
27. RPJ asserted that his Board was doing everything that was reasonably practicable to achieve a significant shift in performance. There was a great deal of challenge to the executive to deliver improvement: it was not yet all being delivered but the Board were doing as much as they could. Some future work was still being planned but there was already plenty of activity under way.
28. We gave a number of examples where NR had set their own targets or plans and had now failed to deliver them. We also gave some detailed examples where our executive were not confident that the NR Board were fully in the picture.
29. We all agreed that we should continue to have a Board-to-Board dialogue through what was likely to be a challenging time. NR were due to respond to the draft determination at a meeting with the ORR Board on 3 September. Our executives were already discussing emerging areas of concern and the Boards should meet after 3 September when we might revisit CP4 performance.
**Item 7: Performance - Long distance and LSE**
30. We noted the paper on Network Rail performance in the Long Distance and LSE sectors and the recommendations from the executive team.
31. Following discussion and consideration of the evidence we agreed to the executive’s recommendation to find Network Rail in breach of their licence in respect of the failure to meet Public Performance Measures in 2012-13. Following discussion we agreed that we would not impose a financial penalty. We recognised that we need to ensure that the NR board are engaged and committed to holding the NR executive team to account on the delivery of improvements to performance and this is clear in our public handling on the issue.
32. We discussed the content of the decision letter. We agreed that it would be important to continue to discuss with the NR Board how they will improve performance. As part of this we agreed that it would be important to understand what additional funds and resources they will put in place to ensure that performance is improved by the end of 2013-14 and entering into CP5.
33. We delegated handling of this decision to the Chair and Chief Executive to manage. The Chair agreed to discuss with Richard Parry Jones once the decision letter was finalised. The Chief Executive agreed to discuss with David Higgins in parallel. We agreed that it was important for Richard Emmott to develop a short public statement on our decision.
**Board 23.07.2013 Action iv:** Decision letter to be prepared by Alan Price.
**Board 23.07.2013 Action v:** Handling of the points should be signed off by the Chair and Chief Executive. As part of this the Chair agreed to discuss with Richard Parry Jones in advance of a public announcement.
**Board 23.07.2013 Action vi:** Richard Emmott agreed to develop the appropriate press lines to take.
**Item 8: Access application**
34. Brian Kogan presented this item and asked the Board to consider the merits of an application submitted by West Coast Trains Ltd under section 22A of the Railways Act 1993 for track access rights to run two return services Monday to Saturday and one return service on Sunday between London Euston and each of Blackpool and Shrewsbury from December 2013 until the expiry of its track access contract in December 2022. Network Rail had not been prepared to agree the necessary access rights.
35. The decision had been escalated for a decision at Board level because it was likely to be controversial.
36. In considering the evidence and arguments of the parties the Board had regard to the statutory duties imposed on ORR primarily under section 4 of the Railways Act 1993 (as amended). The Board saw as particularly relevant to this application our duties to protect the interests of users of railway services, promote the use of the network for passengers and goods, promote competition for the benefit of rail users and promote improvements in railway service performance. Following discussion on the evidence and arguments, the Board agreed to reject the application based on the analysis both of existing poor performance and the lack of appropriate capacity on the West Coast Mainline. Whilst direct services to Blackpool and Shrewsbury would obviously be of benefit to the passengers making those journeys without having to change trains en route (as evidenced by the public support shown for these proposals), the Board believed the negative impact on greater numbers of existing users would outweigh that advantage because of the effect that these additional services would have on their punctuality and reliability.
37. The Board agreed however that it was important for the public announcement on this decision to make it clear that we understood why these services were wanted and would look at the issues again in the future. A letter communicating our decision and reasons for it would be sent by Brian Kogan to the applicant copied to Network Rail and DfT.
38. The Board noted that Network Rail anticipated that the timing of enhancements meant that no significant new services could be accommodated before a major timetable recast in December 2016. However Network Rail have recently indicated that they are investigating the scope for bringing forward work, together with associated timetable improvements perhaps as early as December 2014. ORR has also increased pressure on NR’s board to deliver improved performance before the end of CP4. The Board agreed that should more capacity become available (e.g. through the completion of enhancement improvements) and Network Rail showed the ability to deliver improved performance, we would be prepared to consider applications for the use of any newly available capacity.
39. The Board discussed the handling for public communications about our decision and agreed that the Chief Executive and Richard Emmott would prepare a public statement. The Board also agreed that it would be beneficial for the Chair to explain our decision to the Secretary of State who had publicly supported the application. Brian agreed to prepare a speaking note for this conversation.
**Board 23.07.2013 Action vii:** The Chief Executive and Richard Emmott agreed to prepare a public statement on our decision.
**Board 23.07.2013 Action viii:** The Chair would speak to the SoS and other DfT ministers to explain ORR’s decision. Brian Kogan would prepare a speaking note to assist this discussion. Board 23.07.2013 Action ix: The Chair would raise these issues with Richard Parry Jones to emphasise concerns about how NR plans to address capacity issues.”
Item 9: Real Time Train Information
40. We noted the paper which set out that we establish a multi-stakeholder task force involving the industry with an independent Chair to develop a solution to the problems of third party access in this market. The proposal was that we would ask the task force to write a report containing recommendations within four months. Paragraph 41 has been redacted as it relates to policy development
41. We discussed establishing a stakeholder task force would have the objective of presenting a report to us on a proposed solution to the problems with this market. We agreed that it was crucial to have an independent chair of the group. We agreed that Anna Walker would discuss potential candidates with Cathryn and Annette – any suggestions should be passed to Cathryn.
Item 10: Chair’s report
43. The Chair highlighted the following points from her report:
44. Colin Foxall (Chairman of Passenger Focus) had challenged us to use our influence more proactively to drive improvements in TOC behaviour, citing lack of information during disruption on the East Coast.
45. DfT had proposed that the new Highways regulator should be a public corporation and this left ORR as the only DfT regulator which would be a non-ministerial government department. We needed to consider whether this mattered to us. There was a great deal of discussion about economic regulators at the moment and we needed to be taking an active part in that.
46. The Board objectives for 2013/14 were included. Any final comments should be sent to the Board Secretary. A report on the first six months’ progress would be included with the October Chair’s report.
47. We noted the suggested Board dates for 2014. We agreed to review the dates and provide comments to the Board Secretary. We agreed to group the Board and committee meetings together in two days each month. Dates would be provided to Board members shortly.
Board 23.07.2013 Action x: Board members agreed to Board objectives. Any further comments to be provided by end of the week.
Board 23.07.2013 Action xi: Board members to provide availability on proposed 2014 Board dates.
Board 23.07.2013 Action xii: Board Secretariat to contact Board members with proposed Board Committee dates for 2014
Item 11: Chief Executives report
48. The Chief Executive highlighted the following points:
49. We continue to engage at all levels as the arrangements are put in place to establish the Competition and Markets Authority (CMA) and the new concurrency framework. We have seen and commented on drafts of the various supporting statutory instruments and guidance documents. There has been a first joint CEO’s meeting of the CMA and regulatory heads at which the CMA’s strategic principles for concurrency were discussed. The Head of Competition and Consumer policy is part of the joint drafting group for the new ‘UK Competition Network Strategy’.
50. We received an update on the recent rail incident in Bretigny, France. Sue confirmed that we had been in dialogue with French officials to understand the cause of the incident and to understand whether there are any lessons to learn.
51. We noted the work to look at the Board’s vision and how this can be more visible to staff. We agreed with the suggested actions to address this concern. Some work with staff will take place to understand the poor staff survey results. We agreed with the proposal for NEDs to attend staff briefing sessions in September to discuss the Board’s vision.
52. The upward trend of the Precursor Indicator Model (PIM) was noted. We agreed that the September CE’s report would provide Board members with an update.
53. Daniel Brown provided a brief update on the feedback received following the publication of the Long Term Regulatory Statement (LTRS). We agreed that it was particularly important the DfT took up the challenges set out for them. The follow up actions planned for the LTRS would be shared for comment with the Board.
Board 23.07.2013 Action xiii: The Board agreed that it should understand the follow up actions to the LTRS as this was potentially sensitive for ORR’s reputation. Dan agreed to circulate the plan to Board members for agreement.
Board 23.07.2013 Action xiv: The next CE’s report should highlight PIM trends and their significance.
Item 12: Board forward programme
54. The Board forward programme was noted. No comments were received.
Item 13: Approval of minutes of Board meeting held on 25 June 2013
55. The draft minutes of the meetings held on 25 June 2013 were noted and agreed.
Item 14: Matters arising not taken elsewhere on the agenda
56. The updates on the outstanding Board actions were noted.
Item 15: Any other business
57. No items were raised.
Item 16: Meeting review
58. We agreed that the meeting had been productive given the significant number of important issues on which decisions had had to be made.
59. We agreed that more time should have been allocated to the discussion on Network Rail’s annual efficiency assessment and the Board attached importance to seeing the follow up document prior to publication to ensure all issues had been covered.
Items for information
Item 17: Internal Health and Safety report 60. We noted the report. No comments were made.
**Item 18: Europe – update**
61. The paper was noted. The Chair confirmed that the paper will be discussed in detail at the September Board meeting.
Anna Walker\
Chair\
Minutes approved by the Board on 17 September 2013
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1711a693ff5d923953ca208b07293f94b09ce070 | Office of Rail Regulation
Minutes of the 97th Board meeting on 17 September 2013 (10:00 – 16:00), ORR offices, One Kemble Street, London – Room 1
Board present:
Non-executive directors: Anna Walker (Chair), Peter Bucks, Mark Fairbairn, Stephen Nelson, Ray O’Toole, and Steve Walker.
Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics)
In attendance, all items: Daniel Brown (Director of Strategy) Juliet Lazarus (Director, Legal Services), Richard Emmott (Director, External Affairs), Tess Sanford (Board Secretary), and Gary Taylor (Assistant Board Secretary).
In attendance, specific items: Geoff Horton (Interim Economist) item 4, Steve Armitage (Head of Competition Economics) item 4, Brian Kogan (Deputy Director, RME) items 4 and 5, Agnes Bonnet (Head of European Policy) item 5, Alan Bell (Head of Railway Safety Policy) item 5, Alasdair Frew (Head of Corporate Communications) item 6, Rachael Durrett (Corporate and Industry relations manager) item 6, Andrew Winston (Head of Media relations) item 6, Quinten Manby (Head of Internal Communications) item 6, Alastair Gilchrist (Director, Corporate Operations) item 7, David Chapman (Associate Director, HR) item 7.
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. Apologies for absence were received from Mike Lloyd and Tracey Barlow (non-executive directors).
Item 2: Declarations of interest
2. None.
Item 3: Monthly Safety Report
3. Ian Prosser told the Board that a freight derailment had taken place at Sellafield on 16 September. He confirmed that Inspection of the incident had taken place and a full report was currently being prepared. Ian would update the Board next month.
4. Ian Prosser presented an item on four major train accidents which took place overseas during July. For each incident we discussed the causes of the incidents and the follow up investigations and actions which have taken place. As part of this presentation, Ian highlighted any lessons for the UK to ensure that protection against similar incidents on our network is improved.
5. We noted that the incident in Canada had its roots in the de-regulation of the freight sector which ultimately led to less regulatory site inspection and poor practices. New legislation had already been implemented in Canada following the accident.
6. The Board noted that it did not have sight of the frequency of ORR’s site inspections. Ian confirmed that management information was available on the numbers of ORR proactive and reactive inspections. Ian agreed to consider how to present this to the Board going forward to improve board scrutiny and awareness. We agreed that the level of information received by the Board was one area that should be reviewed following the Board Safety training session on 3 December.
7. The incident in France which appeared to have resulted from a detached fishplate had similarities to a crash in the UK at Southall East in 2002. Ian said fishplates have been a historical issue which had been addressed since 2002 although a slight increase had been seen in the last three years. We agreed that an important lesson to learn is the need to ensure that adequate maintenance and mitigating controls are in place at sites where renewal has been deferred past the expected life of the asset. Switches and crossing are an important area of risk for the inspection programme and it was essential to ensure that NR maintain switches and crossings effectively.
[Paragraphs 8-9 have been redacted, along with the related Action point G to avoid potential prejudice to on-going inspection and enforcement activity.]
10. We noted Ian's report on the catastrophic derailment in Spain. The incident appeared at this stage to have been caused by over speeding and driver distraction. We noted that the number of deaths was extremely high for a single train derailment (as opposed to a head on collision) and that this raised questions about passenger survivability of the rolling stock. Ian highlighted that the Spanish rolling stock would not meet current UK standards but would have been licensed under Technical specification for interoperability (TSI). We noted that the European Railway Agency (ERA) have acknowledged our position and recognised the points raised.
11. We noted that there had been no early speed reduction systems in place compared to Britain where the Train Protection Warning System + (TPWS+) is in place. We agreed that any learning would be particularly relevant in the European rail traffic management system (ERTMS) transition period. We noted that the risks caused by not having effective systems had been discussed at SRC and that it would be important to explore those at our Board training session in December.
12. We noted that RENFE were exploring whether to expand their operations into Britain and that any evidence about their culpability in this case may be relevant to considering any future licensing applications from them.
13. We noted the incident in Switzerland. The authorities there had again acted to prevent a recurrence. Ian confirmed that a similar incident would be unlikely with our track and signalling layouts and the Driver Reminder Appliance, designed to prevent similar incidents.
14. Ian would provide an update to SRC on 21 October 2013.
15. Richard Emmott said he felt strongly that a rehearsal of communications in a catastrophic incident should take place across a number of organisations to take into account the learning from these incidents and ensure that these processes are current and effective. The immediacy of social media meant that an entrenched view of the cause of any accident could be adopted by the public before inspectors were even on site. Significant work might then be needed to over-write that perception with an evidence based understanding.
16. We agreed that this was important to follow up and the exercise needed to involve all those who might become involved in a real case. The Chief Executive agreed to write to NR to ensure that this consideration of handling issues happens.
17. As part of his monthly update to the Board Ian noted the improvement notice served on NR after they had switched off level crossing obstacle detector safety equipment on the Ely-Norwich line without performing an appropriate risk assessment. Indications were that NR had agreed to turn the equipment back on and the notice would therefore be withdrawn.
18. We had asked for a detailed discussion of the trends in the Precursor Indicator Model (PIM). Ian noted that a 5% improvement in the PIM since March 2013 had wiped out the 2012 risk increases. He said that RSSB would be making changes to the PIM to help NR baseline the end of CP4 against which CP5 would be measured. Ian noted that a focus of work on stretcher bars had resulted in fewer incidents with these. He said that rolling contact fatigue was now becoming an issue. These incidents required whole sections of track to be replaced.
19. We thanked Ian for a thorough and comprehensive report.
Board 17.09.2013 Action A: Ian Prosser to provide update on the freight train derailment on the Sellafield line at the October Board meeting. Board 17.09.2013 Action B: Ian to ensure a new metric on pro-active and reactive inspections should be added to regular Board reports to increase visibility of this at the Board. Board 17.09.2013 Action C: Ian to add Board report content to the SRC agenda following the safety training in December. Board 17.09.2013 Action D: Ian to provide the Board with the findings of the ORR audits taking place on NRs maintenance delivery units. Board 17.09.2013 Action E: We agreed that the safety item on the November agenda would be extended for Ian to provide further updates on these points. (change to the forward programme) – Tess to put on forward plan. Board 17.09.2013 Action F: RP to write to NR to suggest a crisis communications exercise. [Redacted action point G]
Item 4: Open Access consultation
20. Cathryn Ross and Geoff Horton presented this item which set out the responses received as a result of the Open Access consultation exercise which opened in June 2013. The paper also set out a number of options for potential change to the current Open Access policy.
21. We considered the consultation responses and the follow up discussions with stakeholders which had focused on three options for taking forward our Open Access policy. The three proposed options were:
- Option 1, maintain the existing policy
- Option 2, where the mark-up is based on the level of abstraction.
- Option 3, where the mark-up is calculated on the basis of costs.
22. We discussed these options and the consultation responses. In conclusion we agreed with the Executive’s recommendation to maintain the current policy for the time being and to not introduce additional mark ups at this time but to include them in our forthcoming review of charges when a proper review could be undertaken. We agreed that we should aim to address those areas that will make a difference in the longer term for CP6 - such as reviewing the structure of charges and the structure and effectiveness of the not primarily abstractive (NPA) test.
23. We noted the significant links to other important areas including the capacity charge, and the European move towards an economic equilibrium test, which was likely to raise additional hurdles to open access operators. We thought we had successfully intervened on the economic equilibrium test (see below). We discussed the overall competition landscape and agreed that we should consider a full review of the variety of competition issues arising from Europe and franchising, open access and charging to ensure that we understand how the various tensions worked together. We acknowledged that open access was an imperfect response to the very difficult question of how to encourage on-rail competition but it was the best solution we had at this time.
24. We agreed that this work would be discussed as part of the development of the 2014-15 business plan. We noted that the charges review should not be delayed by including these aspects.
25. Brian Kogan provided an update on the Alliance open access application. Brian confirmed that a decision would be sought from the Board in November.
**Board 17.09.2013 Action H:** Agreed that an internal strategic review of our approach to competition should take place and be picked up as part of the business planning round for 2014-15.
**Board 17.09.2013 Action I:** discussion on the application from Alliance will take place at the November Board (change to forward programme).
**Item 5: Europe update on objectives**
26. Brian Kogan and Agnès Bonnet provided an overview of the progress made to date on delivering against our strategic objectives for European activity – as agreed by the Board in May 2013. We reiterated how important it was to have objectives for our work in Europe and assess progress against these regularly.
27. Agnès highlighted the following:
28. Consideration of the initial proposals for the Fourth Railway package had been a significant piece of work. We noted that that ORR had been successful in influencing the debate on the technical pillar (interoperability) of this work and our compromise proposal for the award of technical authorisations has been adopted by member states in the European Council. We still had concerns on what was proposed for safety authorisation (a choice of NRG or ERA) and would need to continue to work with the DfT and the Commission on this.
29. We discussed the economic equilibrium test. Brian Kogan confirmed that significant progress had been made in explaining our concerns in this area and we have influenced the thinking of the European Commission significantly. Agnès confirmed that our approach to the economic equilibrium test was consistent with our approach to Open Access.
30. We discussed the Channel Tunnel. Alan Bell confirmed that much had been achieved to remove unnecessary safety rules. Brian confirmed that once the recast is implemented the economic regulation of the tunnel will be carried out by ORR and the French Regulatory body. Brian confirmed that this was a significant issue which should be discussed by the Board in due course.
31. We discussed whether we should be encouraging DfT to take a more active role in Europe. We asked the executive to share our views with DfT officials.
**Board 17.09.2013 Action J:** Paper on the joint economic regulation of Channel Tunnel to be prepared and scheduled on the Board forward programme.
**Board 17.09.2013 Action K:** Agreed that the executive should meet the DfT to discuss the European agenda. Item 6: ORR’s communications plan
32. Richard Emmott highlighted the progress made in implementing the communications strategy which was agreed at the Board in February 2013.
33. Richard highlighted the following significant pieces of work which had taken place:
- media coverage for the draft determination was highly focussed in terms of message delivery and extensive in quantity
- each successive edition of Monitor has increased impact – enhancing ORR’s reputation for holding NR to account for performance.
- team now fully resourced with high quality hires in media relations and stakeholder/parliamentary functions
- evaluation tools now in place to measure our effectiveness and show the organisation how it is perceived.
- Closer relationships have been developed across the office to improve proactive communications work
- started to use social media routinely as part of our delivery. twitter account drives traffic towards news announcements and reports
34. Richard highlighted that there were a number of significant challenges facing External Affairs over the next six months. These include the publication of the Final Determination and the scene setting for CP5. The re-launch of the Transparency programme would also be a significant piece of work.
[Paragraphs 35-37 and related action have been redacted as relating to sensitive stakeholder relationships.]
Item 7: Performance and Reward
[This item to be redacted as the content of the proposed new scheme is subject to negotiation with staff and OTUS.]
Item 8: Board Committee feedback
Audit Committee
46. Mark Fairbairn highlighted the following significant items discussed at the Audit Committee on 16 September:
- The committee received a presentation on the use of “bow tie” analysis to assess the industry risk landscape.
- Cathryn Ross and John Larkinson attended the meeting to discuss the risks associated to the PR13 project with a focus on the actions currently in place to mitigate significant risks.
- The National Audit Office presented their audit strategy and key dates for the year ahead.
- The committee noted the work undertaken to prepare an assurance map of third party information published by ORR.
47. We noted that the Audit Committee had approved the proposal to jointly procure Internal Audit services with other regulators whose internal audit contracts also expire on 31 March 2014. The aim of this approach would be to reduce our costs while securing an effective internal audit service. Due to timing requirements, it was proposed that final approval be delegated to the Chief Executive. This would be conditional on a note being provided to the Board at its January meeting with the list of those providers shortlisted, in order that the Board has the opportunity to comment. We agreed with this recommendation.
**Board 17.09.2013 Action P:** Board Secretary to update delegations list to permit the Chief Executive to approve the final appointment of an internal audit service after the January Board consideration of the shortlist.
**Nominations Committee**
48. The Chair highlighted that the inaugural Nominations committee meeting took place on 3 September. The discussion focused on the upcoming recruitment exercise to replace departing Non-Executive Directors and the skills and experiences required to fill subsequent capability gaps.
**Item 9: Chair’s report**
49. The Chair highlighted the following points from the report:
50. Useful discussions had taken place with Nicola Shaw (HS1) on the franchising function at the DfT and the current review at the DfT. HS1 issues were also discussed – in particular concerns around ongoing work in Europe which could be considered to be a significant risk to markets both in the UK and in the EU.
51. The meeting with Hitachi had proved extremely interesting where technology developed for on train communications would help maximise capacity on the network. The Chair had been invited to an onsite demonstration of the technology and welcomed any Board members to accompany her on this visit.
**Board 17.09.2013 Action P:** Secretariat to invite Board members when the visit to Hitachi has been arranged.
**Item 10: Chief Executive’s overview**
*This item (para 52-55) has been redacted as containing sensitive information about our stakeholder relationships*
**Item 11: Board forward programme**
56. The Board forward programme was noted. The Board Secretary said that a definitive list of confirmed Board and Board committee dates for 2014 will be circulated to Board members.
**Board 17.09.2013 Action R:** Confirmed dates for 2014 to be circulated to Board members
**Item 12: Approval of Board minutes from 22 and 23 July 2013**
57. We noted and agreed the minutes from the meetings on 22 and 23 July subject to two amendments suggested by Ian Prosser and the Chief Executive. The Board Secretary agreed to amend accordingly.
58. Following discussion the Board Secretary agreed to highlight areas for redaction in the draft Board minutes.
59. We noted the continuing absence of published minutes on our website and asked the Board Secretary to expedite work to bring these up to date.
**Board 17.09.2013 Action S:** Board Secretary to amend July Board minutes accordingly Board 17.09.2013 Action T: Draft Board minutes to include suggested redactions for Board members to note Board 17.09.2013 Action S: Board Secretary to expedite work to bring website up to date with published minutes
Item 13: Matters arising 60. The actions from the previous meeting were noted. We agreed that the revised format was useful and would ensure better tracking of actions in the future.
Item 14: Any Other business 61. No items were raised.
Item 15: Meeting Review 62. It was noted that the papers had been well written, clear and concise and prompted thorough discussions. 63. We agreed that having fewer items on the Board agenda helped to ensure that we had thorough discussions at the appropriate level which did not feel rushed or cut short.
Anna Walker Chair Minutes approved by the Board on 22 October 2013
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f93eca4db86d9dfa7cdb911b41307b85bbabea70 | Office of Rail Regulation Minutes of the 98th Board meeting on 1 October 2013 (09:00 – 17:00), ORR offices, One Kemble Street, London – Room 1
Present: Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, Ray O’Toole, and Steve Walker. Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), and Cathryn Ross (Director of Railway Markets and Economics) In attendance, all items: Daniel Brown (Director of Strategy) Juliet Lazarus (Director, Legal Services), Alasdair Frew (Head of Corporate Communications), Tess Sanford (Board Secretary), and Richard Gusanie (PR13 Project Manager). Carl Hetherington, John Larkinson, Sue Johnston In attendance, part: Geoff Horton (Interim Economist)
Abbreviations: Network Rail (NR), Final determination (FD) draft determination (DD) Strategic Business Plan (SBP)
[References to individual slides from the papers are given as Sxx for the main pack and SSxx for the supplementary pack. All single slides referenced in the minutes are included in an annex which begins on page 15. These slides do not stand alone and so will not be published]
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. There were no absences.
Item 2: Declarations of interest 2. None.
Item 3: PR13 Final Determination
Introduction 3. John Larkinson introduced the meeting where he hoped the Board would feel ready to make decisions on the final determination. The slide pack which had been circulated would be familiar: it was based on that used on 16 September at the Periodic Review Committee (PRC) to debate points of policy. There were minor discrepancies in the pack because of the time lag between different iterations of the models. These were not material. The detailed figures, which would be generated by a final run of model, would be updated for the final determination document. If any material differences emerged in the final model run the team would raise these with the Board.
Summary of proposed approach 4. A draft of the executive summary would be circulated to all NEDs for comment on or about 10 October and comments would be very welcome. There was a conference call that NEDs could join if they wished on 16 October and that was the final deadline for comment on the executive summary.
05. John would present the various decisions at today’s meeting. Almost all the recommendations were based on the collective view of the executive team. One issue remained (level crossings) where the executive had not had time to reach a view because discussions had been going on with NR. This would be addressed in the meeting.
06. Since the PRC meeting on 16 September, further discussions had taken place on the issues around Schedules 4 and 8 and he understood that most questions about the implications of the changes proposed had now been answered.
07. John reminded the Board of the decision making framework that we were under and our statutory duties. He drew our attention to the factual slides about routes and time limits for legal challenge. The executive believed they had undertaken a robust process which mitigated the risk of successful challenge as far as they could.
08. John said that all the representations made to ORR following the publication of the draft determination had been considered. Where new or additional evidence was offered this had been assessed. Many of the representations made by NR were effectively assertions which had not been supported by credible evidence. It was important for ORR’s credibility that we were able to communicate clearly why changes had been made – or not made.
09. There were some changes proposed between the draft and final determinations. These were largely the result of adjustments either on the basis of new evidence or of a better understanding of NR’s likely exit position on CP4 performance and its likely debt level.
10. John reminded us that NR had objected to the level of scrutiny that we were seeking in respect of asset management, but that the rest of the industry had positively supported our approach. We felt that the information we were seeking was a subset of the management information that Network Rail should be collecting anyway.
11. John said that it was important that NR were clear that our long term intent continued to be towards more risk based regulation. We would reduce the level of scrutiny if Network Rail demonstrated that it was effectively managing its risks and assets.
12. NR had also asked for clarification on our approach to ‘spend to save’. We were relaxing constraints on this to support a more commercial attitude, which would help send a balanced message.
13. We agreed that some of the key messages about the final determination would be around the evidence base for the changes between it and the draft.
14. John updated us on progress on discussions about financial monitoring of NR in CP5. It was clear that this could not be resolved before publication of the final determination and discussions were ongoing. Relevant wording would be agreed between ORR and NR for inclusion in the final determination. [The discussion of each segment of the determination ranged widely and can be described as information which relates to the formulation of policy. Given the detail included in the final determination, we have redacted paragraphs 15-91 from the published minute as relating to policy development.]
Expenditure and revenue requirements (affordability)- paras 15-19
**Outputs:**
- PPM – paras 20-27
- Network availability – para 28-32
- Northern Hub/non-HLOS enhancements – para 33-36
- Journey times – para 37
- Performance: HLOS target – para 38
- Climate change and extreme weather resilience para 39-41
**Efficient expenditure – para 42**
- Track and signalling renewals – para 43-45
- Information management – para 46-47
- Level Crossings – para 48-51
- Cross cutting efficiency: occupational health – para 52
- Cross cutting efficiency: Management of inflation – para 53
- Innovation match funding cap- para 54-56
- Property income – para 57-58
- Financing costs and financial framework – para 59-60
- Use of outperformance – para 61
- Financial framework – para 62
- True-up mechanism – para 63
- Cost of capital – para 64
- Network grant – para 65-66
- Sustainability adjustment – para 67
- REBS (Route-level efficiency benefit sharing mechanism) – para 68
- Capacity Charging – para 69-75
- Financial monitoring – para 76
- Decisions on areas where we have not made changes.- paras 77-78 Overview
92. John Larkinson drew our attention to the two slides (141, 142) summarising changes to ‘impacts on’ compared to the DD, the latest affordability position on slide 136 and the projection of long term sustainability on slide 193.
93. We agreed to discuss the success criteria for CP5 at a later meeting before CP5 started so that criteria could be published before April 2014. [Action]
94. We noted that NR had identified five major areas of the DD where they had sought changes. Small adjustments were proposed in each area which were based on new evidence that had been submitted.
95. We noted that the final question for us was about deliverability – did we think that NR could deliver under this package? We also wanted to review whether there were any areas where we could more actively support them in delivering.
96. The Chair asked board members to comment on the overall package and to say whether they agreed with it overall. The comments included:
a. We had responded positively on NR’s requests for more on track renewals and level crossings, but only given 10% of what they had asked for on support, operations, maintenance and renewals. There was a risk that they would continue to meet PPM and underperform on volumes.
b. NR’s major concerns had been addressed. They had set themselves challenging targets on track renewals but understood the importance of getting it right.
c. We should remember that station improvements were important to passengers.
d. The passenger experience would be mixed in CP5 – disruption followed by improvement when enhancements were completed; mechanisms were in place to involve passengers in relevant decisions and overall it would result in a better experience.
e. Our process was soundly based on evidence and we had responded to new evidence and representations appropriately.
f. There was a good level of challenge in the package overall but there was a risk that NR would underperform. This package included mechanisms for NR to address any issues. We needed to find a way to help NR tackle the challenges positively and own the solutions. g. It was important that NR believed that the package was deliverable as that confidence would support delivery. We had concerns about NR’s internal motivation and it was suggested that if Year 1 was not delivered then performance was unlikely to be recovered during the remainder of CP5.
h. There remained an issue around the change in leadership at NR and particularly the quality of route leadership. This was a programme which required considerable cultural change and NR’s history in that area was not encouraging. The new leadership would be essential in driving this through and we should support this where possible.
i. We noted the need to work with the new leadership and to support development of route level leadership at NR so that they could work better with industry colleagues. We needed to make sure that the way that we regulate is transparent and seen to be supporting delivery.
j. There was no evidence that more money would drive better performance from NR.
k. We needed to learn from CP4 where we had spent too long before intervening on performance and we must move quickly to identify mechanisms for that before CP5 starts.
l. How ORR regulates during CP5 will influence the way that NR performs. In principle we supported the motivational model but NR had to show its willingness and determination to deliver.
m. There was not much slack in any part of the settlement and that meant that there was a reasonably high level of risk around delivery. It was vital that we made sure that safety was maintained and improved through the control period.
n. The interaction of the various elements had been explored, was understood and needed to be explained clearly in the FD.
97. Overall, we felt confident that the package was balanced, achievable and defensible.
Handling strategy
98. We noted that the handling strategy would build on that used for the draft determination in May with key changes being identified and explained. One essential part of the story would be any differences in how ORR would be monitoring or regulating differently between CP4 and CP5.
Success criteria
099. We noted the slides setting out suggested success criteria for PR13 (slides 144-149) and that these would be discussed again before CP5 began (Action). Next steps
100. It was noted that there would be a final run of the financial model to generate the numbers for the final determination. Only if something anomalous or unexpected emerges would staff bring issues back to the Board.
101. The draft executive summary would be circulated to all board members for comment on or around 10 October, with comments welcomed ahead of the NEDs phone call to discuss the summary on 16 October. After that call, the text would be finalised for the Chair/Chief Executive to sign off.
102. The Board would discuss the handling strategy at their meeting in October.
103. The Board would consider a scoping proposal for an evaluation exercise of the PR13 process in the new year (add to forward programme).
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4a5173c14d3a90c3cbbc76e694cb4c24a6377968 | Office of Rail Regulation Minutes of the 99th Board meeting on 22 October 2013 (09:00 – 14:00), ORR offices, One Kemble Street, London – Room 1
Present: Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Mike Lloyd, Stephen Nelson, and Steve Walker. Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance), In attendance, all items: Dan Brown (Director of Strategy) Juliet Lazarus (Director, Legal Services), Richard Emmott (Director of Communications) Tess Sanford (Board Secretary), Cathryn Ross (former Director of Railway Markets and Economics), Gary Taylor (Assistant Board Secretary) In attendance, specific items: John Larkinson (acting Director of Railway Markets and Economics), Carl Hetherington (Deputy Director, RME), Alasdair Frew (Head of Corporate Communications), David Keay (Head of Inspection, Railway Operators) Abbreviations: Network Rail (NR) Final determination (FD) draft determination (DD) Strategic Business Plan (SBP)
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting and noted that Ray O’Toole had sent apologies.
Item 2: Declarations of interest 2. None.
Item 3: Monthly safety report 3. Ian Prosser noted that the precursor indicator model (PIM) was now being produced each month and continued to show improvement after the temporary rise associated with earthwork failures during last year. Moving train risk was also down.
04. We discussed a number of aspects of worker safety. The introduction of close call reporting was starting to change attitudes – but very slowly. We discussed red zone working and noted that though it was desirable to eliminate the practice, it was currently impracticable. We noted that we had ‘rolled over’ the 7 day working funds to support the reduction of red zone working. IP reported that NR were changing the way safety was managed for teams on the railways with changes to the Controller of Site Safety (COSS) and Sentinel systems amounting to a ‘permit to work’, aimed at improving the safety and management of workers on the railway. IP said that these measures would take time to embed and to deliver improvements but should deliver significant advances and NR were being given time to implement these changes.
05. We discussed the relative importance of PIM and level crossing risk models and whether these could inform the way RSD resources should be targeted to maximise benefit. Ian Prosser said that one reason the PIM had not improved as quickly as hoped was because that it reflected increasing misuse of level crossings by users. Network Rail were targeting improvements at crossings with high levels of misuse along with foot crossings which could be replaced by footbridges.
06. We noted the review of our recommendation handling processes commissioned by the Chief Executive from Melvyn Neate (independent Audit & Risk Committee member) which was covered in the CE’s report. This review would cover a) how effectively ORR deals with RAIB recommendations generally and b) determine whether the criticisms by RAIB of ORR as a result of the Stafford SPAD incident had already been addressed by recent process enhancements or whether further improvement was needed. It was suggested that the terms of reference for Melvyn Neate’s work should include a review of how ORR ensured NR was acting on agreed recommendations.
07. We noted that Carolyn Griffiths (the Chief Inspector, RAIB) had twice expressed concerns to our Chair about some aspects of ORR’s response to RAIB recommendations and included criticism of ORR and the industry in her annual report. This was therefore an important piece of work to help the Board unpick those concerns and look at the underlying evidence.
08. We agreed that RAIB was a very important stakeholder for ORR and had a different, complementary role to ours. The chain of organisations in the UK responsible for rail safety (RSSB, ORR and RAIB) need to have strong mutual respect and good working partnerships to deliver a joined up and coherent approach that was credible across the industry. If those partnerships were not functioning well, ORR should first consider whether it had done all it could to improve them. It was important that all the bodies presented sufficient appropriate challenge to each other to avoid complacency and that any such challenge was based on robust evidence.
09. We noted that the Regulations under which RAIB operated had first been introduced ten years ago and might benefit from a review which brought them up to date with other developments in safety regulation. This would be a matter for the DfT as RAIB reported to the Secretary of State.
10. Melvyn Neate’s report would be considered at the Audit and Risk Committee in December and reported to the Board in January. (Action: update forward programme)
11. Ian Prosser briefly reported that:
- Two letters had been sent to NR asking 1) to see their internal review of 2B2C and 2) to understand their plans for managing safely the 15% reductions announced recently in managers’ posts.
- Two recent freight derailments (Gloucester and Camden Road) seemed likely to be related to poor track maintenance. Ian had asked his team to consider whether there was sufficient emerging evidence to suggest a national enforcement notice should be issued.
- The efficiency saving imposed on NR on maintenance in the final determination of 16.4% across the control period was still felt by the executive to be the correct judgment given the trajectory proposed. We expected the projected savings to be generated by the move from a find-and-fix approach to a planned maintenance schedule.
- The Law Commission’s report on level crossings had been published and offered a welcome opportunity to achieve a step change in risk.
- A prohibition notice had been issued on the Wells & Walsingham Railway preventing it from operating as it had no effective safety management regime. (Action: NEDs to receive prohibition notices when issued, noting that they are not public until 28 days after issue.)
12. We noted that the November report would include a discussion of the issue of zero hour contracts in the industry which had been raised as a safety issue by the unions. We agreed that the detail of employment contracts would only be a matter for ORR if they prevented the competence or capability of staff responsible for safety from being properly managed.
13. We asked that the safety report should in future be separated from the Chief Executive’s report within the board papers. (Action)
**Item 4: Communications plan for the Final Determination**
14. Richard Emmott introduced the paper which built on the successful process for the draft determination, and set out the key messages for the final determination and a plan for delivering them to key audiences.
15. Key elements of the plan included strong messages that
- ORR had responded to passenger concerns and priorities,
- the overall package reduces the financial pressure on the taxpayer and passenger;
- a ‘predict and prevent’ approach to maintenance is better value than find and fix,
- safety underpins every regulatory decision;
- the overall package is deliverable,
- NR can and must improve its performance.
16. We had noted that NR used the executive summary of the DD as a key internal communications tool and this would be borne in mind over the final few days of drafting.
17. We expected NR to assert that they were doing everything reasonably possible to improve performance, that extreme weather had not been taken into account, that the real story was reactionary (secondary) delays. We should be careful to allow credit where it was justified and robust where we could demonstrate otherwise.
18. **Action:** the Board asked to see the final version of the press release with an accompanying script. Item 5 PR13 Remaining Policy issues
19. John Larkinson said that a great deal of work was going on to finish the Final Determination text. There had been a flurry of new representations and three of these were being brought to the Board today.
_The discussion of the detail of the determination contains information that relates to the formulation of policy. Given the detail included in the final determination, we will redact paragraphs 20-31 from the published minute as relating to policy development._
CP5 measures of success
32. These were still to be developed and agreed but were unlikely to be included in the text of the final determination. They needed to be in place before the beginning of CP5. (Action: add to the forward programme for early 2014)
Item 6 – Developments in wider government policy affecting ORR
33. Dan Brown introduced the item which followed on from the discussion at the Board evening session on 21 September. He described how the current political agenda had changed to focus on the cost of living, the cost of regulated services and infrastructure investment. There was a great deal of discussion and thinking going on in government around transport, railways and regulation – we should actively contribute where relevant but we should not be distracted from performing our core functions diligently and well.
_The rest of this item (paras 34-42) has been redacted as it relates to the development of policy._
Item 7 Business plan Q2 update
43. Richard Price introduced the paper, setting out headlines under the five strategic objectives. Ian Prosser clarified a point around the level crossing guidance which must be implemented by NR, not by ORR. Cathryn Ross said that while good progress had been made on consumers, she thought she had been over-ambitious in setting the business plan and the unanticipated changes in the competition regime had displaced some of her resources. Richard noted that VfM was in a good place overall, although CP4 exit was likely to be disappointing. On sector development, the team was reviewing the LTRS engagement plan to ensure that we did not lose momentum. On our journey to becoming a high-performing regulator we were making progress and any delays were likely to be recoverable.
44. We noted the high number of vacancies and Richard explained that these were being carefully managed and would provide sufficient headroom for the management changes planned over the rest of this year. The budget would be tight for next year.
45. We asked whether we should be concerned about the apparent rise in RME sickness rates and were reassured that this was caused by a single long term sickness. It was not a reflection of the pressure that the team were under on PR13 although individuals were under considerable short term pressure.
46. We queried the high number of deliverables that had been reforecast and asked how the risk report reflected these changes. We said that it was important that proper programme discipline was followed on the business plan and that we wanted to see better evidence of it in the next report.
47. Richard told us that he was receiving regular assurance from the directors that most of the slippage was recoverable in year and that it was largely caused by overspill from PR13. We were still in the first year of this business management system and the team had learned a lot about which milestones should be set and reported which would be applied next year.
48. We asked that the reports be reviewed and should in future include: an indicator of how long a milestone would take to be recovered, some reiteration of the business plan, highlights of issues for the board, comments on divergence from critical paths and key issues.
**Item 8 Organisational Development quarterly update**
49. Alastair Gilchrist introduced the report. There was one red flagged item – on performance management, where there had been a delay in agreeing new arrangements and there was continuing difference of views between the Executive and the Remuneration committee which was being worked through.
50. We agreed we would not expect it to be possible for the programme to have an overall green status while the underlying report included a red flag. We noted the link between delay to the policy development programme and the underlying risk to ORR capability. Dan Brown explained that the programme was largely additional to people’s individual targets and therefore proceeding only slowly.
51. We noted that while improvements were visible in many places in the organisation, these were not adding up to the step change from where we are to where we need to be. We looked forward to seeing the results of the staff survey and the programme report would come back to the Board again in February 2014.
**Item 9 Feedback from Committees**
*Remuneration: Stephen Nelson*
52. Stephen Nelson reported on the previous day’s meeting. David Chapman had presented some good and comprehensive work on pay and performance management for non-SCS staff. The process this year would be much the same as in previous years with a guide distribution between the four categories although the Committee was not recommending a forced distribution. Implementation of the process would be improved with RP having oversight of the whole and no announcement of individual ratings until moderation was complete. Acting on feedback from HMT there was a proposal that the size of individual awards should be reduced and the Committee had noted this. Stephen said that he had asked to see the comparable awards made by other CS and non CS bodies (Action to be captured for Remco).
53. The Executive had also sounded out the committee on the use of the 1% increase in the consolidated pot. Their preferred option, given the smallness of the amount in question and the rate of inflation, was to give all staff achieving a ‘good’ rating a 1% increase. The Committee had discussed and endorsed this approach.
54. The Board was minded to agree to this and the Board Secretary would circulate the proposal in writing for formal agreement.
55. Stephen said that in the mid term some structural inequalities had been imposed by the pay freeze and they would need to be addressed soon. ORR needed to be liberated from the current pay constraint and we should explore ways to do so.
56. The Remco minutes would capture the confidential issues which formed part of Stephen’s report.
Safety Regulation Committee: Steve Walker
57. Steve reported to colleagues that the agenda had generated useful discussion on the Channel Tunnel, followed by one on interoperability and its relationship to safety strategy. They had received assurance on the four (now five) international incidents reported at the last meeting and how learning from them was being applied in the UK. The Committee had been reassured that ORR and NR were taking these lessons very seriously.
Rail Industry Health and Safety Advisory Committee: Mike Lloyd
58. The meeting had received an interesting presentation on the platform interface from Passenger Focus and LUL. Engagement from the various representatives was mixed but it was a useful forum and the only formal interface with the Unions, who responded positively to the opportunity. We noted that ATOC still refused to allow individual TOCs to attend but continued to engage themselves only half-heartedly. It would continue to be chaired by an ORR NED after Mike left (in the interim Tracey Barker has agreed to Chair).
59. (Action: Secretariat to ensure that approved minutes of committee meetings are included in the Board papers as below the line items).
Item 10 Chair’s report
60. The report included a six month update against the Board objectives. There was a great deal of senior recruitment underway, including NEDs, the RME director and the director of regulatory economics.
61. John Larkinson reported that the task of appointing a chair to the RTTI task force was proving challenging and a field of candidates was being considered.
62. The Chair reported on three successful sessions with managers which had produced three different sets of messages for the Board. This had been a very useful exercise and should be repeated in the new year. (Action: EA to plan additional sessions.) Item 11: Board Forward programme
63. We noted the forward programme.
Item 12: Minutes of the Board meeting on 17 September 2013
64. We noted the minutes.
65. The Board Secretary reported that some minutes had been posted on the website and the remainder of the outstanding minutes would shortly be up posted (ie excluding the September minutes).
Item 13: Any other business
Resignation
66. Steve Walker said that he was resigning from the end of 2013. He had found that his time was increasingly pressed and he was unable to remain on the Board. He said he thought ORR was fortunate generally in the quality of its staff but he had necessarily spent most of his time with RSD staff and he was very comfortable that rail safety was in good hands.
67. The Chair thanked Steve for his important contribution, particularly as chair of SRC. She thought the RSD staff in particular would be very sorry to see him go.
Departures
68. The Chair noted that this would be Mike Lloyd and Cathryn Ross’s last Board meetings and wanted to record the warm thanks from the whole Board for their significant contribution.
69. Mike said that ORR was full of very loyal and capable people and he had great admiration for the organisation. He had learned a great deal and was sorry to be leaving.
70. Cathryn said that the rail industry carried a higher degree of complexity than any other she had encountered. She said it was important to make sure that we got the best contribution from our staff and from the Board members.
Anna Walker
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f5b7da1809a941c93b06c6dcb17a264eaf09dd64 | Office of Rail Regulation Minutes of the 100th Board meeting on 26 November 2013 (09:30 – 15:00), ORR offices, One Kemble Street, London – Room 1
Present: Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks, Mark Fairbairn, Stephen Nelson, Ray O’Toole and Steve Walker. Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety), Alan Price (Director, Railway Planning and Performance) In attendance, all items: Dan Brown (Director of Strategy) John Larkinson (acting Director of Railway Markets and Economics), Juliet Lazarus (Director, Legal Services), Richard Emmott (Director of Communications), Tess Sanford (Board Secretary), Gary Taylor (Assistant Board Secretary) In attendance, specific items: Item 5: Carl Hetherington (Deputy Director, RME), Item 3: Sue Johnson (Deputy Director Railway Safety), Item 8 and 9: Brian Kogan, Rob Plaskitt, Ian Williams, Paul Hadley, Item 6: Annette Egginton, Chris Simms.
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting. There were no apologies.
Item 2: Declarations of interest 2. None.
Item 3: Monthly safety report 3. Ian Prosser told the Board that at the half year point, good focus on the passenger/train interface by Network Rail (NR) had contributed to a 7% reduction in the safety risk across the system – greater than the HLOS target.
04. Two general enforcement notices had been issued on vegetation control and repeat track twist faults. NR had undertaken to deliver new guidelines on vegetation management which had not been delivered. Some routes were managing vegetation well, but some were not doing preventive clearing and only reacting to specific incidents. Inspectors were alert to this issue and a programme of cab rides was being undertaken to gather more information.
05. ORR had written in October asking to see the safety validation process which NR would apply during the 15% management cuts that had been announced. No reply had been received.
06. ORR’s interventions on safety issues must meet the legal requirement to demonstrate actual risk and the team now felt that enough evidence had been gathered to identify actual risk on the handling of track twist faults across the system.
07. Sue Johnson explained that the current programme of inspections of delivery units was yielding evidence that supported the team’s previously reported concerns about the long term deterioration of assets as a result of NR's poor maintenance regime and, significantly, the associated gradual increase of the safety risk.
08. Our inspectors generally reported that the local staff were competent and that there were good systems in place to deliver the necessary work. But they also reported that the maintenance depots were saying that there was no funding to deliver the necessary proactive work.
09. Twist track faults are known to increase the risk of derailment and latest information is that 30% of the twist track faults which NR are fixing are repeats. These faults were often being fixed manually and then fixed again a few weeks later. Although concrete evidence was not presented, it was asserted by our Director of Railway Safety that many were on track where renewal had been deferred.
10. ORR had issued an improvement notice requiring NR to identify why repeat faults were happening and to develop a plan to address them. That plan needed to cover resources, access and delivery.
11. The Board welcomed the steps taken to address this specific issue and noted that it was one aspect of a wider set of problems. We noted the mismatch between what we understood was the state of NR's funding and the messages that the delivery units were giving our inspectors about being starved of necessary cash. We had been told by the executive previously that there was an underspend in maintenance and renewals in the order of £1.2billion.
12. We discussed the possible underlying causes of the shortfall in maintenance work, including the question of whether there was appropriate local or organisation-wide capability in NR to deliver the necessary programme of maintenance and renewals that has been funded. The anecdotal evidence pointed to an organisation unable to plan possessions, relevant equipment and people to deliver maintenance effectively.
13. We noted that the executive had given us a comprehensive picture, backed by evidence and built up over time, of the way that NR's underspend on maintenance and renewals had impacted on its performance. This had been articulated very clearly previously by one of our executive members. We agreed that we recognised how that growing backlog of maintenance threatened to impact on safety. We had been told that some of NR's directors asserted that there was no money to do the work, but we had also been told that the work had been funded but not done. What we had been told about resource availability within the company led us to conclude that hard internal constraints had been applied which meant that the funds were not being used for the purpose for which they had been made available. We could see no operational justification for this.
14. We agreed that we must act to address these issues directly with Network Rail's Board. We needed to share our perspective, demonstrate how we had reached it, and make our concerns very clear.
15. We needed NR to account for the unspent sums which had been intended to fund maintenance and renewals and to take urgent steps to address the growing safety risk. It was their responsibility to make sure that sufficient resources to do the necessary work were made available – or to make serious representations if there was not sufficient resource.
16. We agreed that this should be a staged process. Our Chair and Chief Executive would speak directly to their NR counterparts as soon as possible after the meeting to explain the depth of the Board’s concerns and the overall issues which we felt needed to be escalated.
17. The Chief Executive and Director of Planning and Performance would urgently seek time with the NR Board. At that meeting, they should present the same information that the ORR Board had seen on performance, maintenance backlogs and safety. They should explain the analysis and conclusions that we had reached.
18. The Secretariat would arrange a meeting between the two Boards at which we should make our concerns and expectations about their responsibilities very clear. This needed to be as soon as possible.
Board 26.11.2013 Action i: Meetings with NR to be set up (R Price).
Board 26.11.2013 Action ii: Chair and CEO to speak to NR counterparts
Item 4: PR13 progress
19. John Larkinson gave a verbal report. The process for implementing access contracts following the Determination was proving more complex even than anticipated. Resources were being added and close management would be required to meet the 20 December deadline. The draft enhancement delivery plan, which was due from NR in the new year, would need whole industry involvement to be effective and credible. There was potential for controversy and an associated risk of delay.
20. Staff were working with NR in an effort to understand and resolve any questions on the interpretation of the Determination. The size of the gap between ORR’s appraisal of NR’s financial performance and NR’s own assessment in the summer of 2013 meant that everyone was focused on agreeing how ORR would measure and assess NR financial performance (and if necessary make adjustments) in CP5 before the control period began. NR had commissioned external professional advice to help identify objective measures and ORR staff were awaiting a letter setting out their position on this issue.
21. John Larkinson noted that NR thought there was a risk that the larger amounts of data required from them in CP5 would lead ORR staff to interfere in their business. This was not the intention. It was important that we developed a pragmatic solution to the lack of confidence that existed.
22. John reported on a tripartite meeting with the Competition Commission at which NR had explained some of their concerns including reference to the pace and scope of change needed.
23. John noted two remaining items of board business on PR13. A draft of the success measures would be proposed at the January meeting. There was also the question of commissioning the independent review of the PR13 process which we wanted this to start as early as possible. Scoping the project and work to identify an appropriate lead would begin now.
24. Richard Emmott said that media coverage of the Determination had been stronger than expected. 80% of coverage had been neutral (which was exactly where the regulator needed to be). The trade press had not yet commented because of publication dates.
Board 26.11.2013 Action iii: John Larkinson to meet the Chair to discuss the independent review of the PR13 process.
Item 5: Crossrail and financial sustainability
Item 5 to be redacted as it relates to commercial issues in the operation of Network Rail.
Item 6: Presentation by the Competition and Markets Authority
31. Anna Walker welcomed the CMA team: Lord Currie (Chair), Alex Chisholm (Chief Executive), Andrea Koscelli (Executive Director Markets and Mergers) and Tom Kiedrowski (Transition team). She said that the ORR Board believed in the overall direction of the CMA’s strategy and supported Government policy in pushing for better collaboration between the CMA and sectoral regulators. ORR was keen to keep our concurrent powers and to work alongside the CMA.
32. David Currie said that the CMA had no desire to remove concurrency as sectoral experience was important.
33. Tom Kiedrowski said that CMA had appreciated ORR’s contribution to setting up the UK Competition Network (UKCN). He explained the requirements of the revised regime and CMA’s role in it – particularly in the annual accountability report. He noted that 34% of the UK’s GDP was generated by organisations within the Competition Network’s purview.
34. The UKCN covered six areas of focus designed to promote competition by encouraging good networks and supporting each other to improve capabilities. Sharing best practice was a simple and powerful way of improving everyone’s basic skills. UKCN would also be a rare voice advocating a competition approach in public. The first annual concurrency report would show how the various regulators were aiming to use their competition powers.
35. Juliet Lazarus explained what ORR had been working on since David Currie had met the team. A board workshop had fed our priorities into business planning. We had a case under the Competition Act 1998 under investigation where we were getting good cooperation from the CMA and had valued their support on the site visit.
36. ORR was currently scoping a retail market review to focus on two areas: Indirect harm to passengers via restrictions on the role of third party retailers and direct harm to passengers.
37. ORR was considering a piece of work in relation to market structure on Network Rail’s system operator role (planning and managing the use of the whole system efficiently, rather than building, owning and maintaining it). Our aim would be to scope the NR role in running the market efficiently rather than focusing solely on the infrastructure – particularly in terms of maximising and selling capacity – and identifying what incentives might drive NR to improve its delivery of those benefits.
38. ORR was also going to be doing some work in relation to on-rail competition (ie non-franchised) but the area was complicated as open access operators do not contribute to fixed costs and that would need to be considered – particularly in the light of the economic equilibrium test from Europe. We were currently considering our ‘not primarily abstractive’ test in this respect and a full review of the structure and scope of charges for the next price review. Staff would keep in touch with CMA and the competition network as this work progressed. We would need to take account of developing European policy.
39. We noted that policy convergence between CMA and ORR was clearly desirable but recognised that there could be tensions between our agendas that might be appropriate, or even necessary. There could be scope for ORR and the CMA to work together to influence government policy.
40. We noted that infrastructure regulators can be vulnerable to political interventions which did not always serve the consumer well. Being joined up and consistent in our thinking and the positive pursuit of competition across all the regulators would be powerful. Evidence emerging from consumer activities would also be useful for competition purposes.
41. We noted that the CMA’s first report in April would set the baseline of activity for competition regulators recognising their different circumstances. We agreed that we would keep in touch with the CMA as a Board (though not necessarily through set piece meetings like this one).
42. The Chair explained that we were also reflecting on how we undertook competition cases at Board level given the need to separate investigation decisions and enforcement decisions. As a Board we needed to retain our oversight of issues, but without overburdening everyone with the significant time that an enforcement investigation would require. She noted that ORR is required to have someone on the Board who is ‘competition competent’ – although none of our other functions carried that requirement.
43. Alex Chisholm explained how the CMA would make a decision as a board on reference for investigation, undertake supervision of the overall portfolio of cases, procedures and quality issues – but would not itself make a decision on enforcement. Decisions would be delegated to a committee as everyone involved needed to have substantial time to commit to reading and weighing all the evidence.
44. The Chair thanked Lord Currie and the team for their time and contribution.
Item 7 Consumer Programme 45. John Larkinson introduced the paper which set out his outline plans for work specifically on the consumer agenda from the end of 2013 until November 2014, when he anticipated having additional SCS resources in place. He explained that much of ORR’s existing work had the consumer/passenger as its focus and he thought that we sometimes failed to give sufficient credit to staff for that.
46. The business plan would be drafted on the basis of delivering our existing public commitments within existing resources and assessing our impact over time in order to inform decisions about what should be planned next.
47. There were some unexploited opportunities to involve consumers and some where plans were still developing (like how to involve passengers/consumers where it would be relevant in enhancement planning).
48. We agreed that ORR should deliver on its public commitments and noted the current limitations on resources. We wanted to see a better articulation of what our longer term goals were for consumers: what good would look like, what would be different for consumers and how ORR would achieve this. We asked John to work on this with the team - but we accepted that our immediate ambitions might need to be kept modest pending the arrival of the deputy director. We agreed that delivering well on modest commitments now would help build ORR’s credibility for any more ambitious plans that emerged later.
**Board 26.11.2013 Action iv:** John to develop articulation of our longer term goals for consumers.
49. We discussed whether the significant information base about passenger views - on pricing, quality, safety, performance and so on – could be mined for systemic or geographic differences. We would be interested in understanding how regions might compare in their approaches. We also needed to be clear on what we were doing for consumers in different areas: eg safety, performance, enhancements, fares, etc. John reminded us that we needed to distinguish between the things which we could influence actively and those which we could not. He proposed discussing this with the consumer panel.
**Board 26.11.2013 Action v:** John to ask consumer panel to engage with these issues.
**Item 8 High Speed Rail Link: HS2**
50. Brian Kogan updated the Board on the publication of the Bill which had been accompanied by a very long environmental impact statement. The Bill proposed giving ORR an additional statutory duty to facilitate construction of Stage 1 and the Secretary of State would issue new advice on that duty. The Bill currently disapplied the requirement for network licensing and statutory closure provisions during construction and imposed duties of cooperation on relevant bodies.
51. At dinner the previous evening the Board had discussed the questions set out in the paper and now fed back the results of that discussion: a. ORR should remain neutral on HS2 – to build or not to build was a government decision. b. Our regulatory decisions would continue to be taken on the facts at the time and would take HS2 into account where appropriate. c. We should not seek formal involvement except where the scheme interfaced with the existing regulated network. d. The economic or other case for HS2 was not a matter for ORR. e. We did not think that HS2 would be a meaningful comparator for the existing network (except possibly HS1). f. There was a range of views as to whether NR’s involvement in the construction of HS2 would be a good use of their expertise in major construction or risk being a major distraction from running the existing network. Ultimately this was not a matter for the ORR as long as NR was adequately resourced to undertake any additional work.
52. We noted that the construction of HS2 was a unique opportunity to increase interoperability on the UK railways.
53. We asked the team to keep us updated on any emerging issues for the existing network or for ORR as the Bill progresses.
Item 9 Alliance application for access to the west coast main line (WCML)
Paragraphs 54-70 to be redacted as relating to a future decision on an access application
71. We agreed that the Board would consider the new paper and discuss it further on a conference call to be arranged within the next ten days.
Board 26.11.2013 Action vi: Further paper to be prepared and circulated to Board members in advance of a Board conference call – to take place as soon as possible.
Item 10 Competition Decision making
72. Juliet Lazarus introduced the paper which set out proposals to respond to the changing environment in the regulation of competition in the UK.
73. These changes meant that any decision on enforcing competition powers would be more time-consuming than previously and that at least some of those to be involved in such decisions would need to be ‘competition competent’. This made it impractical for our whole board to be the decision making body on competition case decisions.
74. The proposed approach was in line with other regulators – and that described by the CMA earlier in the meeting as their approach. ORR’s Board would be responsible for oversight of the process and would receive assurance on the processes. They would have the opportunity to discuss their views on a particular case with the group who would hold delegated authority to make the final decision.
75. We agreed the proposals and asked for them to be incorporated into revised Board procedures for approval before the new powers begin in April 2014.
Board 26.11.2013 Action vii: Revised Board procedures to be produced - incorporating proposals. 76. We agreed the desirability of having a Non-Executive Director (NED) who met the requirements for competition competence and that these skills were identified in the forthcoming recruitment of new NEDs. We noted that if no appropriate candidate was forthcoming, we could explore further the option of co-opting an independent expert to chair the decision group.
**Item 11 Chair’s report**
77. We noted the Chair’s report and agreed that we wanted to celebrate with staff the likely achievements of 2013/14 – including but not limited to PR13 which seemed likely to conclude on time. We felt that a celebration at the end of the staff conference would be problematic because of people travelling home. We asked Richard Emmott to consider with the executive what might be appropriate.
78. The Chair would write to all staff formally at Christmas congratulating them on the achievements of 2013.
**Board 26.11.2013 Action viii:** Richard Emmott to think about how to convey thanks on behalf of the Board to staff involved in PR13.
**Item 12 Chief Executive’s report**
79. We agreed to the Statement of Intent by the UK Competition Network and authorised the Chief Executive to sign it for ORR.
80. We noted the provisional underspend and asked the executive to bring forward any work that could be funded legitimately from this year’s budget.
**Item 13 Board forward programme**
81. We agreed to set a provisional date for a Board meeting in December 2014 as recent experience suggested that the gap between November and January Board meetings was usually too long. We would not plan to meet, but would hold diary space either for a meeting or for a telephone conference. [The provisional meeting was set for Tuesday 16 December].
**Item 14 Board minutes from 1 and 22 October 2013.**
82. The Board Secretary highlighted that these minutes covered our main PR13 decisions.
83. The minutes were approved subject to any final comments by the Chair and legal teams.
**Item 15 Matters arising**
84. We noted the progress on the action list of matters arising.
**Item 16 Any Other Business**
85. The Chair reminded us that this was Steve Walker’s final Board meeting (he would chair the SRC meeting in December) and wanted to record formally her thanks for his work as a NED. Steve had a passionate commitment to safety and she noted his contribution in chairing the SRC, in improving the Committee’s approach to and understanding of risk, its improved strategic reporting, and supporting RSD in For publication
structuring the annual report better. This work had all been well received. He was well respected by the staff, particularly in RSD and would be missed. ORR also owed him a debt of gratitude for his contribution to the wider Board agenda.
86. Steve thanked the Chair and said he had enjoyed his four years very much. He had seen tremendous progress in ORR, particularly in the way that the safety team had connected with other parts of the organisation to develop into a joined-up regulator. He thought the fact that the industry had multiple risk owners made risk management more difficult than it was in other industries. He knew that there were many excellent people working at ORR and he would miss his contact with them.
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ab36d870b8a2ecda66662cf2e3f4635f32a8cf31 | Office of Rail Regulation
Minutes of the a telephone meeting by the ORR Board on 11 December 2013 (16:30 – 18:00), ORR offices, One Kemble Street, London
Present: Non-executive directors: Anna Walker (Chair), Tracey Barlow, Peter Bucks (both on the phone) Executive directors: Richard Price (Chief Executive), Ian Prosser (Director, Railway Safety) In attendance, all items: John Larkinson (acting Director of Railway Markets and Economics), Richard Emmott (Director of Communications), Tess Sanford (Board Secretary), Brian Kogan, Rob Plaskitt, Ian Williams, Paul Hadley. On the phone: Dan Brown (Director of Strategy), Juliet Lazarus (Director, Legal Services) Apologies: Mark Fairbairn, Stephen Nelson, Ray O’Toole, Steve Walker, Alan Price.
Item 1: Welcome and apologies for absence
1. The Chair welcomed everyone to the meeting and noted the apologies.
Item 2: Declarations of interest 2. None.
Item 3: Alliance application for access to the west coast main line (WCML) 3. Rob Plaskitt explained that the paper had been updated and clarified following the discussion at the board on 26 November. Responding to a request from the Board to have more detail on the hurdles that would need to be overcome to reach a positive decision on this application, the team had updated their paper accordingly. This discussion would only be about the application before the Board – it was important that nothing in the consideration of this application should inadvertently limit our ability to consider any other application on its own merits. 4. We agreed that the updated paper did set out more clearly than the earlier paper the various criteria and the process that the team had applied; and the areas of uncertainty were acknowledged alongside reasons for their recommendation. 5. Juliet Lazarus drew the Board’s attention to the section of the paper which set out those statutory duties that had been identified as most relevant in consideration of this case. She thought the paper captured and reflected the proper application of our process. Ultimately, the board would have to balance their various duties and reach a judgment whether to reject the application at this stage or continue to wait for better information. She felt that they could be assured that the process had been robustly applied. 6. The Board reflected on the four key criteria that are considered in weighing an access application. 7. On capacity, Rob Plaskitt reminded the Board about the lack of current capacity for the peak services sought: there were three theoretical off peak paths each hour. There were some issues about consistency with the Northern Hub requirements under the franchising and HLOS process. Finally (and quite late in the process) uncertainties had appeared about HS2’s impact which suggested there could be serious additional constraints on capacity at the southern end of WCML from 2016 onwards.
08. We discussed how any rights granted for this application would inter-relate with existing franchise operators and passenger services into Euston. Rights granted now to Alliance for 2016 and beyond would take priority over existing franchise operators (whose rights did not run so far). The risk was that, should capacity become more constrained, heavily used commuter services would be displaced by the proposed Alliance priority rights. This would clearly risk disbenefit to large numbers of passengers and the most likely outcome seemed to be that the Alliance rights would have to be bought out. We noted that the commuter services were almost full whereas services on the longer routes run by Virgin still had some on-train capacity – particularly in the off-peak.
09. Brian Kogan reminded us about the issue around charging design. Franchisees are required to provide core services and are charged accordingly. Open Access charges were set to reflect the expectation that they would be supplementary services meeting marginal costs and operating on the margins of capacity. Our policy had not previously been tested by an application which might displace significant existing services.
10. We agreed that we would need to revisit our open access policy in future to ensure that we considered these issues. In the meantime we should continue with the application before us. We agreed that there was no obvious capacity to accommodate this size of application.
11. The second criterion considered in our application process is the likely impact on performance. We have previously accepted that, given the congestion on the network, additional services are always likely to risk negatively impacting on performance. NR had concerns about selling the three theoretical paths because of the potential serious impact on performance. Recasting the timetable in a way that might allow additional paths would require significant work across the industry and might cause knock-on issues such as insufficient rolling stock or an unbalanced timetable. Again, these issues had arisen before the uncertainty around the impact of HS2 emerged. NR was prepared to offer one path an hour, but this was clearly below what Alliance was seeking. We agreed with NR that there was a real risk of serious negative impact on performance if all the available off peak paths were sold.
12. The third criterion was impact on the Secretary of State’s funds. Again, we reminded ourselves that most open access operations abstracted some revenue from franchise operations and therefore risked an adverse impact. The issue in this case was the possible scale of any impact. The previous paper had speculated on the DfT’s likely reaction to a positive determination in this case: the executive had now included its actual responses. The DfT argued that the application, if successful, was sufficiently large that it could be expected to result in a reduced premium for the WCML franchise. In addition there was the risk of displaced franchise services, and the inconsistency implied by undermining the Northern Hub and risking delivery of the extra peak capacity commuter services specified in the HLOS for Euston. While Alliance might deliver some of the HLOS requirements, government would have no certainty over what would be delivered or whether it would continue to be delivered. DfT had also raised the issue of the risk of compensation payments, which were likely to be significant, to sort out any future access constraints.
13. We discussed the scale of the application and the team were very clear that they believed the possible financial impact on the SoS funds was significant – much more material than under previous open access applications. A specific range was impossible to set, but we had already heard there would be significant abstracted value from the franchise operator and the additional risk of compensation payments if those arose. There was also an increased risk that the HLOS would not be delivered so the potential cost to the Secretary of State was likely to be on a scale that would give real concerns in relation to our duty to have regard to the Secretary of State’s funds.
14. We noted that on the three criteria we had considered so far there was an absolute lack of current capacity at peak times, an acknowledged disbenefit on performance and a sizeable negative impact which would likely be more than usually adverse on the SoS funds.
15. The fourth criterion was the NPA [not primarily abstractive] test which we would normally use to assess the impact of new services on an existing timetable to ensure that they generate a level of additional revenue. The test was designed to deal with marginal propositions against existing services – which open access applications we have previously considered had been. Applicants must pass the test, but passing the test did not automatically mean that an application should be permitted.
16. We had already understood that this proposal could displace existing services, and it could not be accommodated without a major recast of the timetable. Staff explained that very rough early calculations had indicated that the application might not generate sufficient additional income to meet the NPA test (less than half the required 0.3 margin) - but the main problem was that there was no proper data on which to run the full test. The test could not be run on the existing timetable – because the new services could not be accommodated within it. A re-cast timetable to include the new services would require significant work across the industry but there was no guarantee that the services would actually be accommodated within a recast timetable. Finally, there would inevitably be an extended period before the medium term impact of HS2 could be understood well enough to gauge the effect on this application. That meant that we could not run an effective NPA test at this time or at any foreseeable future date.
17. We noted that the scale of the application had been relevant to our consideration of the four criteria.
18. We reflected on our relevant statutory duties, particularly those relating to protecting the interests of users of railway services, to promote competition for the benefit of rail users, to have regard to the funds available to the Secretary of State and his guidance, and to enable operators to plan their businesses with reasonable assurance. We noted that we begin the process with an assumption that open access operations will offer benefits to users but that at this time we could not say that about this application. We agreed that the arguments were well rehearsed in the paper and had been supported by our discussion.
19. We asked about the quality of the underlying information provided by NR. Brian Kogan said that NR’s original capacity assessment had been rejected by the team as insufficient but the second one had been competent. In the same way, the team’s analysis suggested that the impact on the Secretary of State’s finances would be less bad than DfT’s initial claim – but it was still a significant impact.
20. We also considered our duty to promote competition for the benefit of rail users. We recognised that this statutory duty had to be weighed against our other statutory duties. We also recognised that the Alliance application would offer more competition in the market. However, given its size, it would have an impact on what franchisees might bid and so potentially diminish competition for the market. We also recognised the need to factor into our decision making our duty to have regard to the Secretary of State’s funds and the interests of the other users of the network.
21. On the basis of the arguments set out in the paper and rehearsed in our discussion we agreed that we should reject the Alliance application now.
22. Given the detailed consideration that the Board had given this application, we asked that the final decision letter should be approved by the Chair and the Chief Executive before it was issued.
23. We noted that the usual practice is to give applicants an opportunity to comment on decision letters before they are published and that this practice would be followed in this case.
Action: Draft of the decision letter to be approved by the Chief Executive and Chair before being issued.
Action: Alliance to be given the opportunity to comment before the final letter is sent.
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f94ff53249052ae03a4c66f8d18086e3d2f722a2 | Freedom of Information Act 2000 Request
Review into prosecutions and convictions under the Coronavirus Act 2020 and the Health Protection Regulations
Request
I am writing to you under the Freedom of Information Act 2000 to request the following information from the Crown Prosecution Service regarding its recent review into prosecutions and convictions under the Coronavirus Act 2020 and the Health Protection (Coronavirus Restrictions) Regulations.
I am requesting the details of the 12 cases that were incorrectly charged under the Health Protection Regulations.
1. What was the specific charge in each case?
2. Why was the charge overturned?
Response
In response to the first part of your request the specific charge in each case are as follows:
Three cases - Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 {8(1), 12(1) (b) & (4)} Five cases - Health Protection (Coronavirus, Restrictions) (England) Regulations 2020 {6 and 9(1) (b) & (4)} Two cases - Health Protection (Coronavirus) Regulations 2020 {4(1), 15(1) (a) and (5)} One case - Health Protection (Coronavirus, Restrictions) (England) Regulations 2020 {9 (2) & (4)} One Case - Health Protection (Coronavirus Restrictions) (Wales) Regulations 2020 {8 (1), 12(1) (b)& (4)}
In response to the second part of your request, please see below which outlines the reasoning for each of the 12 cases, where the charge was overturned under the Health Protection Regulations.
One case - Wrong Section of Regulations Three cases - Welsh Regulations in England Two cases - England Regulations in Wales Four cases - Homeless person Two cases - Regulations Repealed
Information Management Unit 020 3357 0788 [email protected]
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73bdb15cb554bb2012dae8de74da97bd407c9bdd | Section 17 Notice under the Freedom of Information Act 2000
WITHHOLDING INFORMATION
Section 21 states Information accessible to applicant by other means.
(1) Information which is reasonably accessible to the applicant otherwise than under section 21 is exempt information.
(2) For the purposes of subsection (1)—
(a) Information may be reasonably accessible to the applicant even though it is accessible only on payment, and
(b) Information is to be taken to be reasonably accessible to the applicant if it is information which the public authority or any other person is obliged by or under any enactment to communicate (otherwise than by making the information available for inspection) to members of the public on request, whether free of charge or on payment.
(3) For the purposes of subsection (1), information which is held by a public authority and does not fall within subsection (2) (b) is not to be regarded as reasonably accessible to the applicant merely because the information is available from the public authority itself on request, unless the information is made available in accordance with the authority’s publication scheme and any payment required is specified in, or determined in accordance with, the scheme.
Section 21 is an absolute exemption which means there is no requirement to carry out a public interest test if the requested information is exempt.
Section 22(1) states that information intended for future publication is exempt information if:
(a) the information is held by the public authority with a view to its publication, by the authority or any other person, at some future date (whether determined or not),
(b) the information was already held with a view to such publication at the time when the request for information was made, and
(c) it is reasonable in all the circumstances that the information should be withheld from disclosure until the date of publication
Section 22 is a qualified exemption which means that the decision to disclose the requested material is subject to a public interest test. The CPS acknowledges that there is a public interest in demonstrating the transparency of the prosecution process and the performance of the organisation.
The data you have requested will be published on the CPS website; we are not obligated to provide you with this prior to publication.
The timetable for publication allows for the review and validation of the figures/information to be included in the report and to release this information ahead of schedule would compromise the accuracy and completeness of the data and supporting information.
On balance, I do not consider that it would be in the public interest to disclose the information requested ahead of schedule.
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d64a851bd96de2b60dbbd4aa725b00206fb79291 | Freedom of Information Act 2000 Request
Information into data breaches
Your request (in bold and in italics), and our responses appear below:
1. in the 2019/20 year: a) How many personal data breaches (under either the Data Protection Act 2018 or General Data Protection Regulation) were recorded by the CPS? b) How many of these breaches were reported to the Information Commissioner’s Office? c) Were there any instances in which the ICO required the CPS to take action or imposed an enforcement action and, if so, what action was required or taken?
In response to question one, parts a) and b) the Crown Prosecution Service (CPS) is due to publish its data pertaining to financial year 2019/20 and therefore this information is withheld under section 22(1) of the FOI Act - Information intended for future publication. Please see the attached section 17 notice which explains this exemption in further detail.
2. in the 2018/19 year: a) How many personal data breaches (under either the Data Protection Act 1998, the Data Protection Act 2018 or General Data Protection Regulation) were recorded by the CPS? b) How many of these breaches were reported to the Information Commissioner’s Office? c) Were there any instances in which the ICO required the CPS to take action or imposed an enforcement action and, if so, what action was required or taken?
3. in the 2017/18 year: a) How many personal data breaches (under the Data Protection Act 1998) were recorded by the CPS? b) How many of these breaches were reported to the Information Commissioner’s Office? c) Were there any instances in which the ICO required the CPS to take action or imposed an enforcement action and, if so, what action was required or taken?
Data pertaining to financial years 2017/18 and 2018/19, as requested in parts a) and b) of questions two and three is published on the CPS Annual Report and Accounts and is therefore withheld from disclosure under section 21 of the FOI Act – Information accessible by other means. Please refer to the attached Section 17 Notice which explains this exemption in further detail. The CPS Annual Report and Accounts contains data pertaining to all data breaches reported to the Departmental Security Unit (DSU), broken down by breach type and whether the breach was ‘Included or excluded’. Where the explanatory note indicates that the breach was ‘excluded’ on the report, this indicates that the breach was contained.
Data breach information can be located within the Annual Report and Accounts 2018-19 via the link below on page 41.
https://www.cps.gov.uk/publication/cps-annual-report-2018-19
Data breach information for 2017-18 can be located within the Annual Report and Accounts 2017-18 via the link below on page 23.
https://www.cps.gov.uk/publication/cps-annual-report-2017-2018
The Crown Prosecution Service (CPS) does not hold a central record of the information requested in part c) of questions one, two and three. In order to determine whether there was a requirement by the Information Commissioner’s Office (ICO) for action to be taken by the CPS, the subsequent action taken and whether any enforcement actions were imposed by the ICO, a manual review of all ICO referrals during the requested time period would be required.
As a guide, during the three financial years requested, there were a total of 128 ICO referrals made to the CPS.
Section 12(1) of the FOI Act means public authorities are not obliged to comply with a request for information if it estimates the cost of complying would exceed the appropriate limit. The appropriate limit for central government is set at £600. This represents the estimated cost of one person spending 3.5 working days determining whether the department holds the information, and locating, retrieving and extracting the information.
We believe that the cost of manually reviewing 128 referrals would exceed the appropriate limit. Consequently, we are not obliged to comply with your request.
Under section 16 of the FOI Act we have an obligation to advise what, if any, information may assist you with your request. The Information Commissioner’s Office (ICO), publishes information regarding requirements made and any enforcement actions and formal sanctions imposed upon the CPS. This information can be found on their website via the following links:
https://ico.org.uk/action-weve-taken/enforcement/
https://ico.org.uk/action-weve-taken/enforcement/crown-prosecution-service/
Information Management Unit 020 3357 0788 [email protected]
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b59e6d1f6c96a5b3dc95509b121efe8a954d8d29 | Section 17 Notice under the Freedom of Information Act 2000
WITHHOLDING INFORMATION
Section 21 states Information accessible to applicant by other means.
(1) Information which is reasonably accessible to the applicant otherwise than under section 21 is exempt information.
(2) For the purposes of subsection (1)— (a) Information may be reasonably accessible to the applicant even though it is accessible only on payment, and (b) Information is to be taken to be reasonably accessible to the applicant if it is information which the public authority or any other person is obliged by or under any enactment to communicate (otherwise than by making the information available for inspection) to members of the public on request, whether free of charge or on payment.
(3) For the purposes of subsection (1), information which is held by a public authority and does not fall within subsection (2) (b) is not to be regarded as reasonably accessible to the applicant merely because the information is available from the public authority itself on request, unless the information is made available in accordance with the authority’s publication scheme and any payment required is specified in, or determined in accordance with, the scheme.
Section 21 is an absolute exemption which means there is no requirement to carry out a public interest test if the requested information is exempt.
Section 40(2) – Personal Data Relating To Third Parties
The information you have requested contains personal data. Personal data can only be released if to do so would not contravene any of the data protection principles as outlined in Data Protection Act 2018 and set out by Article 5 of the General Data Protection Regulation (GDPR)
Personal data shall be processed lawfully, fairly and in a transparent manner We believe releasing the requested information into the public domain would be unfair to the individuals concerned; these individuals have a clear and strong expectation that their personal data will be held in confidence and not disclosed to the public under the FOI Act.
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85d1ad59ebe6fd5e923542f314148a3f463ae2b4 | Freedom of Information Act 2000 Request
Information on the CPS’ corporate software/enterprise applications
Request and Responses:
I require the organisation’s to provide me with the following contract information relating to the following corporate software/enterprise applications:
A. Enterprise Resource Planning Software Solution (ERP) - this is the organisation’s main ERP system and may include service support, maintenance and upgrades.
B. Primary Customer Relationship Management (CRM) Solution - this is the organisation’s main CRM system and may include service support, maintenance and upgrades. Example of CRM systems the organisation may use could include Microsoft Dynamics, Front Office, Lagan CRM, Firmstep.
C. Primary Human Resources (HR) and Payroll Software Solution - this is the organisation’s main HR/payroll system and may include service support, maintenance and upgrades. In some cases the HR contract maybe separate to the payroll contract please provide both types of contracts. Example of HR/Payroll systems the organisation may use could include iTrent, ResourceLink.
D. The organisation’s primary corporate Finance Software Solution - this is the organisation’s main Finance system and may include service support, maintenance and upgrades. Example of finance systems the organisation may use could include E-Business suite, Agresso (Unit4), eFinancials, Integra, SAP.
In some cases you may come across contracts that provides service support maintenance and upgrades separate to the main software contract, please also provide this information in the response following the requested data below.
1 Software Category: ERP, CRM, HR, Payroll, Finance
The department’s main HR, Finance and Procurement solutions are delivered through an Enterprise Resource Planning (ERP) solution. This information is withheld from disclosure under section 21 ‘Information accessible by other means’ of the FOI Act and the attached S.17 refusal notice explains this in more detail. However, details of our ERP contract can be located within Contracts Finder via the following link: https://www.contractsfinder.service.gov.uk/Search
2 **Name of Supplier: Can you please provide me with the software provider for each contract?**
The supplier is Oracle.
3 **The brand of the software: Can you please provide me with the actual name of the software. Please do not provide me with the supplier name again please provide me with the actual software name.**
The software is Oracle Cloud.
4 **Description of the contract: Please do not just state two to three words can you please provide me detail information about this contract and please state if upgrade, maintenance and support is included.**
Please see the information on Contracts Finder as highlighted in question 1 and covered by the S.17 refusal notice.
5 **Number of Users/Licenses: What is the total number of user/licenses for this contract?**
This applies to all CPS users, so in the region of 6,500.
6 **Annual Spend: What is the annual average spend for each contract?**
7 **Contract Duration: What is the duration of the contract please include any available extensions within the contract.**
8 **Contract Start Date: What is the start date of this contract? Please include month and year of the contract. DD-MM-YY or MM-YY.**
9 **Contract Expiry: What is the expiry date of this contract? Please include month and year of the contract. DD-MM-YY or MM-YY.**
10 **Contract Review Date: What is the review date of this contract? Please include month and year of the contract. If this cannot be provided please provide me estimates of when the contract is likely to be reviewed. DD-MM-YY or MM-YY.**
In response to questions 6-10 details regarding our contracts can be located via the Contracts Finder link provided in our response to Question 1 and again covered by the S.17 refusal notice.
11 **Contact Details: I require the full contact details of the person within the organisation responsible for this particular software contract (name, job title, email, contact number).** In response to your request for the detail of the persons responsible for IT contracts, including their names, job titles and direct contact numbers the department claims an exemption under section 40 ‘personal information’ of the FOI Act 2000. Please refer to the attached S.17 refusal notice.
Our procurement team email address is: [email protected]
Information Management Unit 020 3357 0788 [email protected]
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1a4d67e12ac5129169b64ab230a54f25263664e2 | Disclosure ref: 35 Sent: 26th June 2020
Freedom of Information Act 2000 Request
Request into tax fraudsters and repayments
Request and Response
Your request (in italics), numbered for ease of reference, and our response appears below:
https://www.cps.gov.uk/cps/news/fraudsters-who-stole-millions-wealthy-investors-fake-green-investment-scheme-must-pay-ps20
1. Could you supply an answer if the tax fraudsters paid back the tax court ordered?
2. If so which person paid it back on 3 months and
3. If there were deals to buy it back later?
Response
The Crown Prosecution Service (CPS) has interpreted part one to refer to the amount that has been paid back in satisfaction of the Confiscation Orders issued by the Crown Court in respect of the case referred to. We have interpreted part two to be a request for the names of any defendant who paid their Confiscation Order in full within three months, the period of time given by the Crown Court.
We are unable to proceed with part three of your request as it is not clear what information it is you require. Please can you provide further details on what information you require and we will consider this as a new request under the Freedom of Information Act.
If we do not receive clarification of the information you seek regarding part three within one calendar month of this response, we will consider that part closed.
As regards parts one and two of your request, records held by the CPS Proceeds of Crime unit (CPSPOC), indicate that as of 16 June 2020 the total amount repaid for all defendants is £690,300.31. Mr Anwyl repaid the full amount of his confiscation order within three months.
CPSPOC continue to explore all enforcement options in respect of each defendant.
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a7183aa5c05e262696687d73fb1aa84639dfaedb | Freedom of Information Act 2000 Request
Request regarding rape of Caucasian women By Black or Afro Caribbean? The crimes were they classed as a Racist Attack or rape data from Jan 1, 2017 to Jan 2019. The area that the Metropolitan Police force cover.
Request
Can you supply FOI regarding rape of Caucasian women By Black or Afro Caribbean? The crimes were they classed as a Racist Attack or rape?
What was the percentage of convictions?
On the 17 June 2020 you clarified that the data required was: -
In the following time frame - Jan 1, 2017 to Jan 2019. The area that the Metropolitan Police force cover.
Response
The Crown Prosecution Service (CPS) has interpreted your request to be for the number of recorded offences of Rape, referred from the Metropolitan Police, in which the complainant is recorded to be of Caucasian ethnicity and the defendant is recorded to be of Black, or Afro-Caribbean ethnicity, between the time-frame specified.
The CPS does not hold a centralised record of data pertaining to cases involving an offence of rape. Under section 16 of the Freedom of Information Act we have an obligation to advise what, if any information may assist you with your request. The CPS holds data regarding the outcome of prosecutions, by Police force area, in cases that have been flagged administratively on the CPS Case Management System. The rape flag is applied at the onset of any case referred by the police to the CPS for a charge of rape; and remains in place even if the charge is not proceeded with, is amended or dropped. If a case is referred by the police for a charge other than rape but at a later date a charge of rape is preferred the flag is applied at that point. The London police force area covers both the Metropolitan and City Police organisations. This data is published annually, by financial year, in the CPS’ Violence against Women and Girls’ (VAWG) report available on the CPS website. Annual data is also published on the CPS’ website. The data held is not recordable by complainant or complainant characteristics. Data held pertaining to the ethnicity of a defendant is based upon the self-declaration of the information made to the police, and it is therefore subject to varying levels of error and omission. We therefore do not consider that full reliance can be placed upon the information held.
The CPS’ VAWG and Annual Reports can be accessed via the following links:
https://www.cps.gov.uk/publication/annual-reports-and-business-plans
https://www.cps.gov.uk/cps/news/annual-violence-against-women-and-girls-report-published-0
The Ministry of Justice (MoJ) holds and publishes the official statistics on prosecutions for the offence of rape. Data held by the MoJ can be found via the following link:
https://www.gov.uk/government/organisations/ministry-of-justice
Information Management Unit 020 3357 0788 [email protected]
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c21c8a531628359da48dbe02e84b32f2a21d4849 | Freedom of Information Act 2000 Request
The number of RSPCA private prosecutions taken over by the Crown Prosecution Service (CPS) in the past five years.
Request and Response appears below:
1. In the past 5 years how many RSPCA private prosecutions have the CPS taken over?
The Crown Prosecution Service (CPS) manual records indicate that the CPS has taken over three RSPCA private prosecutions as outlined in your request.
2. Of that number in (a), how many of those prosecutions were discontinued by the CPS
Out of the three RSPCA private prosecutions mentioned above, all were taken over and discontinued by the CPS. For one of these cases, the private prosecution was taken over and discontinued for one of the defendants only.
3. Of that number in (a) how many of those prosecutions were continued by the CPS
None of the three prosecutions mentioned above were continued by the CPS.
...
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2bcb040f3b6778558cdd8c7aa602fd6d21923982 | Freedom of Information Act 2000 Request
To establish the total number of CPS employees within the Human Resources (HR)
Request (emboldened and in italics) responses appear below:
1. On the 1 March 2020, (a) the total number and (b) full-time-equivalent of Crown Prosecution Service (CPS) staff (permanent/temporary employees), by grade in CPS HR
| Grade | a) Total Number | b) FTE | |----------------|-----------------|----------| | Fixed Term Appointment | | | | A2 | 19 | 19.00 | | B1 | Less than 5 | Less than 5 | | D | Less than 5 | Less than 5 | | Permanent | | | | A2 | 116 | 111.91 | | B1 | Less than 5 | Less than 5 | | B2 | 26 | 25.26 | | B3 | 28 | 27.05 | | B3 | 18 | 17.70 | | CA | Less than 5 | Less than 5 | | D | 30 | 28.38 | | E | 7 | 6.92 | | SCP | Less than 5 | Less than 5 | | SCS | 1 | 1.00 | | Grand Total | 135 | 130.91 |
- Please note the data is at 29 February 2020 and not 01 March 2020.
- Where appropriate this data has been anonymised under section 40 of the FOI Act – personal information. To disclose this type of information would be unfair to the individuals concerned; individuals have a clear and strong expectation that their personal data will be held in confidence and not disclosed to the public. This is especially true of personal data as it comprises information that individuals will regard as the most private.
2. **On the 1 March 2020, the total number of contingent labour (contractors) staff engaged by CPS, by their equivalent grade designation, in CPS HR**
The total number of contingent labour staff engaged by CPS HR was zero.
3. **A copy of the organogram for CPS HR on the 1 March 2020, or the latest one that was made, with a date**
Please refer to the document labelled as ‘Milway 9216-Attachment’. This organogram as at end of June 2020.
4. **On 1 March 2020, the total number of CPS HR staff by office location**
| Office Location | Head Count | |----------------------------------------|------------| | Middlesbrough, North Yorkshire, GB | Less than 5| | Nottingham, Nottinghamshire, GB | Less than 5| | Liverpool, Merseyside, GB | 43 | | Eastleigh, Hampshire, GB | Less than 5| | Cardiff, South Glamorgan, GB | Less than 5| | Birmingham, West Midlands, GB | Less than 5| | Brighton, East Sussex, GB | Less than 5| | Greater London, GB | 36 | | Wakefield, West Yorkshire, GB | Less than 5| | York, North Yorkshire, GB | 34 | | Sheffield, South Yorkshire, GB | Less than 5| | Greater Manchester, GB | Less than 5| | Swansea, South Wales, GB | Less than 5| | Preston, Lancashire, GB | Less than 5| | **Grand Total** | **135** |
- Please note the data is at 29 February 2020 and not 01 March 2020.
- Where appropriate this data has been anonymised under section 40 of the FOI Act – personal information. To disclose this type of information would be unfair to the individuals concerned; individuals have a clear and strong expectation that their personal data will be held in confidence and not disclosed to the public. This is especially true of personal data as it comprises information that individuals will regard as the most private.
Information Management Unit
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6f38a850728b9e277994b84bc76ef9bae74f8f74 | CPS Prosecutions on behalf of DWP (Department for Work and Pensions)
| Reason for Prosecution Dropped | 2018 | 2019 | 2 Year Total | |--------------------------------|------|------|--------------| | Disclosure: undermining unused material | 10 | 16 | 26 | | Evidential | 116 | 66 | 182 | | Other | 10 | 1 | 11 | | Public Interest | 132 | 65 | 197 | | Victims and Witnesses | 1 | 5 | 6 | | Total Prosecutions Dropped | 269 | 153 | 422 | | Total Prosecuted | 3,454| 2,334| 5,788 |
The following caveats apply to the above data:
- The data in the attached table is derived from the combination of a unique numerical identifier and the police unit code.
- The counting unit for CPS records is the defendant in a case, as opposed to the number of offences, or the number of cases. Thus, if a single set of proceedings involves more than one defendant, then each defendant is counted, and the outcome is recorded for each defendant.
- Prosecutions dropped are those proceedings where the CPS has discontinued, withdrawn, offered no evidence or the prosecution or indictment has been stayed and where all charges lie on file.
- A reason explaining why the case failed is allocated to all cases resulting in an outcome other than a conviction. If more than one reason applies the principal reason is selected.
- Total prosecution outcomes comprise convictions (guilty pleas, convictions after trial and cases proved in the absence of the defendant) and unsuccessful outcomes (prosecutions dropped by the CPS, discharges, acquittals after trial and administrative finalisations).
Plus:
1. CPS data are available through its Case Management System (CMS) and associated Management Information System (MIS). The CPS collects data to assist in the effective management of its prosecution functions. The CPS does not collect data that constitutes official statistics as defined in the Statistics and Registration Service Act 2007.
2. These data have been drawn from the CPS’s administrative IT system, which (as with any large scale recording system) is subject to possible errors with data entry and processing. The figures are provisional and subject to change as more information is recorded by the CPS. We are committed to improving the quality of our data and from mid-June 2015 introduced a new data assurance regime which may explain some unexpected variance in some future data sets.
3. The official statistics relating to crime and policing are maintained by the Home Office (HO) and the official statistics relating to sentencing, criminal court proceedings, offenders brought to justice, the courts and the judiciary are maintained by the Ministry of Justice (MOJ).
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7c9b5cf8ea5e075880412092c3a2538e8f0981a7 | Freedom of Information Act 2000 Request
What action was taken by the CPS in response to the concerns of the CCRC regarding the DWP's procedures and possible breaches of legislation including CPIA given that it prosecutes DWP benefit fraud cases?
Request and Response appears below:
In July 2019, Karen Kneller (Chief Executive of the CCRC) wrote to the permanent secretary of the DWP, Peter Schofield, regarding concerns raised with the Criminal Cases Review Commission (CCRC) about breaches of the legislation that governs the investigation of criminal investigations. This includes CPIA. Paul Staff of the CPS was copied into this communication.
1. What action was taken by the CPS in response to the concerns of the CCRC regarding the DWP's procedures and possible breaches of legislation including CPIA given that it prosecutes DWP benefit fraud cases?
The Crown Prosecution Service (CPS) holds no recorded information relating to any action taken as described in point one.
2. Can you confirm how many cases the CPS prosecute on behalf of the DWP on a yearly basis for the past 2 years and how many cases it rejects due to evidential shortcomings and/or breaches of CPIA. Specifically the failure to follow all reasonable lines of enquiry that point to and away from the suspect.
The CPS holds data concerning the number of DWP (Department for Work and Pensions) prosecutions for each of the last two calendar years 2018 and 2019. No central data is held regarding the number of those prosecutions that were dropped specifically due to “evidential shortcomings and/or breaches of CPIA” however some data is held to indicate reasons why those prosecutions were dropped. This data is attached and should be read in conjunction with the caveats appended to it. In order to identify whether “evidential shortcomings and/or breaches of CPIA” as described were contributory factors towards the dropping of any of the prosecutions as indicated in the attached data, a manual review of each case would be required. The data indicates that there are 422 relevant cases.
Section 12(1) of the FOI Act provides that public authorities are not obliged to comply with a request for information if it estimates the cost of complying would exceed the appropriate limit. The appropriate limit for central government is set at £600. This represents the estimated cost of one person spending approximately 3.5 working days determining whether the department holds the information, and locating, retrieving and extracting the information.
We believe that the cost of reviewing 422 cases would exceed the appropriate limit. Consequently, we are not obliged to comply with the second part of point two.
3. **What has the CPS done to rectify any issues regarding evidential failings especially in light of the communication of the CCRC.**
The CPS holds no recorded information relating to part three of your request.
4. **Can you also provide details of how many hearsay evidence applications the CPS has submitted to the courts in relation to DWP prosecution cases (For example the DWP has submitted hearsay evidence by way of the DWP investigator exhibiting banking information rather than the bank itself). Please provide the numbers for the previous 2 years and how many of these hearsay applications failed.**
The CPS does not hold a centralised record regarding hearsay evidence applications. In order to determine the number of applications that have been submitted in relation to DWP prosecution cases and the number that have failed during the previous two years, a manual examination of all DWP prosecution cases would be required. Our records indicate that there were 3,454 DWP prosecutions during 2018. A manual review of 3,454 prosecutions would attract the cost limit exemption as described in our response to point two. Consequently, we are not obliged to comply with this part of your request.
Information Management Unit 020 3357 0788 [email protected]
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82a3f6efea2b99dcb78f48da0d1f52e5ccf11c5d | Freedom of Information Act 2000 Request
Details regarding CTL failures attributed to the CPS and other organisations, along with any other information the log contains that can legally be provided
Request
In response to a previous FOI request I was advised that the CPS holds a log of all custody time limit failures attributable to the CPS and to other organisations
Under the Freedom of Information Act please could you provide this log of CTL failures attributed to the CPS and to other organisations, along with any other information the log contains that you are legally able to provide.
Response
Custody Time Limits (CTL) safeguard un-convicted defendants by preventing them from being held in pre-trial custody for an excessive period of time.
The Prosecution of Offences Act 1985 and the Custody Time Limit Regulations set a custody time limit for a Crown Court case of 182 days for a Crown Court case and 56 days for a magistrates’ court (or Youth Court) case.
Custody Time Limits can be extended by the court on application by the prosecution. In order to extend the CTL the court must be satisfied that there is a good and sufficient cause to extend an un-convicted defendant's pre-trial detention. The court must also be satisfied that the prosecution has acted with all due diligence and expedition.
Cases in which the court is not satisfied that the prosecution has acted with due diligence and expedition, or in which the prosecution has failed to apply for an extension, must be reported to the Chief Crown Prosecutor for the area concerned and a report prepared for the Director of Public Prosecutions. Because Custody Time Limits apply to each and every charge some of these cases will represent technical failures in that the defendant would have remained in custody on other charges.
The Crown Prosecution Service (CPS) centrally holds a database relating to Custody Time Limits (CTL) cases in which a failure to extend a CTL was attributable to the actions of the CPS. That database includes cases in which the actions of other organisations led to a failure to extend a CTL but not all such cases will be recorded on the CTL database.
The CTL database indicates that there were 63 cases over the last five financial years (2014-15 to 2018-19) in which the failure to extend the CTL was attributable to the CPS.
However it should be noted that the CPS does not collect data which constitutes official statistics as defined in the Statistics and Registration Service Act 2007. The data recorded has been drawn from both manual diaries and records held in the CPS’s administrative IT system, which (as with any large scale recording system) is subject to possible errors with data entry and processing. The figures are provisional and subject to change as more information is recorded by the CPS.
Under section 16 of the Freedom of Information Act we have a duty to advise you what, if any, information may assist you with your request. The official statistics relating to crime and policing are maintained by the Home Office. A request for information can be made to them via:
[email protected]
The official statistics relating to sentencing, criminal court proceedings, offenders brought to justice, the courts and the judiciary are maintained by the Ministry of Justice. Information requests can be made to them via the following:
[email protected]
Information Management Unit 020 3357 0788 [email protected]
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1341817f63af36055d6670f1d7e625d45a694e78 | Freedom of Information Act 2000 Request
Request for the reasons why there are lower prosecution and conviction rates against Police Officers.
Request & Responses
According to a Freedom of Information-request response from IOPC, there were 309 police officers whose cases were referred to CPS by IOPC between 2015/16 and 2018/19. Out of those 43 individuals were prosecuted and 11 convicted. (The response can be accessed here: https://www.whatdotheyknow.com/request/622849/response/1493447/attach/html/2/1008068%20James%20Marcus%20final%20response.pdf.html)
In the financial year of 2019/20, CPS charged 75% of all referred cases and out of these 84% were followed by a conviction. However, comparing this to the cases against police officers, only 13.92% were prosecuted and out of these individuals, only 25.58% were convicted.
Firstly, could you please tell me why the rate is so much lower in the cases against police officers?
In any case referred to the Crown Prosecution Service (CPS) by the police, a decision to prosecute is made in accordance with the Code for Crown Prosecutors, and a case must meet the evidential and public interest stages of the Code Test. Each case is considered on its own merits, and no distinction is made in cases involving police officers. Further, it is not the function of the CPS to decide whether a person is guilty of a criminal offence, but to make assessments about whether it is appropriate to present charges for the criminal court to consider. I attach a link for your reference regarding the Code for Crown Prosecutors:
https://www.cps.gov.uk/publication/code-crown-prosecutors
Secondly, if there is a suspicion that a police officer has committed a crime, are they investigated by their own force? If so, who decides whether the case is referred to the CPS or not?
Allegations of criminal offences involving police officers are referred to the Independent Office for Police Conduct (IOPC). They will then decide whether the matter requires an investigation and the type of investigation. Under section 16 of the FOI Act we have an obligation to advise what, if any, information may assist you with your request; more information is available on their website and I attach that link:
https://policeconduct.gov.uk/investigations/what-we-investigate-and-next-steps
It is then for the IOPC to take forward and decide whether the case should be referred to the CPS for a decision to prosecute.
*Can the fellow officers decline to give information against the accused and therefore stop the case from proceeding to CPS?*
As in any case, any witness can decline to provide information during an investigation. It is possible this will impact upon the evidential merits of a case, depending on the circumstances of the case. While the CPS can offer early investigative advice to the police, including on lines of enquiry, any decision to refer a case to the CPS for a charging decision is one for the IOPC or police.
Information Management Unit 020 3357 0788 [email protected]
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a08d1df649861b4560b93a1ebc21e6c2fdeceb01 | # FINAL Internal Audit Report
## Banking and Payment Arrangements – Accounts Payable (AP)
**October 2019**
| To: | Director of Finance, LBB\
| | Acting Head of Finance – Projects, LBB | | Copied to: | Finance Director, CSG\
| | Accounts Payable Manager, Accounts Payable, CSG\
| | CSG/LBB AP Business Partner\
| | Deputy Director of Finance, LBB\
| | Assistant Director of Finance, LBB\
| | Accounts Payable Senior Manager, CSG\
| | Accounts Payable Team Leader, Accounts Payable, CSG\
| | Operations Director, CSG\
| | Head of Performance and Risk Management, CSG | | From: | Head of Internal Audit LBB |
We would like to thank management and staff of the Accounts Payable team for their time and co-operation during the course of the internal audit. Contents
Executive Summary
1. Progress against relevant actions from Grant Thornton’s ‘Review of the Financial Management Relating to CPO Fraud’ (Page 6)
2. Accounts Payable audit - Findings, Risks and Action Plan (Page 16)
3. Appendix 5: Follow-up of past audits – Accounts Payable 2017-18 (Page 39)
4. Appendix 6.1: Outcome of detailed testing from Payments Data Analytics and Matching Exercises’ reported in February 2019 (Page 43)
5. Appendix 6.2 Observations from Payments Data Analytics and Matching Exercises’ reported in February 2019. (Page 54) Executive Summary
| Assurance level | Number of recommendations by risk category | |-----------------|------------------------------------------| | Limited Assurance | Critical | High | Medium | Low | Advisory | | | - | 2 | 4 | 1 | - |
Scope
This review was undertaken as part of the 2018-19 Internal Audit and Anti-Fraud Strategy and Annual Plan approved by the Council’s Audit Committee on 19 April 2018.
The Council’s Accounts Payable function is run by the Customer Support Group (CSG), a Capita function based in Chichester on behalf of the Council. This review identified the key controls over payments made by the Council (outside of the Treasury team) and tested the operation of processes to give assurance on the effectiveness of those controls. See Part 2 of this report for the outcome of the testing of key Accounts Payable controls.
In December 2017, it came to light that potentially fraudulent transactions of ca. £2m had been made against the Council. An investigation was opened by the Council’s Corporate Anti-Fraud Team (CAFT) and it was found that the transactions related to Compulsory Purchase Orders (CPOs). As a result of the alleged fraud the Chief Financial Officer (CFO) commissioned Grant Thornton (GT) UK LLP to undertake a review of the governance and financial control environment surrounding regeneration projects. In total, 32 recommendations were raised to enhance the financial control environment at the Council. As part of this audit we sought to verify that actions related to Accounts Payable from the Grant Thornton ‘Review of the Financial Management Relating to CPO Fraud’ have been completed and associated processes are now being complied with. The outcome of this testing is contained within Part 1 of this report.
The review also incorporated the outcome of the separate ‘Payments Data Analytics and Matching Exercises’ reported in February 2019. This included an assessment of whether any further fraudulent payments had been made – to date no further fraudulent payments were found. See Appendix 6 of this report.
Finally, we also followed up audit actions from previous audits in this area. See Appendix 5 of this report.
Due to the far-reaching nature of this review, incorporating the response to the GT action plan, the fieldwork has been undertaken over an extended period from September 2018 to July 2019.
Summary of findings
1. Grant Thornton review – outstanding actions, GT15 and GT16, relevant to AP
GT15 **GT Recommendation:** We recommend that the BACS process be reviewed for the adequacy of controls over new suppliers where there is no purchase order (such as E-form payments).
**Implemented**
For GT15, segregation of duties is now embedded in non-PO payments as follows:
- API E-Form payments authorised by budget manager and independent payment checks (AP) for non-PO (purchase order) OTV (One Time Vendor) and non-PO, non-OTV payments;
- supplier creation / supplier change requests (Service), related independent checks (AP) and related creation/change (CST, IT Integra Support Team) in Integra;
- the separate authorisation of non-API non-PO payments; and
- the provision of adequate supporting documentation for all non-PO payments.
Non-PO API payments are now governed by fit for purpose documented procedures which have been implemented. An API Exemption list has also been completed defining the types of payment and documentation that are exempt from the standard PO route.
**GT 16**
**GT Recommendation:** The Masterfile supporting the BACS payment process does not automatically identify and flag payments made to different suppliers/recipient that had the same bank account number.
**Implemented**
For GT16, the New Supplier and Supplier Amendment Process which has been implemented will:
- mitigate the risk of fraudulent changes to bank details in the manner perpetrated in the recent fraud; and
- mitigate the risk of the creation of fraudulent suppliers with the same bank account.
The creation of new suppliers and changes to vendor bank details are now done by E-Form, the process is segregated and is subject to independent checks by AP prior to update in the system by ICT.
**2. Accounts Payable audit**
This audit has identified 2 high, 4 medium and 1 low risk rated finding relating to the control design and operating effectiveness of the controls in place over Accounts Payable as follows: • **Authorisation of Purchase Orders (POs) (High):** We found that there was no reporting and review process for dual authorisation of purchase orders above £1m as required by the "Dual Authorisation for Payments over £1million Process Note V1.0". For 2/15 purchase orders tested, the related dual authorisation of the purchase orders above £1m was not attached in Integra as required.
• **Manual upload process (High):** Payments, recently to the value of £101m annually, are made through Integra using a manual upload process defined in a process document "Manual Upload BACS Payments Process V1.0". The related process document is not clear as to the type of payments which may be made through the manual upload process and the schedule of manual payment authorisers, referred to in the document, was out of date as it referred to officers who had left the Council/Capita.
• **Duplicate payments (Medium):** Arrangements to identify potential duplicate payments (non-PO and PO) using software, AP Forensics, searching by payment parameters such as value and payee name were in progress, however had not been implemented despite discussions being ongoing since 2018. There was evidence of an existing process being possible identifying duplicate payments, however this had only been run once pending implementation of the new software.
• **Missing supplier invoice (Medium):** In 1/10 (10%) instances of our testing of standard PO payments, the invoice was not attached in Integra when the audit test was done. The invoice was subsequently found to be attached in Integra however only on 26 June 2019, a significant period after it was cleared 5/12/2018 for payment in Integra. We would have expected AP to reject a payment without a supporting invoice.
• **AP training and development (Medium):** CSG Management indicated that a programme of training and development existed for the CSG AP team. The programme involved AP officers completing a training needs assessment in which they recorded their understanding of various related procedure documents. Gaps noted in what they recorded, as compared to the content and purpose of the document, informed their training. We do not have an issue on the design of the process. However, evidence of its operation had been requested by Internal Audit but had not been provided for our review. We can therefore not provide assurance over the effective operation of the control.
• **AP documented procedures (Medium):** We reviewed 14 Intranet procedures relevant to AP processing, findings as follows:
- 10/14 documents were out of date and had not been reviewed or updated in more than two years.
- 4/14 documents had been updated in the course of 2018, but contained information which was out of date around the escalation route for AP Other issues and the current supplier request process.
Other key documents such as the “New Supplier and Supplier Amendment Process V1.0 (16/8/2018)” Appendix 4: “Budget Managers and Superiors” was out of date, for example, it included officers who had left the Council.
• **BACS reconciliation (Low):** Evidence of the daily BACS payment review processes was provided. However, although the process involved the review of payments over £35k and the Listing of BACS payments report was retained for referral, it was not clear how the process, by its design, could mitigate the risk of a fraudulent change(s)/alteration(s) to the BACS file after approval, the specific risk referred to in the agreed terms of reference for the audit.
3. **Follow-up of previous Audit Actions, refer to Appendix 5 for detailed findings** We followed up three recommendations made in the Accounts Payable 2017-18 audit. All actions were considered implemented/completed by 31 March 2019.
4. ‘Payments Data Analytics and Matching Exercises’ (PDAME) reported in February 2019, refer to Appendix 6 for detailed findings
At Audit Committee 22 November 2018 Members raised a query after the GT report was presented about the possibility of other fraudulent payments in Integra i.e. the possibility of similar financial failings occurring in other Services across the council. This prompted internal audit to undertake a data analytics and matching exercise for the LBB Payments Account which involved the identification of matches, for example payments to one vendor but to different bank accounts (such as in the recent fraud), which could relate to potentially fraudulent transactions in a financial environment where controls were weak. Where matches warranted further investigation in terms of being potentially fraudulent or where they highlighted poor data quality for vendor master data, they were referred to CAFT and AP for further review.
A summary of the findings relating to the data matches, referred matches and review findings are set out in Appendix 6.1.
The PDAME identified 11 datasets. Work has been completed with no issues on 5/11 datasets, with work ongoing and approaching completion on 6/11 datasets.
The data matches identified seven bank accounts that had received fraudulent payments; these were already known to CAFT as part of an ongoing fraud investigation. No further transactions reviewed to date have been found to be fraudulent.
The Data Analytics review also raised a number of Observations to be considered which are included within this report at Appendix 6.2. It has been agreed that the AP Finance Business Partner will review the observations as a basis for implementing changes in Integra, in current or future versions/updates based on a risk/cost/benefit analysis.
1. Progress against relevant actions from Grant Thornton’s ‘Review of the Financial Management Relating to CPO Fraud’
| GT Ref | Recommendation | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|----------------|-----------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|-----------------------------------------------------| | GT15 | BACS Process for new suppliers | We recommend that the BACS process be reviewed for the adequacy of controls over new suppliers where there is no purchase order (such as E-form payments). | High, immediate | CSG to review process for one-time vendors, propose improvements and implement. | The process has been submitted and verified, however it has not been possible to test the operating effectiveness of this control, as the control design was not finalised in the testing period. Further testing is required | Not Implemented | Implemented |
**a. Non-PO payment including API E-Forms**
Non-Purchase Order (Non-PO) transactions include payments to:
- One Time Vendors – suppliers paid only once and
- suppliers that may be paid more than once where no purchase order is required. Where a OTV is paid more than once, the payee will now need to be created as a supplier on the Vendor Master File in Integra.
A non-Purchase Order Exemption list has been approved by Finance and communicated to Accounts Payable (AP) defining payments which are exempt from the normal purchase order process. These payments are now processed via electronic API E-forms in the Council’s accounting system, Integra. They are authorised in terms of Integra workflow which is set up to ensure approval in line with the Schemes of Financial Delegation, schemes reviewed routinely and available on the Intranet for referral. Supporting documentation matching the | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------| | | | | | | | payments must be attached with the Integra API E-Form by the Service. | | | | | | | | AP reject payments not using the Integra API E-form. They are also required to ensure that supporting documentation matches the API E-form detail, including the bank details, in terms of the API E-Form Vendor Process V1.0 and reject payments which do not comply. | | | | | | | | Evidence was provided to us confirming that Accounts Payable (AP) were undertaking the API E-Form checks for API payments they were required to undertake in terms of the “API E-Form Vendor Process V1.0” process document. Our sample testing confirmed that bank details per the supporting documentation matched the bank details in Integra. | | | | | | | | Other types of non-PO payments were also reviewed, for example those made through the ControCC and Mosaic interface – the social care systems in Family Services and Adults and Communities - into Integra. These were authorised and supported by sufficient documentation. | | | | | | | | **b. New Suppliers** |
| GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------|
Where suppliers are paid more than once, a vendor account needs to be created in the Integra Vendor Master File. Creation of the new vendor or changes to the vendor details are governed by the “New Supplier and Supplier Amendment Process V1.0”. A Supplier E-Form is:
- created in the Service with supporting documentation including bank details,
- completed by AP after they have conducted detailed supplier checks in terms of the above document and then
- created in the system by ICT.
Evidence was provided to us that AP were undertaking the new supplier and change in bank detail checks they were required to undertake in terms of the “New Supplier and Supplier Amendment Process V1.0” process document. Our testing confirmed that bank details per the supporting documentation provided with the supplier E-Form matched the bank details in Integra.
**Summary**
For GT15, segregation of duties is now embedded in non-PO payments as follows: | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------| | | | | | | | - API E-Form payment authorised by budget manager and independent payment checks (AP) for non-PO (purchase order) OTV (One Time Vendor) and non-PO-non OTV payments and supplier creation / supplier change requests (Service), related independent checks (AP) and related creation/change (CST, IT Integra Support Team) in Integra - the separate authorisation of non-API non-PO payments - the provision of adequate supporting documentation for all payments. | | | | | | | | In terms of the recent fraud where the fraudster changed the bank account details of an existing master file vendor (a solicitor) to his own, this would not be possible through the AP route as the change in bank details would be subject to independent check by AP in terms of the “New Supplier and Supplier Amendment Process V1.0” | | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|---------------------------------------------------------------------| | | | | | | | Related PDAME outcomes - refer to Part 4 for detailed findings on matches and referral findings/progress | | | | | | | | The PDAME identified matches relating to bank details that were referred to CAFT and AP for further review. | | | | | | | | 1.1 Vendors Receiving Payments into Multiple Bank Accounts (non OTV) – matched items related to low risk changes in bank sort code. Matches were not escalated to CAFT/AP for further review. | | | | | | | | 2.1 Amendments to Supplier Bank Details – 13/52 matches were referred to AP and 7/52 matches to CAFT for further review, | | | | | | | | AP: Confirmation of validity of bank account changes resolved for 4/13, in progress for 9/13 | | | | | | | | CAFT: Investigations 7/7 completed without issues. | | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|------------------------------------------------------|-----------------------------------------------------|---------------------------------------------------------------------| | GT16 | Duplicate banking details | Medium | Put in place controls to identify BACS and CHAPS payments made to different suppliers with the same bank account number. There was also no manual control in place to identify BACS and CHAPS payments made to different suppliers which had the same bank accounts. We recommend that this control be considered as an addition to the new Treasury Payment Procedure. | The process has been submitted and verified, however it has not been possible to test the operating effectiveness of these controls, as the control design relating to one-time vendors was not finalised in the testing period, and the e-form used to set up new suppliers within Integra was not yet live within the system. Internal audit has reviewed the process as agreed with GT, but have not yet been able to test this independently. No issues were noted with the operating effectiveness of the checks carried out over the validity of supplier details within the Treasury Payment Process. | Partly Implemented | Implemented | | | | | | | | a. Duplicate banking details (payments to different vendors with the same bank account) | | | | | | | | The New Supplier and Supplier Amendment Process which has been implemented should support mitigation of the risk of creating fraudulent/fictitious vendors in Integra (many suppliers with the same one bank account of the potential fraudster in this instance). The creation of new suppliers is now done by Vendor E-Form, is segregated and is subject to independent checks by AP prior to update in the system by ICT in line with the process. The robust process should therefore deter the creation of fictitious vendors in Integra in the first instance. Supporting detective reporting identifying where payments made to different suppliers/vendors with the same bank account details will be achieved once the software package AP Forensics has been implemented. Commissioning and implementation of the software is being overseen by the Council/Capita AP Task Group responsible for improvements in the financial control environment. | | GT Ref | Recommendation | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|----------------|-----------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|---------------------------------------------------------------------| | | | | | | ce provided around the controls relating to those processes. | | for payments. We understand that procurement and implementation of the software is imminent. The first demonstration of the software has confirmed that such detective reporting will be possible | | | | | | | | | Related PDAME outcomes - refer to Part 4 for detailed findings on matches and referral findings/progress | | | | | | | | | The PDAME identifying matches relating to different vendors having a common bank account were referred to CAFT and AP for further review. | | | | | | | | | 1.2 Multiple Vendors Receiving Payments into Common Accounts – 55/101 matches referred to AP and 7/55 suppliers covering 3 bank accounts were referred to CAFT | | | | | | | | | AP: Investigations resolved no issues for 3/55, In progress 52/55 | | | | | | | | | CAFT: Investigations resolved with no issues for 4 suppliers covering 2 bank accounts, In progress for 3 suppliers covering 1 bank account. | | | | | | | | | 2.2 Multiple Vendors Sharing a Common Bank Account Referred 284 / 296 matches to AP | | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------| | | | | | and 8/296 covering 2 bank accounts to CAFT | AP: 138/284 already resolved deactivated, 146/284 in progress. | | | | | | CAFT: 8 suppliers 2 bank accounts in progress, further information has been submitted to AP for review. | | 4.3 One Time Vendors Receiving Payments into Common Accounts – CAFT have completed checks on Integra. There are some matches which remain unverified and have been escalated to AP for further review and for them to respond with any suspicions. | | b. Misuse of the One-Time-Vendors) OTV process | | There will be occasions when undertaking Council business that one-off payments to persons (OTV) may be required. | | To ensure that officers do not use the One Time Vendor process excessively to bypass the standard PO and vendor creation processes, Integra now recognises when an OTV payment is made to a bank account used for an OTV payment before. In this | | GT Ref | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|------------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|---------------------------------------------------------------------|
case the OTV payment will be rejected and the supplier will then be required to be set up as a vendor in Integra as part of the Vendor Master Data. The creation of the vendor will be subject to the various independent checks referred to in GT 15 above.
Where OTV payments are paid by cheque or to different accounts, the above bank account rejection will not apply. This will be addressed by the introduction of AP Forensics which will allow the rejection of payments based on OTV payee name too. For cheque payments, in the interim, Finance, following discussion with Cash Book team, will investigate whether the CSG team responsible for producing Integra cheque runs will identify where payees paid by cheque have previously been paid by BACS or cheque.
The action is under ongoing review by the Capita/Council AP Task group responsible for improving the control environment over Council payments.
**Action:** | GT Ref | Recommendation | Recommendation detail | Priority | Action | Status reported to Audit Committee 22nd November 2018 | Status reported to Audit Committee 31st January 2019 | Status verbally reported to Audit Committee May (GT16) and July (GT15) 2019 | |--------|----------------|-----------------------|----------|--------|-----------------------------------------------------|-----------------------------------------------------|------------------------------------------------------------------| | | | | | | AP Forensics meeting all user reporting needs will be commissioned and implemented. | | | | | | | | | **Responsible officer:** Acting Head of Finance – Projects | | | | | | | | | **Head of Financial Systems, Capita** | | | | | | | | | **Target date:** 31 August 2019 | | | | | | | | | **Related PDAME outcomes - refer to Part 4 for detailed findings on matches and referral findings/progress** | | | | | | | | | 4.1 One Time Vendors (OTVs) Receiving More than One Payment – in progress, resolved for CAFT no issues (bank accounts correct in relation to suppliers) | | | | | | | | | 4.2 One Time Vendors Receiving Payments into Multiple Bank Accounts – in progress, CAFT have requested further information from AP | | |
## 2. Accounts Payable audit - Findings, Risks and Action Plan
| Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 1 | **Authorisation of purchase orders (PO)**\
Location 6 payments (Standard PO transactions)\
The Dual Authorisation for Payments over £1million Process Note V1.0 requires the dual authorisation of purchase orders over £1m. The process document referred to the quality checking as follows:\
“Quality Checks: A report will be run on a monthly basis for payments over £1million to check the requisitions have the necessary form attached.”\
We found that there was no reporting and review process as stated.\
We tested a sample of 15 payments through location 6 in Integra for which purchase orders were raised. The 3-way match of invoice, goods receipt and PO was evident, however the dual authorisation of 2 / 15 purchase orders was not attached in Integra as required by Dual Authorisation for Payments over £1million Process Note V1.0. | If planned expenditure doesn’t support the Council’s objectives or is not aligned with business needs through the lack of appropriate scrutiny and challenge, for example, if dual authorisation is not obtained for expenditure, where necessary there is a risk of misallocation of finances, budget overspends and resident dissatisfaction. | High | **Capita (non-AP):**\
a(i): A list of purchase orders raised in Integra above £1m will be provided to Council Finance monthly.\
**Responsible officer:**\
Integra team\
**Target date:** 31 October 2019\
**Council Finance**\
a(ii): Finance will ensure that the Dual Authorisation form is completed for all POs above £1m on the monthly list. Finance will ensure that the form is completed correctly in line with the Council Constitution and is attached in Integra for referral.\
**Responsible officer:**\
Acting Head of Finance – Projects\
**Target date:** 31 October 2019\
**Council Finance**\
b(i): Finance will ensure that expenditure with Staples, the supplier replacing Office Depot, is set up in Integra to follow the standard PO route, so the 3-way match of PO, Goods Receipt and invoice, with purchase | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | £3,556.80. We would have expected goods receipting for an invoice of this value. We tested a sample of 8 payments ranging from £50 to £3600 in 2018-19 and 2019-20. In 2/8 cases the PO was not approved by the budget manager referred to in the prevailing Financial Scheme of Delegation (FSoD). Although the transactions are low value, the finding suggests that the Integra approval workflow may potentially not be aligned with the relevant approved SoFD at all times. At the time of this report the Council’s stationery supplier was due to change to Staples from Office Depot. **Family Services authorisation limits in ControCC** In Family Services, we noted that Heads of Service were able to authorise services up to £181,302 as stated in the Family Service Financial Scheme of Delegation within the Children’s Service Scheme of Delegation in the Constitution. However, in LCS, the Family Services social care system, the Heads of Service limit for approving services was set at £250,000. This did not affect our sample tested as commitments selected were all below the £181,302 limit in the Constitution. Family Services Finance provided us with a document, “Authorising spend - what you need to know”, which they used together with the Children’s Service Scheme of Delegation and which referred to the limit of £250,000. Our initial view is that the limits set in ControCC need to be updated at the Head of Service level so that they align with the Constitution and that Finance should review the validity of the document. We have not tested the commitment cost approval levels in Mosaic, the Adults social care system, as our testing related to authorisation at the | | | | order approval in Integra in line with the Financial Scheme of Delegation. **Responsible officer:** Acting Head of Finance – Projects **Target date:** 31 October 2019 **Accounts Payable (AP)** b(ii): Thereafter, Staples invoices will be released for payment following the standard PO route, the 3-way match of invoice, goods receipt and PO. **Responsible officer:** Accounts Payable Manager, Accounts Payable, CSG **Target date:** 31 October 2019 **Council Finance** c. Finance will review the authorisation limits as stated in the “Authorising spend - what you need to know” document, governing the authorisation levels of social care management for approving cost commitments in LCS, the Family Services social care system - set in ControCC, the Family Services financial system - to ensure that they are consistent with the Council’s Constitution. Authorisation limits will be | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | invoice level and matching to commitments. However, a review of the position in Adults and Communities should also be undertaken to ensure that the SoFD and related limits in Mosaic are aligned. | If a payment process facilitates the circumvention of approved payment limits then there is a risk of invalid payments and financial loss. | High | Council Finance | | | | | | a.(i) The Manual upload process will be reviewed and updated to ensure clarity over when this approach is permissible for payments, so which payments may follow the manual upload process. | | | | | | (ii) The process document will be kept up to date. The related authorisation sheet will be reviewed, updated and provided to AP on a quarterly basis as a minimum. AP will be notified of changes to the authorisations immediately, for example, where | | 2. | **Manual upload process (control design and operating effectiveness)** | | | | | | There is a documented procedure for the manual upload process, the ‘Manual Upload BACS Process V1.0’. It is estimated that the money spent via this route annually is circa £100m. The payments are made in Integra in location 2. A review of the document indicated that: | | | | | | - the preamble in the process document was vague in that it stated “This method of paying suppliers is restricted to specific types of payments, and cannot be used to circumvent the standard AP procedures”, however | | | | | | | | | updated in ControCC where applicable. A similar exercise will be done confirming that limits for approving cost commitments/care packages in Mosaic for Adults and Communities are in line with the Constitution. | | | | | | **Responsible officer:** Acting Head of Finance – Projects | | | | | | **Target date:** Implemented (as per management) | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | the list of the ‘specific types of payments’ or the rationale as to why this method needs to be used in each case was not specified. | | | Finance become aware that authorising officers have left the Council. | | | - The Manual Upload BACS Process V1.0 (16/8/2018), paragraph 6, “Master List of Approvers Allowed to Certify” was out of date as it included leavers, for example, xxx, xxx and xxx It is not clear how this list of approvers would be updated or by whom. | | | (iii) The Manual upload process document will emphasize that authorising officer limits must align with the total value of the manual upload payment, referring specifically to the situation where the manual upload is broken down into various payments across more than one budget manager and cost centre. | | | - We are aware of a number of payments initiated on 14/9/18 via this route which were >£25k that had been authorised by someone who only had £25k limit as per this list. Therefore, the payments should not have been made by AP. | | | Responsible officer: Acting Head of Finance – Projects | | | | | | Target date: 31 October 2019 | | | | | | AP | | | | | | AP will reject manual upload requests which do not comply with the updated manual upload process above, for example, where officers authorise total payments outside their defined limits. | | | | | | Responsible officer: Accounts Payable Manager, Accounts Payable, CSG | | | | | | Target date: 31 October 2019 | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 3. | **Duplicate payments**<br>We tested for duplicate payments within our sample across various Integra pay locations since Integra was implemented in 2014. None were noted.<br>Since the GT review, there is now a process in Integra for automatically identifying One Time Vendor (OTV) BACS payments that have been paid to the same bank account in the past. Such payments are rejected and assessed for inclusion of the related payee/supplier in the Integra Master Vendor List to prevent misuse of the OTV payment route by Services.<br>Crystal reporting introduced in September 2018 identifies “fuzzy matches” around supplier number, invoice reference, value and date on a daily basis for potential duplicate payments – refer to Part 3 (Appendix 5) follow-up of past audits – AP 2017-18 (AP4).<br>As part of this audit, we requested evidence of daily duplicate payment reviews, however CSG Management indicated that the report had only been run once when AP undertook, at the Council’s request, a one-off exercise to identify potential duplicate payments. This report was supplied to the Council along with a comment that AP were unable to fully complete this task as the data included interfaces of which AP have no input.<br>Processes to identify duplicate payments on a wider scale across Integra through the commissioning and procurement of software, AP Forensics, is in progress, however has not yet been implemented despite being discussed since 2018. Implementation is being overseen by the Council and Capita AP Task Group established to improve financial controls over | If duplicate payments are made for invoices or activities that have been paid in the past **then** there is a risk of overpayments, budget overspends and resident dissatisfaction | Medium | **Council Finance**<br>a. The implementation of software, AP Forensics (APF), will be expedited in line with Council requirements, to identify potentially duplicate payments based on a variety of agreed criteria such as value, name and bank details.<br>b. The Head of Counter Fraud Operations will be engaged as part of the implementation of the software, as a potential end user of the application.<br>c. Processes for identification, escalation and investigation, clarifying roles and responsibilities and the timing of reports will be documented and communicated.<br>c. Pending implementation of APF, Finance will arrange for the download of the last 3 years of Council payments at the Council through AP Forensics software to identify potentially duplicate payments for investigation. | **Responsible officer:** | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | payments. We understand that the software will allow the identification of duplicate payments through various criteria, for example, value, name and bank details, the full user requirements still to be defined. Pending implementation of AP Forensics, reports identifying duplicate payments are not being run as frequently as necessary in our view. An AP Forensics Demo exercise, involving Council Finance, was undertaken 6 August 2019 to demonstrate its functionality and capabilities. We requested input to assess whether functionality addressed areas below, relevant to AP and GT findings:
1. Robust reviews for duplicate payments on a variety of criteria
2. Identifying repeat OTVs, based on criteria other than OTV BACS payments to the same bank account (currently in place)
3. Detective reporting identifying where payments are made to different suppliers/vendors with the same bank account details, the gist of GT16
4. Detective reporting identifying payments to the same supplier with different bank accounts, so similar to the fraud. Finance confirmed that the AP Forensics tool should meet the above requirements. | If payments are not matched to supplier invoices and attached in Integra as evidence of accurate payment then there is a risk of supplier overpayments and financial loss | Medium | Acting Head of Finance – Projects liaising with Head of Financial Systems, Capita\
Head of Counter Fraud Operations (engage with the AP Forensics implementation process as a potential end user of the software)\
**Target date:**\
31 October 2019 | | 4. | **Missing invoice**\
We tested 10 invoices in location 1 in Integra (Standard POs) for the three-way match of invoice, good receipting and PO. In 1/10 (10%), the invoice (value £858k) was not attached in Integra when the audit test was done. The invoice was subsequently attached 26 June 2019, a significant period after it was cleared, 5/12/2018. We would have expected AP to reject a payment without a supporting invoice, particularly one of such a significant amount. We have reviewed to confirm that the invoice and payment were valid. | | | AP\
The availability of supplier invoices in Integra will be monitored as part of AP reconciliation audit processes. Supplier invoices will be attached in Integra in all cases, where applicable. AP will reject payments where no invoice has been provided and refer them back to the Service. | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | | | | | | 5. | **AP Training and development**<br>AP (CSG) | If gaps in training and development are not identified then there is a risk of processing errors, processes not being followed and payments not being rejected where necessary. | Medium | **AP**<br>Evidence of AP training and development relevant to AP payment processing will be provided for Internal Audit review. AP management will review current training plans and will respond with a proposal for review | | | CSG Management indicated that a programme of training and development existed for the CSG AP team. The programme involved AP officers completing an assessment in which they recorded their understanding of various related procedure documents. Gaps noted in what they recorded informed their training. | | | **Responsible officer:**<br>Accounts Payable Manager, Accounts Payable, CSG<br>**Target date:**<br>31 October 2019 | | | We do not have an issue on the design of the process. Evidence of its operation, for example, the courses assessed, how evaluated and the resulting training identified had been requested by Internal Audit, however at the time of this report had not been provided for our review. | | | **Responsible officer:**<br>Accounts Payable Manager, Accounts Payable, CSG<br>**Target date:**<br>31 October 2019 | | | Internal Audit has right of access to all records governing the Council operations in terms of the Financial Regulations of the Constitution. | | | **Responsible officer:**<br>Accounts Payable Team Leader, CSG<br>**Target date:**<br>31 October 2019 | | | We found that new starters in Council Finance 1 January to date had attended mandatory Integra training which included AP related courses. | | | **Responsible officer:**<br>Accounts Payable Manager, Accounts Payable, CSG<br>**Target date:**<br>31 October 2019 | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 6. | **Documented AP Procedures**<br>a. The following documents relevant to AP processing were noted during the AP review:<br> - API E-Form Vendor Process V1.0" (non-PO transactions)<br> - The API Exemption List (non-PO transactions)<br> - “New Supplier and Supplier Amendment Process V1.0" (non-PO and PO transactions)<br> - the Integra User Guide (PO transactions)<br>We reviewed 14 Intranet procedures relevant to AP – refer to Appendix 4 for detailed review, findings as follows:<br> - 10/14 documents were out of date at the date of testing (07/11/2018) and had not been reviewed or updated in more than two years.<br> - 4/14 documents had been updated in the course of 2018, but contained information which was out of date around the escalation route for AP issues and the current supplier request process.<br>b. We also noted that documents signposted within other documents were not held on the intranet. These included a Requisitions User Guide and some Integra e-forms which aren’t in use at Barnet.<br>c. The “New Supplier and Supplier Amendment Process V1.0 (16/8/2018)” Appendix 4: “Budget Managers and Superiors” was out of date, for example, it included leavers such as xxx, xxx, xxx, xxx and xxx. | If outdated AP procedure documents or procedure documents that are no longer relevant are referred to by responsible officers **then** there is a risk of processing errors, processes not being followed and payments not being rejected where necessary.<br>**If** officers are not aware of all systems interfacing with Integra which may impact AP processes meaning, for example, that relevant reconciliation processes between those systems are not applied **then** there is a risk of inaccurate | **Medium** | **Council Finance**<br>a. All AP procedures will be reviewed, updated and communicated to the relevant finance officers. The Frequently Asked Questions (FAQ) document referring to AP payment arrangements will be finalised and published.<br>b. AP process documents no longer relevant will be removed from the Intranet.<br>c. Finance will engage with the relevant Capita teams to produce flowcharts mapping all Integra interfaces with other systems, for example, Mosaic and ControCC and defining related operation,<br><br>**Note:**<br>Process documents should not include embedded documents which may be subject to change periodically, for example, budget manager lists. The documents should have links to sign | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | d. | The Manual Upload BACS Process V1.0 (16/8/2018), paragraph 6, “Master List of Approvers Allowed to Certify” was out of date as it included leavers, for example, xxx, xxx and xxx. | payments and liabilities in Integra. | posted documents which are also available on the Intranet. | Responsible officer: Acting Head of Finance – Projects, liaising with Capita officers where necessary. Target date: 31 October 2019 | | e. | We were unable locate a document mapping all systems interfacing with Integra, specifically impacting AP. We satisfactorily tested interface reconciliations between Integra and Mosaic - the Adults Social Care system - and ControCC - the Family Services Social Care system. We were however unclear, for example, around the Council’s Integra interfaces with other systems such as those used in Housing. | | | | | 7. | **BACS reconciliation (design)** Evidence of the daily BACS payment review processes was provided. However, although the process involved the review of payments over £35k and the Listing of BACS payments report was retained for referral, it was not clear how the process, by design, could mitigate the risk of a fraudulent change(s)/alteration(s) to the BACS file after approval, the specific risk referred to in the audit term of reference, without evidence of a formal reconciliation between BACS summary reports and the related Integra payment files. Our expectation was that BACS summary reports would be reconciled to relevant payment files after release, similar to the payroll control process where the BACS payroll file is reconciled the Net Pay system file. | If the BACS payments file is altered/changed prior to release without authorisation then there is risk of overpayments and financial loss. | Low | Council Finance The BACS file review will include a process to ensure that the BACS file has not been altered after approval, for example, a check that the amount taken from the bank account matches the amount of the approved payment run. Responsible officer: Acting Head of Finance – Projects Target date: 31 October 2019 | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | | | | | | | | | | | | | | | | |
### Appendix 1: Definition of risk categories and assurance levels in the Executive Summary
Note: the criteria should be treated as examples, not an exhaustive list. There may be other considerations based on context and auditor judgement.
| Risk rating | Immediate and significant action required. A finding that could cause: | |-------------|---------------------------------------------------------------------| | Critical | • Life threatening or multiple serious injuries or prolonged workplace stress. Severe impact on morale & service performance (eg mass strike actions); or | | | • Critical impact on the reputation or brand of the organisation which could threaten its future viability. Intense political and media scrutiny (i.e. front-page headlines, TV). | | | • Possible criminal or high profile civil action against the Council, members or officers; or | | | • Cessation of core activities, strategies not consistent with government’s agenda, trends show service is degraded. Failure of major projects, elected Members & Senior Directors are required to intervene; or | | | • Major financial loss, significant, material increase on project budget/cost. Statutory intervention triggered. Impact the whole Council. Critical breach in laws and regulations that could result in material fines or consequences. | | High | Action required promptly and to commence as soon as practicable where significant changes are necessary. A finding that could cause: | | | • Serious injuries or stressful experience requiring medical many workdays lost. Major impact on morale & performance of staff; or | | | • Significant impact on the reputation or brand of the organisation. Scrutiny required by external agencies, inspectorates, regulators etc. Unfavourable external media coverage. Noticeable impact on public opinion; or | | | • Significant disruption of core activities. Key targets missed, some services compromised. Management action required to overcome medium-term difficulties; or | | | • High financial loss, significant increase on project budget/cost. Service budgets exceeded. Significant breach in laws and regulations resulting in significant fines and consequences. | | Medium | A finding that could cause: | | | • Injuries or stress level requiring some medical treatment, potentially some workdays lost. Some impact on morale & performance of staff; or | | | • Moderate impact on the reputation or brand of the organisation. Scrutiny required by internal committees or internal audit to prevent escalation. Probable limited unfavourable media coverage; or | | | • Significant short-term disruption of non-core activities. Standing orders occasionally not complied with, or services do not fully meet needs. Service action will be required; or | | | • Medium financial loss, small increase on project budget/cost. Handled within the team. Moderate breach in laws and regulations resulting in fines and consequences. | | Low | A finding that could cause: | | | • Minor injuries or stress with no workdays lost or minimal medical treatment, no impact on staff morale; or | | | • Minor impact on the reputation of the organisation; or | | | • Minor errors in systems/operations or processes requiring action or minor delay without impact on overall schedule; or | | | • Handled within normal day to day routines; or | | | • Minimal financial loss, minimal effect on project budget/cost. |
| Level of assurance | | |--------------------|---------------------------------------------------------------------| | Substantial | There is a sound control environment with risks to key service objectives being reasonably managed. Any deficiencies identified are not cause for major concern. Recommendations will normally only be Advice and Best Practice. | | Reasonable | An adequate control framework is in place but there are weaknesses which may put some service objectives at risk. There are Medium priority recommendations indicating weaknesses but these do not undermine the system’s overall integrity. Any Critical recommendation will prevent this assessment, and any High recommendations would need to be mitigated by significant strengths elsewhere. | | Limited | There are a number of significant control weaknesses which could put the achievement of key service objectives at risk and result in error, fraud, loss or reputational damage. There are High recommendations indicating significant failings. Any Critical recommendations would need to be mitigated by significant strengths elsewhere. | | No | There are fundamental weaknesses in the control environment which jeopardise the achievement of key service objectives and could lead to significant risk of error, fraud, loss or reputational damage being suffered. | Appendix 2 – Analysis of findings
| Area | Critical | High | Medium | Low | Total | |--------------------|----------|------|--------|-----|-------| | | D | OE | D | OE | D | OE | D | OE | | | Accounts Payable | - | - | 1 | 1 | - | 4 | 1 | - | 7 | | Total | - | - | 1 | 1 | - | 4 | 1 | - | 7 |
Key:
- Control Design Issue (D) – There is no control in place or the design of the control in place is not sufficient to mitigate the potential risks in this area.
- Operating Effectiveness Issue (OE) – Control design is adequate, however the control is not operating as intended resulting in potential risks arising in this area.
Timetable
| Terms of reference agreed: | Fieldwork commenced: | Fieldwork completed: | Draft report issued: | Management comments received: | Final report issued: | |---------------------------|----------------------|----------------------|----------------------|-------------------------------|---------------------| | 14 August 2018 | 03 September 2018 | 25 July 2019 | 12 August 2019 | 22 August 2019 / 3 September 2019 / 4 September 2019 (AP) Various responses 13 August 2019 – 23 August 2019 / 3 September 2019 (Council Finance) 17 September 2019 (Exit meeting) | 01 October 2019 |
## Appendix 3 – Identified controls
| Area | Objective | Risks | Identified Controls | |--------------------|---------------------------------------------------------------------------|----------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------| | Accounts Payable | Liabilities are accurately and completely recorded in the underlying accounts | Manual posting error to the general ledger | Three-way check of invoice, goods receipting documentation and POs | | | | Automated posting errors occur between the two interfaces | An API Exemption List has been developed defining the type of payments which may bypass the standard PO process, including the expected supporting documentation and criteria, including value, which AP should expect, failing which payment will be rejected. | | | | | API E-Form Process payments specifying AP checks to supporting documentation. | | | | | AP checks of API payments to supporting documentation. | | | | | Monthly reconciliation of AP control account to AP creditors ledger, including independent review. | | | | | Reconciliations between Integra and ControCC/Mosaic interface payment files. | | | | | Council/Capita AP Task group has been set-up, responsible for improving overall financial controls relating to payment processing. | | | All liabilities are correctly valued and relate to legitimate expenditure-related transactions | Expenditure may be incurred for goods or services that have not been received and/or do not pertain to the organisation | See above | | All expenditure incurred relates to legitimate services or goods, and evidence exists to verify that these services or goods have been provided. Note: testing will cover the whole transaction lifecycle i.e. that the transaction has been appropriately raised and authorised within the delivery unit in question. | Fraudulent payments may be made by staff for unauthorised goods and services. Processing errors are not identified and remedied in time to prevent financial loss to the Council. Non-procurement payments are made without appropriate authorisation. | Three-way match of PO payments. Non-PO payments, OTV and non-OTV, are governed by communicated fit for purpose documented procedures and followed. BACS reconciliation reviews by Integra Finance involve the independent checks of payments over £35k. API E-Form payments governed by API E-Form Vendor process. Authorisation is done by the SoFD budget managers. Council/Capita AP Task group has been set-up, responsible for improving financial controls relating to payment processing. | | --- | --- | --- | | Potential duplicate payments are identified and investigated. | Duplicate payments are made resulting in financial loss. | Commissioning and implementation of AP Forensics in progress, managed by the Council/Capita AP Task group responsible for improving financial controls relating to payment processing. Existing crystal reporting of “fuzzy” matches. | | Invoices and payments relate to valid suppliers. | Fictitious suppliers have been created or duplicate suppliers have been set up. Changes to supplier details, including bank details, are erroneously or fraudulently made. Repeat suppliers are not appropriately set up as suppliers within the system. | Fit for purpose documented communicated process for creating and changing supplier details in Integra, New Supplier and Supplier Amendment Process V1.0”. The process referred to the creation of new suppliers and changing bank details. New Suppliers now requested via E-Form and follow a segregated creation process with supporting documentation. AP checks being done on new suppliers and change to bank details in line with the above process document, refer to GT 15 summary, above. OTV BACS payments made to suppliers more than once and paid to the same bank account are identified by Integra, investigated and escalated for creation as a supplier in Integra (Vendor Master Data). | | Payments are accurately made | Changes to the BACs payment runs are fraudulently made\
The migration of the BACs payment could be corrupted in transfer from one system to the other\
Suppliers are not paid or are paid late, leading to damaged supplier relationships | BACS reconciliation process involves the check of payments over £35k and the retention of the BACS files.\
There is a late payment KPI within the contract, subject to monitoring by the Performance Team.\
FI PI 33: Ninety-five per cent (95%) of local companies are paid within ten (10) Business Days and all other companies within thirty (30) Business Days: Target 95%, June 2019 (Actual: 93.7%), trend target missed\
FI PI 33b: Ninety-five per cent (95%) of all other companies within thirty (30) Business Days: Target 95%, June 2019 (Actual: 100%), trend is target achieved\
The Corporate Performance team has the residual risk of “Supplier Non-Payment” (non-or late payment) at score 8 and there is an improvement place which is being monitored.\
General controls ensuring accurate payments noted above\
Three-way check of invoice, goods receipting documentation and POs\
An API Exemption List has been developed defining the type of payments which may bypass the standard PO process, including the expected supporting documentation and criteria, including value, which AP should expect, failing which payment will be rejected.\
API E-Form Process payments specifying AP checks to supporting documentation. AP checks of API payments to supporting documentation | | Staff are aware of up to date policies and procedures in relation to Accounts Payable | Employees are not aware of the policies and procedures around the accounts payable process and therefore do not follow the correct procedure | The following documents relevant to AP processing were noted during the AP review:
- This guidance has been replaced with "API E-Form Vendor Process V1.0"
- The API Exemption List
- "New Supplier and Supplier Amendment Process V1.0"
- the Integra User Guide (PO transactions)\
The process documents cover the non-PO and PO AP processes.\
The AP control reconciliation process is referred to in the Control Account process document (referred to in the General Ledger audit, 2018-19) | | Accounts Payable feeder systems are clearly mapped and access to them is appropriately restricted | Payments are authorised within feeder systems which should not be authorised\
Feeder systems are not reconciled to the AP sub-ledger and general ledger | GT15 involved the review of Mosaic/ControCC payments. Invoices are reconciled by Adults and Family Services Finance teams to authorised commitments in the relevant social care system. In Family Services, commitments are independently authorised by social care managers/Heads/Directors of Service in social care system in line with limits before transfer to ControCC, the Family Services Payment system. In Adults, the commitment costs are independently approved by senior Social Care Managers (at Panel) before commitments transfer to Mosaic for the system for paying invoices.\
Responsibility for reconciliation between ControCC/Mosaic and Integra is clear and allocated. There was evidence that reconciliations were undertaken. | | All payments are requested and authorised in line with the Scheme of Delegation and Financial Authorisation | Payments are fraudulently or accidentally authorised by people who should not be able to authorise them | The workflow in Integra is designed to ensure that non-PO payments and purchase orders are approved by the budget manager in line with the prevailing Financial Scheme of Delegation (query raised above) | |---|---|---| | E-form design and use supports efficiencies in payment processing | If e-forms are badly designed or misused, payments may be authorised or made inappropriately and records of transactions may not be appropriately maintained. | The API E-Form and New Supplier and Supplier Amendment E-Form is referred to in related procedure documents. The process embedded checks of validity by AP. | Appendix 4 – Accounts Payable procedure documents review
AP process documents on the Intranet were reviewed to ensure that they were accurate.
| Title | Date | Comments | Status at the date of the AP draft report and action | |--------------------------------------------|----------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|------------------------------------------------------| | Changes to the supplier payment process | 16/10/2014 | This process is out of date, as the team responsible for processing invoices once they've been scanned by the mailroom are no longer based at Barnet and are instead based in Chichester. This page outlines the interim processes in place in 2014, and as such should be replaced with an updated supplier payment process. | Action: The process will be updated as necessary and communicated, including saving it to the Council's Intranet | | Title | Date | Comments | Status at the date of the AP draft report and action | |-------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------| | 2 | Integra 2 - E-Forms Guidance | 11/08/2015 The e-forms guidance references multiple e-forms which aren't used by LB Barnet staff:\
• New Vendor Request Form – Set up a new vendor on the system in order to raise PO's (this has only been available to staff since 05/11/18)\
• New Contract/Contract Variation Form – Create a new or vary an existing contract on Integra\
• Framework Order Form – Set up profiled payments for a particular vendor\
There is a section on the API e-forms which states that users need to check:\
• Does the requirement appear on the exemptions list?\
• Will the requirement be a one-off payment?\
• Can the requirement be paid by an alternative method, i.e. P-card or Purchase Order\
The API workflow is shown as USER > LINE MANAGER > PROCUREMENT > ACCOUNTS PAYABLE, which is in line with known process.\
The guidance is limited to this and telling people how to access the forms in Integra.\
The guidance has not been updated for more than three years, and does not reflect the current available e-forms. | This guidance has been replaced with "API E-Form Vendor Process V1.0" and "New Supplier and Supplier Amendment Process V1.0"\
**Action:** Process documents no longer relevant will be removed from the Intranet. | | 3 | API Debit E-Form Guidance | 11/08/2015 This is a step by step guide to using the API debit e-form, and is in line with process. However, it doesn't give any information to the user about when it is appropriate to use an API debit e-form. The guidance has not been updated for more than three years and is currently under review. | This guidance has been replaced with "API E-Form Vendor Process V1.0".\
An API Exemption list has been approved, documented and communicated to all relevant parties, including AP. | | Title | Date | Comments | Status at the date of the AP draft report and action | |-----------------------|------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------| | 4 FAQs | 03/02/2016 | This was guidance issued at the point of the 2016 relocation of the Accounts Payable service to ensure staff knew what the changes would entail. The information about the complaints procedure states that any escalation should be referred to xxx. As such, this guidance needs to be updated in the wake of his departure. | **Action:** Process documents no longer relevant will be removed from the Intranet. | | 5 Supplier Adoption | 03/02/2016 | This process is out of date and has been superseded by the supplier creation process linked below. It references a 2015/16 pilot of an e-Form within Integra, and describes the process for using this and states that the e-form will supersede paper forms as of 01/04/2016 if the pilot is successful. However, as paper forms are still in place at the date of this audit (October 2018), it does not seem that the pilot was successful. As such, this page should have been removed from the intranet at the point where it was decided that the e-form would not be used. | **Action:** The process will be updated as necessary and communicated, including saving it to the Council's Intranet. **This guidance has been replaced with “New Supplier and Supplier Amendment Process V1.0”** **Action:** Process documents no longer relevant will be removed from the Intranet. | | Title | Date | Comments | Status at the date of the AP draft report and action | |------------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------| | 6 No PO, No Pay | 03/02/2016 | The Council's No PO, No Pay policy reflects the requirements of the Council's financial regulations around POs. The only exceptions noted are around SWIFT payments from Family Services and Adult Social Care and: - contracts under seal or documented by the Head of Legal/Director of HB Law (joint Legal Service) which do not require subsequent orders to be placed - gas, water, electricity, telephones, periodical payments and annual subscriptions - cash purchases properly defrayed from loan accounts or advances from petty cash This document does not cover other forms of no PO transactions (like those on the exempt list), and has not been updated since February 2016. | Action: The process will be updated as necessary and communicated, including saving it to the Council’s Intranet | | 7 Electronic API and Debit Notes | 03/02/2016 | This is the covering note for the guidance which was created at the point of the roll-out of the electronic API form. It states that any queries should be referred to xxx. As such, this guidance needs to be updated in the wake of his departure. | This guidance has been replaced with "API E-Form Vendor Process V1.0". An API Exemption list has been approved, documented and communicated to all relevant parties, including AP. Action: Process documents no longer relevant will be removed from the Intranet. | | Title | Date | Comments | Status at the date of the AP draft report and action | |-------------------------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------------------------------------------| | 8 Vendor Set-Up E-Form Process Map | 03/02/2016 | The supplier e-form process map describes the e-form process in place for new suppliers. There are limitations with the process, as it does not include any verification of whether the supplier is a duplicate supplier. Additionally, the process was not adopted at the point where this process map was made, and until now, new supplier set-up has taken place on paper forms. This process map has not been updated since February 2016 and may therefore be out of date in the new Integra system. A new process has been instituted, and as such this may need to be re-mapped. | This guidance has been replaced with “New Supplier and Supplier Amendment Process V1.0” | | 9 New Vendor E-Form User Guide | 03/02/2016 | This is a step by step guide to using the new vendor e-form. However, the use of the new vendor e-form was not rolled out across the council at this time. The guidance has not been updated for more than three years, and a new process has been instituted for vendor set-up (see Supplier Creation below). As such, this has been superseded. | This guidance has been replaced with “New Supplier and Supplier Amendment Process V1.0” | | | | **Action**: Process documents no longer relevant will be removed from the Intranet. | | | 10 Accounts Payable - New Processes | 01/06/2018 | While this page has been recently updated, it names xxx as key contact for queries and issues and as such needs to be updated in the wake of her departure. | **Action**: The process will be updated as necessary and communicated, including saving it to the Council’s Intranet. | | 11 Supplier Creation | 02/07/2018 | This is the paper-based process for the creation of new suppliers. It was superseded by e-forms for supplier set-up on 05/11/18 | This guidance has been replaced with “New Supplier and Supplier Amendment Process V1.0” | | | | **Action**: Process documents no longer relevant will be removed from the Intranet. | | | Title | Date | Comments | Status at the date of the AP draft report and action | |------------------------------|------------|----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------| | 12 New Vendor Form | 02/07/2018 | This is the paper-based form for the creation of new suppliers. It was superseded by e-forms for supplier set-up on 05/11/18. This guidance has been replaced with “New Supplier and Supplier Amendment Process V1.0” | | | 13 API exemptions list | 13/09/2016 | This list is not linked to on the Accounts Payable pages, and was found by searching the intranet. It is held within the Procurement pages. The Accounts Payable team at Chichester did not have access to a copy. The form states that it can be used for “small value one-off vendors”, but does not define small value. It can be assumed that this is lower than £25k, at which point a contract is required under the Contract Procedure Rules, but it’s not clear whether the cut-off is as low as £10k, the highest value at which no evidence of multiple competitive quotations is required. An API Exemption list has been approved, documented and communicated to all relevant parties, including AP. **Action:** Process documents no longer relevant will be removed from the Intranet. | | | 14 Integra FAQ 0.2 | 04/07/2018 | This document responds to FAQs. The document is out of date as it does not reflect the new supplier request process, and names xxx as a key contact for escalation. It also refers users to a **Requisitions User Guide** which is not linked to on the intranet. **Action:** The process will be updated as necessary and communicated, including saving it to the Council’s Intranet. | |
### Appendix 5: Follow-up of past audits – Accounts Payable 2017-18
| Ref | Finding | Risk rating | Recommendation | Responsible officer | Due date | Outcome of follow-up | |-----|---------|-------------|----------------|---------------------|----------|----------------------| | AP4 | Accounts Payable – Potential Duplicate Payments | High | 1) CSG Finance will investigate the introduction of third-party software or fit for purpose automated controls will be built into the system to identify, report and prevent duplicate payments. This will include identifying where attempts are made to progress duplicate invoice numbers for payment and a formal exception reporting and resolution process. | Head of Exchequer Services, CSG | 31/07/2018 | In interviews with the AP team, it was confirmed that the fuzzy match is now in place within the AP workflow, and that potential duplicates are investigated before any payments are released. We requested copies of the fuzzy match for given dates and were provided with these. We verified that the creation date of the reports matched the dates requested, and that the report included a column to record the outcome of the assessment by the AP team of whether the potential matches were real duplicates or not. We reviewed the parameters of the fuzzy match, and agreed that they are sufficient to identify potential duplicates. This meets the requirement within the audit recommendation for a fit-for-purpose automated control within the system. Discussions about the use of AP Forensics are ongoing. We were provided with evidence that a historic fuzzy report was completed for both Barnet and Cambridge Education in August 2018. This identified duplicate payments for Barnet (£11k) and for CE (£0.5k) and the recovery process has been started for these by the Accounts Payable Team. Note: AP Forensics has still not been implemented therefore we have raised this as a medium risk rated finding above, refer to paragraph 3 (Finding 3) | Complete | to possible duplications. However, a high volume of potential matches is received from the NFI making it difficult to identify any true duplicate and CAFT have found that the high number of false duplicates identified make it uneconomical to investigate these transactions. Due to the same data issues, the Accounts Payable team have not been able to perform their own review of data to identify duplicate invoices submitted for payment.
2. Working with relevant stakeholders, including Commissioning Group Finance, CAFT, CSG procurement and delivery units, a data cleanse of Integra vendor data will be performed to ensure that the data is of an appropriate quality to successfully support the automated controls (1) and also the NFI and/or other data matching exercises - including in house exercises. These actions (1) and (2) will be completed well in advance of the next NFI data uploads in September 2018.
Management were able to demonstrate that a historic exercise has been carried out by the Accounts Payable team to identify and investigate suppliers who share bank details. This exercise found 286 bank accounts which were attached to more than one supplier. An investigation was carried out into the root cause of the duplication, which revealed that a large number of these potential duplications were legitimate cases of multiple suppliers sharing a bank account (e.g. multiple family members using a single bank account), but that there were instances where supplier accounts had been duplicated. Additionally, a report was run of suppliers not used in the last 18 months. As a result of these two exercises, a list of 88 duplicate and 134 dormant suppliers to be deleted from Integra has been generated. However, no evidence was provided to show that the agreed cleansing has taken place. Management confirmed that this has now been approved and stated that a data cleansing exercise will be carried out as soon as possible.
We have seen evidence that the NFI data upload took place on 18/10/18. As a result, this data cleansing exercise will be too late to influence the efficiency of the NFI data matching exercise.
| AP7 | BACs Reconciliation | Control operating effectiveness – High risk | High | 1) We will retain evidence of the preparation of each BACS run to ensure that there is Head of Exchequer Services, CSG | 30/04/2018 | We have reviewed a process note, which demonstrates that the Operational Team in CSG Finance receives an e-mail from Integra Team at Capita Local Government Services advising that the PRL610 (which Complete | were found. Each BACS run is prepared by the AP team and then sent to the Capita Group Payments team who confirm the total amount paid by email. While management were able to provide the confirmation emails from Capita, they were not able to provide us with evidence of the preparation of the BACS report or evidence that the BACS amount has been agreed to the confirmation email so we have been unable to confirm appropriate segregation of duties.
an audit trail to demonstrate appropriate segregation of duties.
is the BACS run) has been run and is ready to check. A member of the Operational Team runs a report showing the total BACS run and another showing payments to suppliers which include invoices over £35k. The invoices over £35k are printed and both reports are given to one of the approved signatories in CSG Finance to check and sign. The Operational Team then reply to Integra Team at Capita Local Government Services advising that the BACS has been checked and is ok to process. A copy of the BACS report is printed, signed and then retained in a folder maintained by the CSG Finance team. We reviewed evidence that this process was followed on a sample of named days and were provided with evidence that the process is operating in accordance with the process note and that supporting information is retained.
July 2018 Audit Committee update:
Management confirmed that evidence now remains within the Integra system and that there is inbuilt segregation of duties due to the separate teams that are involved in file transmission. Additionally, once the Payment Production Report/Update has been run in Integra it cannot be amended.
Note: We have raised a low risk rated action for BACS reconciliation above, paragraph 3 Finding 7. | AP8 | **Policies, Procedures and Process notes**\
All policies and procedures are held in hard copy within a physical folder within the AP team work area at the Council. The majority of Accounts Payable processing is undertaken remotely in Sussex and Darlington; management should ensure all policies and procedures are uploaded to an appropriate shared drive so employees have remote access to all relevant documents. | **Medium** | 1) We will ensure that up to date procedure and process documents are made available to all relevant CSG and Capita staff. | **Head of Exchequer Services, CSG** | **31/03/2018** | Key Accounts Payable and Treasury processes have been through an extensive update and approval process in 2018. These are:
- Treasury Payment Process
- Manual Uploads for BACS Payments
- New Supplier and Supplier Amendments
- API process\
The documents have been shared with staff as they have gone live, and as such, this action is deemed complete.
**Note:** We have raised a medium risk rated action for the review and update of policies and procedures above, paragraph 3, Finding 6, as some procedures are out of date at the date of the draft report. | **Complete** | Appendix 6.1: Outcome of detailed testing from ‘Payments Data Analytics and Matching Exercises’ (PDAME), reported in February 2019: | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |--------|---------------------------------------------------------------------------|--------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------|-----------------|-----------------------------| | 1.1 | Vendors Receiving Payments into Multiple Bank Accounts (excluding one-time vendor supplier codes, where this is expected) | 291 of 4758 unique vendor numbers (6.1%) | Manual review of all transactions carried out, which identified that all changes of account number have been correctly identified through the testing for 2.1 (see below). The remaining items identified for review are due to changes to sort code. These changes are part of a national exercise where major banks have changed sort codes to ringfence business from personal banking. We used an online sort code checker to verify that where the first two digits of the sort code (the bank identifier) were not the same, these were still the same entities. [https://www.sortcodes.co.uk/checker.html](https://www.sortcodes.co.uk/checker.html) | N/A - all changes are sort code changes and in line with expectations. | N/A - no changes need to be referred to CAFT which haven't already been referred under 2.1. | N/A | | 1.2 | Multiple Vendors Receiving Payments into Common Accounts | 101 of 6515 unique vendor numbers (1.6%) | Manual review carried out to verify whether multiple suppliers using the same bank accounts is appropriate.\
**AP**\
55 potentially duplicate suppliers sharing 27 bank accounts have been referred to AP for further investigation and deletion if found to be genuine duplicates.\
**CAFT**\
Where suppliers who do not have any clear link are identified, refer to CAFT for further investigation in case accounts are fraudulent. CAFT to verify the 55 potential duplicate suppliers across 27 bank accounts\
Resolved: 3/55 suppliers de-activated in Integra\
In progress: 52/55\
7 suppliers across 3 bank accounts\
a. Resolved (no fraud implications), 2 bank accounts covering 4 suppliers\
b. In progress: For 1 bank account covering 3 suppliers, below, request sent to AP for further information, awaiting response: | AP to resolve for deletion, where applicable, the remaining 52 matches. | AP to respond to further request for information from CAFT in relation to the one | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|-----------------|-----------------------------| | 1.3 | Vendors Receiving Payments into Bank Accounts Linked with Council or Capita Employees\* | 2 of 6515 unique bank account numbers (0.01%) | Payments relate to fostering and adoption. | N/A | Payments to 2 bank accounts to confirm that two employees are foster carers/adopters and therefore entitled to ongoing payments. CAFT have completed investigation – no issues noted | N/A | | 2.1 | Amendments to Supplier Bank Details | 52 of 306 changes to | Manual review of all exceptions carried out. CAFT | Amendments to bank | Amendments to bank accounts for 7 suppliers | AP to confirm that changes | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|----------------|-----------------------------| | | bank accounts details (17.0%) | Referred 7 suppliers with temporary bank account changes, where payments were made, to CAFT to confirm that they were to accounts held by the individuals/organisations linked with them. AP Where there was no supporting documentation demonstrating that this is a valid change that has been requested by the supplier (totalling 24 bank detail changes), AP asked to confirm directly with the 13 suppliers that the current bank details in the system are correct. | accounts for 13 Suppliers a. Amendments to bank details for 4/13 resolved as correct by AP. b. Confirmation by AP that changes to bank details were correct for 9/13 suppliers still in progress. | a. Resolved: Amendments to bank details of 7/7 suppliers considered valid and non-fraudulent | to bank details for 9/13 suppliers are correct in Integra. Responsible officer: Accounts Payable Manager, Accounts Payable, CSG Target date: 1 October 2019 | | 2.2 | Multiple Vendors Sharing a Common Bank Account | 296 of 11,318 distinct supplier numbers in master data (2.6%) | All bank accounts shared by 3 or more vendors were reviewed in detail including a review of payments made in the period. For all bank accounts with 2 suppliers, names/addresses were reviewed to assess whether reasonable. The volume of such suppliers makes it not practical to review them at transaction level if there’s a clear link by name or address between them. | Referred 284 potential duplicate or dormant suppliers who should be made inactive. | Referred 8 suppliers across 2 bank accounts, 6 vendors share one account and 2 vendors share one account. a. 8 suppliers across 2 bank | AP AP to confirm that deactivation where appropriate for 146/284 vendors sharing | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|----------------|-----------------------------| | | | | AP | a. 138/284 already deactivated. | accounts in progress. CAFT have requested further information from AP, Investigations cannot continue until this is received | common bank accounts. AP to respond to further request for information from CAFT in relation to two outstanding bank accounts. | | | | | CAFT | b. 146/284 in progress. Final queries. | | Responsible officer: Accounts Payable Manager, Accounts Payable, CSG | | | | | | | | Target date: 1 October 2019 | | 2.3 | Multiple Vendors Sharing one or more Email Addresses/Telephone Numbers | 3140 (email addresses) and 2586 (telephone numbers) of 11,318 distinct supplier numbers in master data (27.7% and | Based on an initial review of the outputs of this test, the majority of shared email addresses were generic emails at companies and there was a clear link between the suppliers sharing contact details. There were no indications that an investigation of shared contact details would provide additional information on top of the testing carried out on 1.2 and 2.2, where vendors shared bank accounts. | N/A | N/A | N/A | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|-----------------|-----------------------------| | 3.1 | Vendors Sharing Either: Bank Accounts, Email Addresses or Telephone Numbers with Council or Capita Employees (On Transactional Data)\* | 198 of 4761 vendor numbers (4.2%) | Any false matches (i.e. Building Society paying in accounts shared by multiple vendors/staff) were removed. **AP** 12 suppliers were identified as also being employees or sharing bank accounts with employees but had not been paid through this route since 2016 (at the latest) or had not been paid at all. To minimise the risk of fraudulent activity, these dormant suppliers should be deactivated in Integra. **CAFT** Payments were reviewed to assess whether they should be investigated further by CAFT. One vendor was referred to CAFT for them to verify that the payee is a care leaver. | 12 supplier matches 12/12 resolved no issues | 1 supplier match / to verify with originating service that payments made to the one vendor are legitimate due to them being a care leaver. Resolved no issues | N/A | | 4.1 | One Time Vendors (OTVs) Receiving | 389 of 2919 OTV | Of the 389 ‘OTVs’ receiving multiple payments, the number of repeat payments were RAG rated as follows: | 389 matches | 389 matches a. 389 /389 resolved – covered | **AP** AP to confirm which matches have been set | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|----------------|-----------------------------| | | More than One Payment transactions (13.3%) | | | | | | | | | More than 6 | 33 | | | | | | | Between 3 and 5 | 112 | | | | | | | 2 | 244 | | | | | | | Total | 389 | | | |
Internal Audit work on GT15 confirmed that at the time there were no controls in place to prevent repeat one-time vendor transactions or to verify the validity of OTV payee bank details.
**AP**
AP asked to confirm which of the 389 ‘OTVs’ have now been set up as suppliers.
**CAFT**
CAFT to review 389 matches, checking for any names already known to CAFT and that related bank accounts do belong to the same supplier.
CAFT to review the outcome of the AP analysis (i.e. which ‘OTVs’ have not yet been set up as a supplier which involves more stringent controls).
No feedback at the date of the draft report.
in 4.3. – no issues, for example OTV, that were identified as having two names to one account were checked and have links so no issues.
Some fraudulent payments that CAFT were already aware of as part of different Fraud investigation show up in this match.
up as suppliers and escalate related suspicious activity to CAFT where applicable.
**Responsible officer:** Accounts Payable Manager, Accounts Payable, CSG
**Target date:** 1 October 2019 | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|----------------|-----------------------------| | 4.2 | One Time Vendors Receiving Payments into Multiple Bank Accounts | 96 of 2152 unique bank accounts receiving payments (4.5%) | Of 96 unique bank accounts used, Internal Audit (IA) reviewed a sample of 44 (46%) and 52 (54%) were not reviewed. 22 (50%) were due to an inputting error having been made (e.g. an incorrect digit in a bank account number). We confirmed that no successful invalid payments had been made as a result. **AP** 8 (18%) were referred to AP to confirm that invalid payments were not made (totalling £3,996 in value). AP were able to provide assurance over £325 of this amount but for the remaining three payments ‘All payments were done via a OTV & were processed as API's / pre-authorised payments. AP not advised of any BACS rejects’ For 52 bank accounts not checked by IA, AP asked to provide any information available from when vendors were set up. **CAFT** 8/8 referred to AP, above, were also referred to CAFT to confirm that the accounts belonged to the same payee. CAFT to review the outcome of the AP analysis (i.e. any supporting documents from when ‘OTVs’ were set up). | 8 bank accounts 52 bank accounts not checked by IA a. Matches relating to 8 bank accounts covering £325 / £3,996 (8%) resolved – no issues as to validity of payments (2 bank accounts), remaining 6 bank accounts referred to CAFT b. Matches relating to 52 bank accounts | 72 bank accounts referred to CAFT consisting of 20 reviewed as part of the sample 44 and 52 not part of the sample reviewed by Internal Audit. a. OTV payments to 9/72 bank accounts resolved no issues. Further 5 already known to be Fraudulent as part of on-going CAFT investigation b. OTV payments covering remaining 58 bank accounts may need to be checked pending AP response if any raise suspicions of Fraud | **AP** AP to complete the review of 52 matches **Responsible officer:** Accounts Payable Manager, Accounts Payable, CSG **Target date:** 1 October 2019 | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|-----------------|-----------------------------| | | | | If there is no evidence via that route, then CAFT to consider use of the POCA powers and if possible/practical, for example, under a financial investigation, to obtain relevant information. 14 (32%) were referred to CAFT to confirm that the accounts belonged to the same payee. The remaining 52 unique bank accounts used, which were not reviewed by Internal Audit in detail, were referred to CAFT to confirm that the accounts belonged to the same payee. | CAFT requested further information from AP. Explanation to be provided as to why one supplier has more than one account. To provide evidence for each supplier as Integra does not show invoices. | N/A | 77 bank accounts shared by 260 OTVs reviewed\
a. Resolved no issues 56/77 - links between vendors with different names were established, for example an individual OTV was a director of the related company OTV, so having the same bank account for each was considered satisfactory. | AP\
AP to complete the review of remaining 13 bank accounts and escalate any suspicions to CAFT.\
Responsible officer: Accounts Payable Manager, Accounts Payable, CSG\
Target date: | | 4.3 | One Time Vendors Receiving Payments into Common Accounts | 398 of 2152 unique bank accounts receiving payments (18.5%) | Matches were reviewed and excluded those clearly to the same vendor (i.e. minor spelling differences, shared family name, acronym used instead of full business name). CAFT\
The remainder 77/398 bank accounts relating to 260 OTVs were referred to CAFT for investigation, these include some names that were previously known to CAFT. | N/A | 77 bank accounts shared by 260 OTVs reviewed\
a. Resolved no issues 56/77 - links between vendors with different names were established, for example an individual OTV was a director of the related company OTV, so having the same bank account for each was considered satisfactory. | AP\
AP to complete the review of remaining 13 bank accounts and escalate any suspicions to CAFT.\
Responsible officer: Accounts Payable Manager, Accounts Payable, CSG\
Target date: | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|-----------------|-----------------------------| | | | | | | b. 7/77 – Already known to be fraudulent as part of an ongoing Fraud investigation | 1 October 2019 | | | | | | | c. 1/77 - one transaction appears to have been paid to a different supplier in error. This has been reported to AP | | | | | | | | d. 13/77 – The majority are unexplained and need to be explained by Finance as to why there are several names against one account (for example Barnet Homes bank account has several suppliers). CAFT have completed checks on Integra. There are some matches which remain | | | ToR ref | Test name | Data Analysis exceptions | Summary of testing | Referred to AP | Referred to CAFT | Agreed Action September 2019 | |---------|-----------|--------------------------|--------------------|---------------|-----------------|-----------------------------| | | | | | | | unverified and have been escalated to AP for further review and for them to respond with any suspicions. | | 4.4 | One Time Vendors Receiving Payments into Bank Accounts Linked with Council or Capita Employees\* | 26 of 2152 unique bank accounts receiving payments (1.2%) | All payments were reviewed for reasonableness. 16/26 Payments which required further investigation were referred to CAFT. | N/A | 16 matches investigated Resolved 16/16 – no issues, mainly for verification of season ticket repayments and council tenancies, | N/A |
\*Capita employee data not received and therefore not yet performed. Appendix 6.2 Observations from Payments Data Analytics and Matching Exercises’ reported in February 2019. As part of the PDAME, the following system observations were noted which if implemented could potentially improve financial processes. Our view is that these observations must be considered by officers with the appropriate expertise for potential current and future upgrades to Integra and related processes. | Agreed Action | Responsible Officer | Target Date | |------------------------------------------------------------------------------|------------------------------|-------------------| | Council / CSG Finance management will review the observations as a basis for implementing changes in Integra, in current or future versions/updates based on a risk/cost/benefit analysis. | CSG/LBB AP Business Partner | 31 March 2020 | | Observations which further mitigate fraud risk will be prioritised for assessment. | | |
**Observation**
1. **Functionality to match bank transactions to the accounting system is currently underutilised**
The Integra accounting system has the functionality to upload bank account statements into the system, which enables the matching of incoming and outgoing payments on an individual transaction level to the transactions in the accounting system. We noted that bank account statements are uploaded for only 4 out of the 28 accounts we looked at and that this functionality is not actively used for any of the accounts. Utilising this functionality could make the performance of the bank account reconciliations more efficient and effective and provides assurance that transactions in the ledgers in the accounting system accurately reflect the transactions on the bank statement.
2. **Bank account reconciliations not on individual transactional level**
Bank account reconciliations happen on a monthly basis, but are only reconciled on a total monthly movement and not at an individual transaction level. This in combination with the above finding creates the (fraud) risk that the ledgers do not accurately reflect the actual payments made as per the bank statements.
3. **Manual journals used for correction are inconsistent**
We noted in the accounting system that correcting manual journal postings are made. These journals are not always made on the same aggregation level; some journals reflect individual transactions, some roll up to weekly, and some up to monthly corrective manual journals. Additionally, it is not always directly clear from the manual journal description the reason and source of the corrections.
4. **Integra only stores detailed information for transactions that originate in Integra**
Transactional information like payee information (vendor ID, name and associated bank account information) is not stored for transactions that originate / are initiated outside Integra. When implementing Integra, the design decision has been made to only record the transaction in the accounting system, but not store any of the data associated to that transaction in Integra. This means that only about a quarter of the value paid out by Barnet Council can be analysed using Integra due to missing information.
5. **Payment Audit'-files only retained for 1 month** The bank transactions alone don't provide all the information required to perform the analyses in this review, therefore additional data needed to be added from Integra. All required information is captured in the 'Payment Audit'-files within Integra but currently these reports are not stored automatically and are deleted on a monthly basis as part of system housekeeping to avoid latency and slowness in using Integra (which has been a problem in the past). Capita has verbally confirmed that this has now been amended and these specific reports will be retained on an ongoing basis.
6. **A lack of centralised knowledge on where payment information is held** During our procedures, we noted on multiple occasions that there was a general lack of knowledge on what data was held on the system and where. Before the review it was believed that the transactions for the 28 non-school LBB bank accounts on Bankline were held on Integra. Only during the course of the review, it became clear that for only 15 out of 28 accounts the transactions are captured in Integra. At a very late stage it also became clear that from the 15 bank accounts held on Integra, only 1 account had the full supplier bank account details captured. It was noted that it is not easy to find where a transaction originated through Integra.
7. **Inconsistent naming convention** We noted that there are either no clear rules around naming conventions in outgoing transactions, or that these are not adhered to. For example, in the one-time vendor transactions you see a large variation in payee names for the same recipient. The table below shows an example of 3 one time vendor transactions for the same individual, same bank account\*, under varying naming conventions.
8. **Evaluate the need of all bank accounts** There are a large amount of bank accounts of which some have a small amount of transactions associated with them.
9. Misalignment of payment types between Bankline and Integra
Payment types are misaligned between Integra and Bankline. We identified that Barnet’s Bankline transactions contained 13 different payment types, however in the data from Integra there are 6 payment types used (there are a total of 10 defined in the system). Please refer to Appendix 2 for a full overview of payment types in Integra and Bankline.
When performing our reconciliation between Integra and Bankline we noted that there is a many-to-many relationship for payment types between the two systems. This means that payment types in Integra can relate to multiple payment types in Bankline and those same payment types in Bankline can relate to multiple payment types in Integra. Because of this, there was no possibility to map transaction types between systems and therefore we did not proceed using payment type in our reconciliation. For illustration purposes see the example below.
Example: Payment type A in Integra could consist of transactions of payment types X and Y from Bankline, while at the same time payment type Y can also be Integra’s type B. Therefore, there is no mapping between payment types possible which makes might not impact processing, but makes recognizing, reconciling and controlling transactions significantly more complex. Appendix 7 – Internal Audit roles and responsibilities
Limitations inherent to the internal auditor’s work
We have undertaken the review of Banking and Payment Arrangements (Accounts Payable), subject to the limitations outlined below.
Internal control
Internal control systems, no matter how well designed and operated, are affected by inherent limitations. These include the possibility of poor judgment in decision-making, human error, control processes being deliberately circumvented by employees and others, management overriding controls and the occurrence of unforeseeable circumstances.
Future periods
Our assessment of controls is for the period specified only. Historic evaluation of effectiveness is not relevant to future periods due to the risk that:
- the design of controls may become inadequate because of changes in operating environment, law, regulation or other; or
- the degree of compliance with policies and procedures may deteriorate.
Responsibilities of management and internal auditors
It is management’s responsibility to develop and maintain sound systems of risk management, internal control and governance and for the prevention and detection of irregularities and fraud. Internal audit work should not be seen as a substitute for management’s responsibilities for the design and operation of these systems.
We endeavour to plan our work so that we have a reasonable expectation of detecting significant control weaknesses and, if detected, we shall carry out additional work directed towards identification of consequent fraud or other irregularities. However, internal audit procedures alone, even when carried out with due professional care, do not guarantee that fraud will be detected.
Accordingly, our examinations as internal auditors should not be relied upon solely to disclose fraud, defalcations or other irregularities which may exist.
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18c87dcdab85b81a113cb8ea90c53bcb347ad503 | ## Contents
| Section | Page | |----------------------------------------------|------| | 1. Introduction | 2 | | 2. General | 2 | | - Advice and Support | 2 | | - Confidentiality | 2 | | - Fairness and Objectivity | 2 | | - Gross Misconduct and Misconduct | 3 | | - Representation | 3 | | - Records | 3 | | - Monitoring | 3 | | 3. Special Cases | 4 | | - Criminal Offences | 4 | | - Special Cases (Child Protection/Fraud) | 4 | | - Trade Union Officials | 4 | | - Work colleagues not directly employed by the Council | 4 | | 4. Roles and Responsibilities | 4 | | - Employees Responsibility | 4 | | - Managers Responsibility | 5 | | - Disciplinary Investigations | 5 | | - Disciplinary Hearings | 5 | | - Human Resources | 6 | | - Head of Human Resources | 6 | | 5. Disciplinary Process | 6 | | 5.1 Informal | 6 | | 5.2 Formal Investigation | 7 | | 5.3 Disciplinary Hearing | 8 | | 5.4 Appeal | 12 |
## Appendices
| Appendix | Page | |----------|------| | Appendix 1 | 13 | | Disciplinary Rules | | | Appendix 2 | 18 | | Disciplinary Procedure flowchart | | | Appendix 3 | 19 | | Hearing Procedure | |
1. Introduction
Council policy
The council is committed to providing a working environment where individuals are treated with fairness, dignity and respect; the Procedure is designed to ensure that there are fair and objective arrangements for dealing with disciplinary issues in the workplace.
The Procedure applies to all employees employed directly by the council and follows the guidance contained within the ACAS statutory Code of Practice for Disciplinary and Grievance Procedures, and ACAS guidance on Bullying and Harassment at Work (effective from 6 April 2009).
The Procedure should not be viewed primarily as a means of punishing individuals but as a way of helping and encouraging employees to improve unsatisfactory conduct and behaviour. It is intended to make sure allegations of misconduct are dealt with promptly, fairly and consistently in accordance with the council’s policies, employment legislation and “Best Practice”.
2. General
Advice and support
Human Resources will support and advise managers considering allegations of misconduct and monitor all formal disciplinary cases to make sure that they are dealt with in accordance with the Procedure, employment and equalities legislation, and “best practice”.
Employees are entitled to be accompanied by a trade union representative or a fellow work colleague at any meetings under the “Formal Process”. (See “Representation”).
Confidentiality
In the interests of natural justice and to avoid prejudicing the outcome of any disciplinary investigation, the proceedings must be kept strictly confidential. All those involved in the process including witnesses will be required to maintain confidentiality at all times and must not discuss or disclose details of allegations, witness statements or the outcome of meetings.
Fairness and objectivity
It is important to make sure that the disciplinary process is conducted in a fair and unbiased manner. The persons carrying out an investigation (the Investigating Officer) and conducting the Disciplinary Hearing (the Hearing Officer) must, in order to remain impartial, have had no prior involvement in the case being investigated, that is, as a witness to the alleged misconduct.
Advice must be sought from Human Resources where there any concerns as to “impartiality”. **Gross misconduct/misconduct**
**Gross misconduct** is conduct of such a serious nature that the Authority cannot allow the employee to continue in their job. Employees found guilty of gross misconduct will usually be dismissed.
**Misconduct** is conduct of a lesser degree than gross misconduct. Employees found guilty of misconduct will usually be issued with a written warning.
Examples of what may be considered as gross misconduct/misconduct are detailed in the Disciplinary Rules (Appendix 1).
**Representation**
Employees may only be accompanied or represented at meetings during the formal process (at 5.2-5.4), and by a work colleague or a trade union official.
In exceptional cases, as determined in consultation with Human Resources, the employee may be accompanied or represented by a legal representative at formal hearings and appeals; this will only apply where:
i) the potential outcome may determine the outcome in other proceedings for example where there is no further stage in the process that results in the employee being barred from future employment; or
ii) agreed as a reasonable adjustment for a disabled employee
It is the employee’s responsibility to arrange their representation and to inform their representative of the arrangements (time and dates) of meetings.
**Records**
The ACAS Code of Practice recommends that records should be kept of disciplinary hearings, detailing the following:
- the nature of any breach of the disciplinary rules or unsatisfactory performance;
- the employee’s defence or mitigation;
- action taken and the reasons for it;
- whether an appeal was lodged and it’s outcome; and
- any subsequent developments
Records should be confidential and kept in accordance with the requirements of the procedure and the Data Protection Act 1998. The employee should receive copies of any meeting records although in certain circumstances e.g. the protection of a witness, some information may be withheld.
**Monitoring**
The application of the Procedure will be monitored closely and reviewed annually in consultation with management and the trade unions. 3. Special Cases
**Criminal offences**
Criminal offences or charges are not automatic reasons for dismissal. The line manager, with Human Resources, should consider all the facts and whether the charge/offence is relevant to the person's employment and sufficiently serious to warrant investigation and action under the Procedure.
**Special cases (child protection, vulnerable adults or fraud)**
Managers must seek advice from Human Resources where there are allegations of misconduct relating to fraud, child protection issues or concerning vulnerable adults before taking any action under the Procedure.
**Trade Union Officials**
Managers must seek advice from Human Resources where there are allegations of misconduct against a trade union shop steward, branch official, Health and Safety or Learning Representative. The Branch or Regional Official must be contacted before starting a formal investigation under the Procedure.
**Work colleagues not directly employed by the council**
Managers must seek advice from Human Resources on dealing with any allegations of misconduct concerning agency workers or work colleagues not directly employed by the council.
4. Roles and Responsibilities
**Employee's responsibility**
Employees are required to comply with the Employee's Code of Conduct and the council's policies and procedures, as well as any other arrangements that apply in their service area or department.
Employees must comply with arrangements detailed in this Procedure which are designed to make sure that disciplinary issues are dealt with fairly and objectively. Employees are required to:
- Fully co-operate with the process
- Maintain confidentiality
- Attend meetings at the time and place designated
- Give as much notice as possible when they or their representative cannot attend formal meetings and be reasonable when suggesting alternatives, (which must be within five working days of the original date)
- Follow the terms of any suspension. Manager’s responsibility
Managers must make sure that employees are made aware of the standards expected, as detailed in the Employee’s Code of Conduct and the council’s policies and procedures, as well as any other arrangements that apply.
Managers must comply with arrangements detailed in this Procedure which are designed to make sure that disciplinary issues are dealt with fairly and objectively. Managers are required to:
- Notify the employee of any concerns about unsatisfactory conduct and behaviour
- Maintain confidentiality
- Try and resolve minor issues informally with the employee through informal discussion and advice
- In all other cases, establish the facts promptly before recollections fade and deciding on whether a formal investigation is required
- Consult Human Resources before proceeding to the formal stages of the Procedure
Disciplinary investigations
Disciplinary issues will usually be investigated by the employee’s immediate supervisor or manager, or if they are already involved in the case another manager will take the role of Investigating Officer.
Advice must be sought from Human Resources where there any concerns as to “impartiality” of the nominated Investigation Officer. Any disagreement will be referred to the Head of Human Resources whose decision is final.
Note: In some cases, managers may decide to suspend employees during an investigation; this does not imply guilt and employees will be paid as normal.
Disciplinary hearings
Hearings will be conducted either by a Corporate Director, Divisional Director or Group Manager with the authority to chair a disciplinary hearing and to issue any disciplinary sanctions, for example, issue warnings or dismissal.
In the case of JNC officers, a Member Panel consisting of the Leader and Deputy Leader of the Council (as Chair and Deputy Chair respectively), the relevant port-folio holder, plus at least two other councillors:
i) will make decisions in respect of the dismissal and consider disciplinary action in respect of all JNC Officers with the exception of the Chief Executive (Head of Paid Service), Monitoring Officer and Chief Financial Officer (Section 151 Officer), whose cases will additionally require the involvement of an independent person, and
ii) in the case of dismissal, be subject to recommendations to the Assembly. Human Resources
Procedural advice must always be sought from Human Resources. A Human Resources Adviser will attend all formal Disciplinary Hearings and Appeals (at 5.3-5.4), to make sure a thorough and fair process for all concerned in line with the council procedures and “Best Practice”.
Human Resources will be available to give appropriate support and advice during the process; this will include:
- talking through the process to be followed
- where to go for further help and support
Head of Human Resources
The Head of Human Resources and his/her named representative, has the overriding authority to make sure that all disciplinary cases are dealt with appropriately and in accordance with this Procedure, employment legislation and “Best Practice”.
5. Disciplinary Process
It is essential that any allegations of misconduct are investigated and the facts established promptly before recollections fade. Investigations do not need to be time consuming, but speed should not be at the expense of thoroughness.
In accordance with the principals of natural justice, employees will be advised at each stage, by the Investigating Officer, of the precise nature of the complaint and specific allegation(s) against them and given the opportunity to respond before any decision is made. The individual will also have the right of appeal against any disciplinary action taken after a Hearing.
No disciplinary action will be taken until the matter has been investigated and employees will not be dismissed for a first breach of discipline except in the case of gross misconduct.
5.1 Informal
Most minor issues can be resolved informally by the line manager through informal advice and discussion, consultation and training, as appropriate. Where the allegations are of such a serious nature that they cannot be dealt with informally, the matter will be investigated through the Formal Process at 5.2 to 5-3.
Where there is suspected gross misconduct; or working relationships have broken down, including bullying and harassment; or risks to individuals or to council property etc, managers should consider, in consultation with Human Resources, whether to suspend the employees pending investigation of the allegation or allegations. 5.2 Formal Investigation
Managers must consult Human Resources before proceeding to the formal stages of the Procedure.
Investigation
The Investigating Officer should establish the facts as quickly as possible, and decide whether there is an issue to be dealt with informally or a case to be dealt with using the formal procedure. This includes getting the employee’s version of events and obtaining witness statements.
It is important to remember that disciplinary investigations are stressful for all concerned, that is, the employee; witnesses; the Investigating Officer and colleagues. Therefore, consideration should be given as to what priority and support is allocated to enable the manager to carry out a full investigation as speedily as possible.
It is not possible to set rigid timescales for the completion of investigations but the Investigating Officer must seek advice as soon as possible from their Manager and Human Resources if this is likely to take longer than four weeks. The employee should be kept regularly advised of the progress of the investigation.
Employees may be accompanied at any meeting under the Formal Process either by a trade union representative or work colleague. If a chosen representative is unable to attend a meeting, the Investigating Officer will reschedule the meeting to a mutually convenient time, not more than five working days after the originally notified date, in accordance with the ACAS Code of Practice. This deadline may be extended by agreement provided the meeting is held within 20 working days of the originally notified date. The statutory right to be accompanied applies specifically to hearings which could result in:
i) The administration of a formal warning to a worker by their employer. ii) The taking of some other action in respect of a worker by their employer iii) The confirmation of a warning issued or some other action taken.
The Investigating Officer should obtain all the relevant facts and information as quickly as possible, by collecting written evidence and interviewing witnesses as appropriate. Witnesses should be interviewed or asked to provide written statements. A record should be taken of interviews and the notes of meetings and witness statements signed and dated by the witness. Witnesses must be reminded of the need to maintain confidentiality and that they may be required to attend future hearings.
The Investigating Officer must notify the employee as soon as practicable that an investigation is being carried out and the reason for this. As soon as the Investigating Officer has clarified the allegations they should arrange an investigative meeting. The employee must be formally notified in writing of the arrangements for the meeting and the specific allegations.
The purpose of the meeting is to give the employee the opportunity to respond to the allegations and to raise any concerns, as part of the fact finding process.
Following the meeting it may be necessary to seek further information or to interview/re-interview witnesses to check facts. Where new information is obtained during the investigation, the investigative meeting should be reconvened in order to give the employee the opportunity to respond.
Once the investigation is completed, the Investigating Officer will need to decide whether or not there is a case to answer at a hearing. Their decision should take into consideration the following:
- Has the employee admitted to any of the allegations?
- Has the employee broken any rules and procedures?
- Are the rules known to employees and have they been applied consistently?
- Is it reasonable to expect the individual to know their conduct was wrong?
- If there has been a breach of discipline does it require formal action or can it be dealt with informally by counselling, training and development?
The employee will be notified in writing of the outcome of the investigation and the recommendations.
5.3 Disciplinary Hearing
The arrangements for the Hearing are detailed at Appendix 3.
A Disciplinary Hearing will be conducted by a Corporate Director, Divisional Director or Group Manager (Hearing Officer) with the authority to chair a disciplinary hearing and to issue sanctions. A Human Resources Adviser will provide procedural advice to the Hearing Officer.
The Hearing Officer conducting the meeting will arrange for a note taker to be present. If the employee disagrees with the notes of the meeting, they can ask for their version to be attached to the minutes.
The management case should normally be presented by the Investigating Officer who will arrange for the employee to be formally advised in writing of the date and arrangements for the hearing including:
- the specific allegations against them;
- whether it may result in a dismissal;
- their right to be represented; • their right to present evidence and call witnesses; • copies of the evidence and the names of the witnesses to be presented.
The employee or their representative is responsible for arranging:
i) Their witnesses and notifying them of the time and date of the Hearing. ii) Provision of their evidence or documentation to be presented at the Hearing.
Details of the information to be presented and the names of witnesses to be called should be made available to the Hearing Officer, Investigating Officer and employee, a minimum of five working days before the day of the Hearing.
If the employee’s chosen representative is unable to attend, the Hearing will be rescheduled to a mutually convenient time no more than five working days after the date originally proposed. This deadline may be extended by agreement provided the meeting is held within 20 working days of the originally notified date.
The employee will be notified in writing that if they fail to attend the re-arranged Hearing without good reason, or to arrange representation, the case may be heard in their absence.
Outcome
When considering an outcome the Hearing Officer should consider the following:
• Has there been as much investigation as is reasonable in the circumstances? • Have the requirements of the Disciplinary Procedure been properly complied with up to this point including advance notice to the individual of the matters to be considered? • Have I paid sufficient regard to any explanation put forward by or on behalf of the employee? • Do I genuinely believe that the employee has committed the alleged misconduct? • Have I reasonable grounds to sustain that belief on the balance of probabilities (is it more likely than less likely the individual committed the alleged misconduct)?
If the answer to all of the above points is yes;
• Is the misconduct serious enough to warrant the disciplinary decision I am contemplating? • Whether the Disciplinary Rules indicate what the likely penalty will be as a result of this particular misconduct? • Have I had regard to any mitigating circumstances put forward by, or on behalf of, the employee and a response by management? • Is the decision reasonable in all the circumstances (taking into account the individual's service history and the action taken in similar cases)?
After full consideration of the evidence presented, the Hearing Officer may decide from the following outcomes:
i) **Adjournment**
To adjourn pending further investigation of issues raised at the Hearing, before reconvening to decide on the outcome or to continue the Hearing.
ii) **No action**
Where there is no case to answer or the matter does not warrant a warning, the employee should be informed that the matter is being dropped and that no further action will be taken.
The outcome and any recommendations must be confirmed to the employee in writing and the records and documentation from the investigation will be destroyed.
Line Managers will need to consider how they will re-introduce the person back into the workplace, especially where they have been suspended pending the outcome of the disciplinary proceedings.
iii) **Counselling, advice, referral to Occupational Health**
Where the inappropriate behaviour, or misconduct, can be dealt with through additional training, support, advice or counselling (from the line manager or the council's Occupational Health service or Employee Welfare Line) where there are concerns as to the individual's health.
The Hearing Officer must inform the employee of the outcome in writing and the arrangements for any identified support. The employee must also be informed that if they fail to respond to the support or there is no improvement in their behaviour over the following six months, the matter will be referred back for a decision on any deferred disciplinary action.
Note: Managers must make sure that any support agreed is provided, as it will be unfair to refer the case back to the Hearing Officer for a decision if they have not complied with the outcome. iv) **Written warning**
The Hearing Officer should ensure that the employee is clear about both the reasons for the warning, and the consequences of failure to heed it.
i. **First Written Warning** – For a period of six months. First written warnings are normally given for a minor offence.
ii. **Second Written Warning** – For a period of 12 months. Second written warnings are usually given for a more serious offence or an accumulation of minor offences.
iii. **Final Written Warning** - For a period of 12 months. Final warnings are usually given for further instances of misconduct or a first instance of gross misconduct, depending on the seriousness of the case.
In exceptional cases, where agreed with the Head of Human Resources, a final written warning may be extended to 18 months where the misconduct is so serious - verging on gross misconduct - that it cannot realistically be disregarded for future disciplinary purposes.
v) **Dismissal**
If the misconduct is of such a serious nature that the authority cannot allow the employee to continue their job, they may be dismissed without notice. Dismissal following cumulative warnings or by reason of capability, will be with pay in lieu of notice.
Note: Action will be taken to recover any monies misappropriated or lost in fraud cases or through breaches of Standing Orders and Financial Regulations or any other policies and procedures.
vi) **Disciplinary transfer or Demotion**
In exceptional cases, as agreed by the Head of Human Resources, for example where allegations of bullying or harassment are upheld or the employee no longer holds qualifications that are a requirement of the post, a transfer or demotion may be considered as an alternative to dismissal. This sanction will not be considered in all disciplinary cases and only where there is a suitable post immediately available.
In all cases, the Hearing Officer will notify the employee in writing of the outcome of the Hearing, including any recommendations, within five working days, along with the right to appeal as appropriate. 5.4 Appeal
Employees have the right to appeal against any disciplinary action and if they wish to do so, they should write to Human Resources within 10 working days of receiving the letter confirming the outcome of the Hearing, stating the grounds for the appeal.
Appeals against First and Second Written Warnings will be heard by a Corporate or Divisional Director.
Appeals against Final Written Warnings and Dismissal will be heard by the Personnel Board.
The Officer or Panel hearing the appeal may vary or confirm the decision made at a Disciplinary Hearing but cannot increase the sanction.
Note:
i) A Corporate or Divisional Director with the responsibility to chair an Appeal Hearing will hear appeals against disciplinary sanctions against officers up to and including LSMR posts. Appeals against final warnings and dismissal will be heard by Members at a Personnel Board.
ii) A Member Panel consisting of at least two Cabinet Members, one of whom shall be appointed as Chair, plus two other councillors, subject to none having participated in any previously appointed Panel relating to the case in question, to:
(i) consider appeals in respect of dismissal and disciplinary action from JNC Officers;
(ii) consider, with the involvement of a separate independent person, appeals in respect of disciplinary action against the Chief Executive (Head of Paid Service), Monitoring Officer and Chief Financial Officer (Section 151 Officer); and
(iii) in the case of dismissal, this will be subject to recommendations to the Assembly.
This is the final stage; there is no further right of appeal.
Human Resources will automatically update the Procedure to comply with any changes to legislation or ACAS guidance and notify employees of the amendments. Appendix 1: Disciplinary Rules
Disciplinary rules set standards of conduct at work and it is important that employees know what standards of conduct are expected of them so as not to undermine supervisory control and / or impair the effective exercise of the council's duties and responsibilities.
It is unlikely that any set of disciplinary rules can cover all circumstances that may arise, and the examples detailed are not intended to be either exhaustive or exclusive. Moreover, the rules required may vary according to particular circumstances. In drawing up the rules, the aim has been to specify as clearly and concisely as possible, those necessary for the:
- efficient and safe performance of work;
- legitimate expenditure and use of council resources; and
- for the maintenance of satisfactory employment relations between employees and the council.
The rules, which apply to everyone employed by the council, give guidance on how various types of behaviour are to be treated so that each individual is aware of the consequences of unsatisfactory conduct or performance. Breaches of disciplinary rules will lead to appropriate disciplinary action, taking into account:
- the seriousness and nature of the offence;
- the employee's previous record;
- mitigating circumstances
- in some instances - the nature of the job
Definitions
**Gross misconduct** is conduct of such a serious nature that the Authority cannot allow the employee to continue in their job. Employees found guilty of gross misconduct will usually be dismissed without notice.
**Misconduct** is conduct of a lesser degree than gross misconduct and if found will result in the employee being issued a warning. Recurring or repeated acts of misconduct may be considered as gross misconduct.
1. **Gross misconduct**
The following are examples of offences that would normally be considered as a fundamental breach of contract and gross misconduct. However they may also be considered as misconduct according to the seriousness of the offence and the nature of the employee’s job: 1.1 Any act which could be subject to criminal proceedings and/or the failure to notify the council of any such action.
1.2 Stealing from the council, its Members, its staff or the public, offering or accepting bribes.
1.3 Deliberate damage to, or deliberate neglect of council property.
1.4 Deliberate contravention of Standing Orders and Financial Regulations or neglect of duty (deliberate or otherwise) in failure to follow procurement rules etc that results in a financial loss to the council.
1.5 Fabrication of any document, for financial gain.
1.6 Deliberate fabrication of qualifications or information which is a stated requirement of employment or which could result in financial gain.
1.7 Acceptance of gifts or gratuities.
1.8 Attempted use of an official position for private advantage, including the employment of people to whom you are related to or have a close personal relationship outside work; dishonest or improper use of information obtained in the council's employment.
1.9 Doing unauthorised private work (whether paid or not) during hours when contracted to work for the council or during periods of sick leave.
1.10 Sexual misconduct at any time with any person for whom you have a responsibility and is in your care in your capacity as an employee of the council.
1.11 Accessing or downloading pornographic or offensive material from the web, intranet and/or any other sources etc
1.12 Posting defamatory, offensive, incorrect or improper comments or disclosing confidential information about the council, its clients, or fellow employees through any media including social networking sites
1.13 Fighting or physical assault at work either with fellow employees or other persons; including maltreatment of persons in the care of the Authority; threatening behaviour; intimidation or assault. This does not include reasonable self-defence in cases of assault on an employee. 1.14. Serious breaches of safety regulations, endangering yourself or other people, including deliberate damage to, neglect or misappropriation of safety equipment.
1.15. Deliberate acts of harassment that involve physical or mental intimidation or assault bullying, discrimination on any grounds including age, disability, gender, faith or religion, marital status or civil partnership, maternity or pregnancy, race, sexual orientation, socio-economic status and caring responsibilities.
1.16. Criminal offences committed inside/outside of work will be considered according to the particular circumstances of the case, but dismissal will result where:
- Employment by the council in any way enabled or assisted in the commission of the offence.
- Council property was used to aid the commission of the offence.
- Continued employment would put at risk those served or employed by the council.
1.17. Offences which would affect the member of staff’s ability to undertake contractual duties or obligations under the council’s Code of Conduct, including failure to declare conflicts of interest.
1.18. Making a false, malicious or vexatious complaint or accusation.
2. Misconduct
The following are examples of offences that would normally be considered as misconduct. They may also be considered as gross misconduct according to the seriousness of the offence and the nature of the member of staff’s job.
2.1 General Misconduct
- Failure to obey reasonable instructions.
- Offensive or abusive behaviour.
- Being under the influence of alcohol or drugs (other than those that have been medically prescribed) so that performance of work duties is detrimentally affected or, which could endanger anyone’s safety.
Note: Managers should refer to the drug and alcohol dependency policies and take advice from Human Resources before taking any action under this Procedure.
- Sleeping on duty unless expressly permitted as a requirement of the job role. 2.2 Absence from duty and timekeeping
- Unauthorised absence from work.
- Failure to report absence from work and the reason for such absence.
- Failure to provide an absence certificate as required under sick leave procedures.
- Failure to complete flexible hours records or time recording sheets each day or period as required.
- Bad timekeeping.
2.3 Neglect of duty
- Failure to discharge obligations in accordance with a legal statute or contract of employment without sufficient cause.
- Negligent, careless or wilfully inadequate standards of work.
- Failure to account properly for or to make a prompt and true return of any money or property which comes into the possession of a member of staff during the course of duty.
- Failure to follow financial procedures when submitting and approving claims for expenditure, including the provision and checking of receipts
- Negligent, careless or wilfully downloading from an unsecured website or electronic communication resulting in any loss to the council
2.4 Misuse or fabrication of information
- Making a knowingly false, misleading or inaccurate oral or written statement in respect of official business or for personal gain.
- Failure to disclose a conviction for a criminal offence (unless under the terms of the Rehabilitation of Offenders Act 1974 the conviction is 'spent').
- Communicating to persons outside the Authority proceedings of any Committee meeting or the contents of any document unless required by law or authorised to do so.
- Failure to comply with the obligation placed upon you under the terms of the Data Protection Act 1998.
- Providing employment or business references unless authorised to do so.
2.5 Misuse of council materials, equipment or resources
- Unjustifiable waste of council materials, equipment or resources.
- Failure to report any loss or damage to any property of the council, within your area of responsibility. • Unauthorised use of any council documentation, facilities or equipment including work telephones, electronic portable devices, photocopying or scanning, stationery or supplies, web access etc for private purposes. • Use of waste council material without express authority, including waste food. • Use of council labour, materials, equipment or resources for private purposes.
2.6 Discrimination
Discrimination against an employee or a member of the public on any grounds including gender, sex, colour, race, creed, nationality, religion, disability or ethnic origins, age, sexual orientation, marital status or civil partnership,
Discrimination against an employee or a member of the public on any grounds including gender, sex, colour, race, creed, nationality, religion, disability or ethnic origins, age, sexual orientation, marital status or civil partnership, maternity or pregnancy, caring responsibilities and trade union membership or activities.
2.7 Health and Safety
• Failure to comply with the obligation placed upon the member of staff under the terms of the Health and Safety at Work Act 1974 and any subsequent amendments. • Failure to wear appropriate protective clothing or use necessary safety equipment provided by the council for particular duties. • Failure to comply with accident reporting procedures. • Failure to comply with departmental hygiene requirements. • Dangerous or reckless behaviour involving risk of injury to the member of staff or to other persons or other conduct at work likely to diminish safety standards, for example using mobile phones whilst driving. • Neglecting to carry out any instructions of a medical officer appointed by the authority or, while absent from duty on account of sickness, committing any act, undertaking any private work, or adopting any conduct calculated or liable to postpone return to duty. • Smoking in areas designated as no smoking. • Failure to comply with health and safety guidance or requirements when working from home. Appendix 2: Disciplinary Procedure - Flowchart
Informal
Managers must consult HR before proceeding to the Formal Investigation process.
There is a case to be investigated.
Managers must seek HR advice:
i) and notify the Branch/Regional official of any allegations against a TU shop steward or full time official, health and safety or learning representatives before any investigation or action under the Procedure.
ii) before suspending employees, for example where there are allegations of gross misconduct.
Formal Investigation
Nominated Investigating Officer who is not directly/indirectly involved investigates the case as soon after the alleged incident as possible.
Investigation meeting is arranged with the employee and anyone else involved where appropriate, to discuss all supporting information/evidence.
Disciplinary Hearing convened.
The arrangements will be confirmed in writing to the employee a minimum of five working days before the hearing.
Hearing is chaired by a Corporate Director/Divisional Director/Group Manager (or Members Panel for JNC posts).
Outcome of Disciplinary Hearing is confirmed to the employee in writing within five working days.
Disciplinary Action
No Further Action
Employee has right of appeal against the decision. Appeal to be submitted to the Head of Human Resources within 10 working days of receiving the letter confirming the outcome of the Hearing.
Appeal will be heard by either a Corporate Director/Divisional Director or a Personnel Board (or Members Panel for JNC posts).
This is the final stage; there is no further right of appeal. Appendix 3: Hearing Procedure
1. Introduction
- The person hearing the case (the “Hearing Officer”) will; clarify the roles of those present; check both sides have copies of the documentation and details of the witnesses to be presented; and outline the process to be followed.
- The Hearing Officer will not normally allow any further documentation or witnesses to be presented at the Hearing unless both sides agree.
- The manager presenting the case, the employee and their representative will be present throughout the Hearing except for any adjournment and when the Hearing Officer is considering their decision.
- Witnesses will only be present when they are called to give their evidence and to be questioned by the Hearing Officer, the management and staff sides.
- The Hearing Officer and HR Adviser can ask questions of the manager, the employee and their representative and witnesses at any time.
- The Hearing Officer will give the employee the opportunity to say whether they admit to any of the allegations before management presents their case.
Where the employee admits to the allegations, the Hearing Officer may consider claims of mitigation instead of having the whole case presented. The Hearing Officer will still allow management the opportunity to ask the employee or their representative questions. The employee and/or their representative will then have the opportunity to clarify any points raised during the questioning.
In such cases the Hearing would then go directly to Stage four: Summaries
2. Management case
- Management will present their case and call witnesses and refer to documents as appropriate
- After the presentation, the employee and their representative can ask the management questions
- Management will then have the opportunity to clarify any points raised during questioning.
3. **Employee case**
- The employee and their representative will present their case and call witnesses and refer to documents as appropriate.
- After the presentation, management can ask the employee and/or their representative questions.
- The employee and their representative will then have the opportunity to clarify any points raised during the questioning.
4. **Summaries**
- Both sides, starting with management, will have the opportunity to **summarise** their case if they wish. This is not a rehearing of the whole case and neither side will be allowed to ask any further questions.
- Both sides will then withdraw whilst the Hearing Officer considers their decision. If it is necessary to recall the employee, manager or a witness to clarify points of uncertainty as to the evidence presented, this must be done in the presence of both parties who will be called back together.
5. **Outcome**
- The Hearing Officer will recall both sides together to notify them of the outcome. If further time is needed to consider the matter, both sides will be recalled and given an indication as to when a decision is to be made and allowed to leave.
- The Hearing Officer will confirm the decision and any recommendation(s) in writing within five working days and arrange for the notes of the meeting to be issued to both parties and the Human Resources Adviser as soon as possible afterwards.
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342202149f79d36ba99137c51da3c1c0bddac779 | Flexi-time Working Arrangements | Contents | Page | |------------------------------------------------------------------------|------| | 1. Introduction | 2 | | 2. Eligibility | 3 | | 3. Responsibility for the operation of flexi-time | 3 | | 4. Operation of the Scheme | 4 | | - Standard Hours | | | - Accounting Period | | | 5. Additional hours/overtime working | 4 | | 6. Medical appointments, special Leave and training | 5 | | 7. Other conditions | 5 | | - Services excluded from flexi-time working | | | - Agreeing flexi-time arrangements | | | - Flexi-time recording | | | - Staff leaving the Council | | | 8. Monitoring | 6 | | 9. Advice | 6 | | Appendix 1: Flexi Hours Record Sheet | 7 |
1. Introduction
The Council recognises the value of providing more flexible working arrangements, with the benefits that these bring to the Organisation and has adopted a flexi-time scheme.
Flexi-time should benefit employees and the Council. It can help employees in managing their work life balance and gives them more freedom to arrange their working hours to suit their personal circumstances whilst allowing the Council greater flexibility in the way it delivers services and manages workloads, as well as deals with urgent matters.
This Policy applies to all employees directly employed by the Council and is recommended to schools as best practice.
2. Eligibility
The introduction and operation of flexi-time is at the discretion of management and will be available to employees up to and including PO6 only.
There are some services where for practical reasons e.g. the operating hours or the provision of services to the public, employees cannot work flexi-time. Departments will decide which services are excluded from flexi-time or where the level of flexibility will need to be restricted according to the needs of the service, following consultation with employees at the departmental consultative committee and after carrying out an impact assessment; this will be reviewed annually.
Note: The statutory right of employees with 26 weeks continuous service to apply for flexible working is not affected i.e. for employees who are:
i) parents of children aged under 17 or of a disabled child aged under 18; or ii) a carer or expects to care for adult who is a dependant \*
- See definition of “carer” on Intranet at: http://lbbd/search/c.htm
3. Responsibility for the operation of flexitime
The success of the Scheme is dependent on all employees accepting responsibility to ensure that the work of the Council and the provision of services to the public do not suffer.
Managers are responsible for the successful operation of flexi-time arrangements i.e. managing employee attendance and the application of the Scheme. Managers must ensure that offices and workplaces are covered at all times during the Council’s standard hours.
There may be exceptional circumstances e.g. employee shortages where the needs of the service must take priority and it may be necessary to restrict or withdraw flexi-time working, having first considered other alternatives with employees. In these cases, the situation will be kept under review with employees.
Employees who fail to follow the flexi-time arrangements and/or to keep accurate up to date record sheets will have the facility withdrawn and may be subject to disciplinary action. 4. Operation of the Scheme
Standard Hours
The Council’s standard working day is 8 hours, (with a 1 hour unpaid lunch break), to be worked between 8am to 6pm. The core office opening hours are: 8:45am - 4:45pm and services must be provided to the community within these hours.
For employees working flexi-time, the working day is divided into 3 parts:
- “Core time”, fixed periods when all employees must be at work.
- Lunch break 1 hour (minimum 30 minutes) to be taken between 11.30am - 2:30pm, (or up to 2 hours with the manager’s approval).
- Flexible periods when the individual has some discretion in start/finishing times.
The standard band for flexible working hours is between 8am and 6pm, as detailed:
| Flexible Time | Core Time | Flexible Time | Core Time | Flexible Time | |---------------|-----------|---------------|-----------|---------------| | 8 - 10am | 10 -11.30am | 11.30am – 2.30pm | 2.30 – 3.30pm | 3.30- 6pm |
Departments may vary the standard band to ensure that services are accessible to the community; where shift arrangements are in operation, it may be possible to allow some flexibility i.e. 1-8 pm shift, flexible period from 12 noon- 9:30 pm.
Council offices are normally accessible between 7:30am & 7pm but time may only be accrued for flexi-time purposes between 8am & 6pm.
Accounting Period
The accounting period is 4 weeks. A standard working day or half-day is 7 hours or 3 hours 30 minutes respectively. Flexi-time will be recorded in blocks of 15 minutes to the nearest 15 minute interval e.g. arrival at 9:05/13 is recorded at 9:00/15am.
Flexi-days leave must be approved in advance by the manager, (via the Oracle HR self-service where employees have access to this); employees may only take 1 flexi day leave in any 4 week accounting period.
Up to 7 hours credit/debit may be carried forward into the next accounting period. Any credit in excess of 7 hours will be lost unless authorised by the manager. Any debit carried over must be made up by the end of the next four-week period.
Departments may vary the limit of credit to be carried forward at “peak” periods e.g. the end of the financial year, during “inspections” or to ensure services to the public are not disrupted. This must be agreed in advance with the Corporate Director.
5. Additional hours/overtime working
All additional/overtime working outside of the standard band for flexible working hours e.g. to attend evening/weekend meetings, must be agreed in advance with the Corporate Director, Divisional Director or Group Manager in accordance with the existing arrangements. Authorised additional/overtime working outside of the standard band for flexi-time, must be recorded separately on the Flexible Hours Record Sheet (FHRS). The additional hours worked will be credited to be taken later as Time Off In Lieu (TOIL), or paid as overtime in accordance with the normal arrangements; this is separate to the arrangements for taking flexi-time.
In exceptional circumstances, Corporate Directors may agree to overtime paid at the standard overtime rates; this only applies when taking accrued hours will affect service delivery. Employees cannot work overtime during the standard band for flexi-time.
6. Medical appointments, special leave and training
Medical appointments
Employees are expected to arrange medical and domestic appointments e.g. “check ups”, home deliveries or repairs etc in their own time. The arrangements for urgent medical, dental and optical appointments etc are detailed in the “Arrangements for Special Leave and Time-Off from Work” available on Intranet at:
http://lbbd/hr/employee-leave/employee-leave-home.htm
Pregnant employees have the right to paid time off for ante-natal care and must produce evidence of such appointments if requested; these appointments are outside of the flexi-time arrangements and time off will be credited.
Training
Absence to attend a full day training course or seminar will be credited as 7 hours or the normal working day.
Part time employees who would normally work less than 7 hours that day will be credited the additional hours worked to be taken later as TOIL or flexi-time as agreed with the manager beforehand.
7. Other conditions
Services Excluded from Flexi-time Working
Departments must keep a list of the services excluded from flexi-time working and/or working non standard band widths using the pro-forma at Appendix 1. A copy of the list should be forwarded to the Human Resources Service Centre for monitoring purposes and to be included with recruitment packs and contracts of employment.
Agreeing Flexi-time Arrangements
Managers and employees must be clear from the outset as to the arrangements for ensuring that the workplace is covered during the standard hours, as well as to deal with emergencies and for attendance at evening/weekend meetings etc.
The arrangements must ensure that service needs are met and that services to the public, (or other customers and departments), do not suffer e.g. standard start/finish times and the minimum number of staff to be on duty at any one time etc. Where employees are required to attend evening meetings etc, some flexibility should be allowed to enable them to work outside the standard band e.g. to start and finish later that day, providing the office/workplace is covered.
**Flexi-time Recording**
Employees must keep an accurate and up to date record of their starting, finishing and break times on a daily basis using the standard Flexible Hours Record Sheet (FHRS). At the end of the 4-week accounting period, the FHRS must be forwarded to the manager for approval. The standard FHRS is available on Intranet at:
http://lbbd/staffinfo/index.htm http://lbbd/hr/benefits/flexible-working.htm
The success of the Scheme is dependant on everyone following the arrangements detailed in this Policy and employees that do not will have the facilities withdrawn. Employees who abuse or undermine the integrity of the system or falsify flexible working hours records etc will be subject to disciplinary action.
**Employees Leaving the Council**
All employees on leaving the employment of the Authority will be expected to reduce their “credit/debit” to zero by their last day of service. Employees will not be paid for any credit balance but any debit must be reported to Payroll Section to make the necessary adjustments to pay.
8. **Monitoring**
The Policy will be impact assessed and reviewed annually. Departments will be responsible for impact assessing the operation of the flexi-time arrangements across their service areas.
9. **Advice**
If an employee has any queries about the scheme they should speak to their line manager in the first instance. Any unresolved issues should be referred to the Divisional Director/Corporate Director.
Any queries or disputes as to the interpretation of the procedures that cannot be resolved at departmental level, should be referred to the Head of Human Resources or his/her nominated officers for consideration.
Human Resources will automatically update the Procedure to comply with any changes to legislation or ACAS guidance and notify employees of the amendments. Appendix 1.
.................. Department
Services Excluded from Flexi-time Working
Services Working Non-Standard Band Widths
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f2666c122dd412accd11ab20b67bafa26dfc4b21 | Managing Attendance at Work (Sickness Absence) Procedure | Contents | Page | |----------------------------------------------|------| | 1. Introduction | 3 | | 2. General | | | Advice and support | 3 | | Confidentiality | 3 | | Fairness and objectivity | 3 | | Managing sickness absence | 4 | | Representation | 4 | | Records | 4 | | Monitoring | 4 | | 3. Roles and Responsibilities | | | Employee’s responsibility | 5 | | Manager’s responsibility | 5 | | Employee supervision | 6 | | Absence Reviews | 6 | | Absence Hearings | 7 | | Occupational Health | 7 | | Reasonable adjustments and Access to Work (ATW) | 7 | | Human Resources | 8 | | Head of Human Resources | 8 | | 4. Absence Process | | | 4.1 Managing attendance and sickness absence | 8 | | 4.2 “Trigger points” | 9 | | 4.3 Absence Review | 10 | | 4.4 Absence Hearing | 12 | | 4.5 Appeals | 14 | | Appendices | | | Appendix 1: Managing Attendance at Work (Sickness Absence) Procedure - Flowchart | 15 | | Appendix 2: Details of support arrangements | 16 | | Appendix 3: Absence Hearing - Procedure | 17 |
1. Introduction
**Council Policy**
The Council is committed to providing a working environment where individuals are treated with fairness, dignity and respect; the Managing Attendance at Work (Sickness Absence) Procedure is designed to ensure that there are fair and objective arrangements for managing sickness absence and attendance.
The Procedure follows the guidance in the ACAS statutory “Code of Practice for Disciplinary and Grievance Procedures” and “Managing attendance and employee turnover”, as well as “Best Practice”. It applies to employees directly employed by the Council only and is recommended to schools with delegated authority for staffing matters, as “Best Practice”.
The Procedure should be viewed primarily as a way of helping and encouraging employees to improve their attendance and/or to manage long-term sickness absence. It is intended to ensure that absence issues are dealt with promptly, fairly and consistently in accordance with the Council’s policies, employment legislation and “Best Practice”.
2. General
**Advice and support**
Human Resources will support and advise managers dealing with unsatisfactory attendance and/or long-term sickness absence and monitor all formal cases to ensure that they are dealt with in accordance with the Procedure, employment and equalities legislation, and “best practice”.
Employees are entitled to be accompanied by a trade union representative or a fellow work colleague at any meetings under the “Formal Process”. (See “Representation”).
**Confidentiality**
All those involved in the process will be required to maintain confidentiality at all times.
**Fairness and objectivity**
It is important to ensure that the absence review process is conducted in a fair and unbiased manner.
Advice must be sought from Human Resources where there any concerns as to the process being followed. Managing sickness absence
The Council recognises that most sickness absence is genuine and will support employees who are genuinely ill and unable to attend work, but absence (both short-term and certificated) also needs to be managed effectively.
The Procedure is intended to help ensure that sickness absence is managed fairly and effectively, and appropriate support is provided to employees including those with a disability and/or long-term medical condition. This will help reduce the impact of absence on the employee, services and colleagues e.g.:
- higher levels of stress and low morale
- extra work for work colleagues, added pressure with impact on morale
- lost production, missed work targets and delays
- disruption to services and service users
- additional salary costs to cover sickness absence
- loss of competitive edge over other service providers
- failure to meet Best Value indicators and/or other performance targets
Any concerns as to employees abusing the sickness arrangements or failing to report absence may be dealt with under the Disciplinary Procedure.
Representation
Employees may only be accompanied / represented at meetings during the formal process (at 4.3-4.5) by a work colleague or a trade union official.
It is the employee’s responsibility to arrange their representation and to inform their representative of the arrangements (time and dates) of meetings.
Records
Records should be kept of all Absence Reviews and Hearings, detailing the following:
- the employee’s absence record;
- the employee’s response and/or explanation;
- action taken and the reasons for it;
- whether an appeal was lodged and it’s outcome; and
- any subsequent developments
Records should be confidential and kept in accordance with the requirements of the Procedure and the Data Protection Act 1998.
Monitoring
The application of the Procedure will be monitored closely and reviewed annually in consultation with management and the trade unions. 3. Roles and Responsibilities
**Employee's responsibility**
The Council, as part of the normal employment contract, expects the following from its employees:
- that they attend work on the days and times they are contracted to be working and provide a satisfactory explanation for any absence from duty;
- compliance with the Council’s absence procedures as detailed in the “Guidance on Sickness Absence and Reporting Arrangements”;
- compliance with reasonable orders, instructions, requirements, and observance of Council practices, policies and procedures.
Employees must comply with arrangements detailed in this Procedure which are designed to ensure that concerns about sickness absence and/or attendance are dealt with fairly and objectively. Employees are required to:
- Fully co-operate with the sickness absence and reporting arrangements;
- Notify and speak to their line-manager/supervisor in person on the 1st and each day of uncertified absence and keep them informed as to the reason(s) and likely duration of absence as required by their manager;
- Provide medical certificates (“Statement of Fitness for Work”) on the 8th calendar day of sickness and to cover their absence from then or when they are hospitalised and/or as required by their manager;
- Enter their sickness absence on Oracle HR Self Service (where they have access to this) or complete a Return to Work (Self Certificate) Form;
- Participate in “return to work” interviews;
- Notify their line-manager/supervisor of any issues that may affect their attendance at work and of any reasonable adjustments to be considered;
- Attend any medical appointments/examinations organised by the Council;
- Maintain confidentiality;
- Attend meetings at the time and place designated;
- Give as much notice as possible when they or their representative cannot attend formal meetings and be reasonable when suggesting alternatives, (which must be within 5 working days of the original date).
**Manager's responsibility**
Managers must ensure that their employees are made aware of the standards expected and that:
- Employees are aware of the sickness absence arrangements and for reporting absence to their line manager/supervisor;
- Employees enter their sickness absence on Oracle HR Self Service (where they have access to this);
- Employees are aware of the support that is available including the Employee Assistance Programme (EAP) and Access to Work (ATW);
- Where appropriate, reasonable adjustments are made for employees Managers must comply with arrangements detailed in this Procedure which are designed to ensure that concerns about sickness absence and/or attendance are dealt with fairly and objectively. Managers are required to:
- Manage absence levels within their own service areas and take appropriate action when the “trigger points” are reached;
- Ensure that sickness absence is entered on Oracle HR Self Service, the line manager is responsible for entering this where employees do not have access to Oracle or on the 4th consecutive day of absence;
- Carry out a “return to work” interview for every sickness absence and record this on Oracle HR Self-service;
- Ensure that medical certificates are provided as required and forward copies to Payroll promptly to avoid any over/underpayments of salary;
- Maintain regular contact with employees on sick leave, especially those on long-term absence and ensure that the employee is aware of their responsibility to keep in touch and at what intervals;
- Notify the employee of any concerns about their sickness absence and/or attendance;
- Maintain confidentiality;
- Try and resolve concerns about sickness absence and/or attendance or as they arise with the employee through informal discussion and advice, (this may include referral to Occupational Health) before the “triggers” are reached:
- Ensure that any actions and/or reasonable adjustments agreed following referral to Occupational Health or Access to Work (ATW) are implemented;
- Consult the Human Resources Employee Relations Team before proceeding to the formal stages of the Procedure.
**Employee supervision**
Any concerns should be raised and investigated by the employee’s immediate supervisor/manager at the “return to work” interview and as part of the normal supervision process. This includes identifying with the employee any issues that may affect the individual’s attendance.
**Absence Reviews**
The purpose of the Absence Review is to formally review with the employee their sickness absence and any underlying causes; why the absence is causing concern and the impact on the service and work colleagues; and how to reduce the level of absence. It is intended as a supportive not a “disciplinary” process and will be conducted by the employee’s line-manager. HR will also attend the meeting and the employee may be represented.
Advice should be sought from the Human Resources, Employee Relations Team if there are any concerns as to arrangements for the Absence Review. Absence Hearings
Hearings where sanctions e.g. warnings or dismissal may be considered will be conducted by a Corporate or Divisional Director or Group Manager with the authority to chair a hearing and to issue any sanctions.
In the case of JNC officers, a Member Panel consisting of the Leader and Deputy Leader of the Council (as Chair and Deputy Chair respectively), the relevant port-folio holder, plus at least two other councillors:
i) will make decisions in respect of the dismissal and consider disciplinary action in respect of all JNC Officers with the exception of the Chief Executive (Head of Paid Service), Monitoring Officer and Chief Financial Officer (Section 151 Officer), whose cases will additionally require the involvement of an independent person, and
ii) in the case of dismissal, be subject to recommendations to the Assembly.
Occupational Health
Employees should not be automatically referred on reaching the “trigger points” unless there is a specific need for Occupational Health advice e.g. is there any need to refer an employee whose absence is due to a broken limb?
Line managers may, after discussion with the Human Resources Employee Relation Team, refer employees to Occupational Health at any time when there is a concern as to the individual’s health or reason(s) for absence.
Where employees submit a medical statement giving stress, (including anxiety or depression), as the reason for absence, they should be automatically referred by the manager to Occupational Health after 2 weeks continuous absence.
Occupational Health will seek the employee’s consent if they need to contact the individual’s doctor or an independent medical practitioner; if consent is refused, Occupational Health will advise managers on the information available to them.
Reasonable adjustments and Access to Work (ATW)
Under the Equality Act 2010, there is a duty to make “reasonable adjustments” to enable disabled employees to remain in employment; examples may include:
- Special equipment, aids and adaptations
- Altering working hours and times
- Making provision for additional absence for disability related treatment
- Adjustments to premises or changing the actual place of work
- Transfer of some duties to another post
- Transferring or redeploying the employee to a suitable alternative post
Guidance on reasonable adjustments and ATW is available on the HR Intranet site at: http://lbbdstaff/HR/Pages/equality.aspx Human Resources
Procedural advice must always be sought from Human Resources. A Human Resources Adviser will attend all formal Absence Reviews, Absence Hearings and Appeals (at 4.3-4.5), to ensure a thorough and fair process for all concerned in line with the Council’s procedures and “Best Practice”.
Human Resources will be available to give appropriate support and advice during the process; this will include:-
- talking through the process to be followed
- where to go for further help and support
Head of Human Resources
The Head of Human Resources and his/her named representative, has the overriding authority to ensure that concerns about sickness absence and/or attendance are dealt with appropriately and in accordance with this Procedure, employment legislation and “Best Practice”.
4. Absence Process
It is essential that any concerns as the employee’s sickness absence and/or attendance are raised with the individual as soon as possible; this will normally be done through the “return to work” interview or regular supervision meetings.
In accordance with the principles of natural justice, employees will be advised at each stage, by their manager of the precise nature of the concerns about their absence or attendance and given the opportunity to respond before any decision is made. The individual will also have the right of appeal against any action taken e.g. warnings or dismissal, after a Hearing.
Employees will not be dismissed before the matter has been discussed at an absence review meeting where the employee will be given an opportunity, to reduce their sickness absence and/or to return to work, and other alternatives considered e.g. reasonable adjustments or redeployment if appropriate.
4.1 Managing attendance and sickness absence
The intention is to try and resolve concerns about the employee’s sickness absence and/or attendance informally where possible, and to help them improve their attendance record and/or to return to work where possible. It is important to try and identify whether:
i) there are any underlying reasons for intermittent or short-term absence; ii) there is any support that may be provided to employees on long-term sickness and to help them back into work (See Appendix 2); iii) reasonable adjustments have been considered for employees including those with a disability or long-term medical condition. Managers also need to ensure that:
- the employee has been made aware of the absence reporting arrangements and support available to staff e.g. Staff Welfare Line;
- the employee has had “return to work” interviews, and regular supervision / 1-1 meetings;
- where appropriate reasonable adjustments have been made for employees (and that these are being used and supportive);
- the employee has been made aware of any concerns and given a reasonable opportunity to reduce their absence and/or return to work.
The employee should be kept informed of the nature of the concerns, the level of improvement required and the time limit for achieving this. They should also be advised that failure to reduce their sickness absence and improve their attendance may lead to formal action being taken.
In long-term sickness cases, managers should maintain regular contact with the employee and obtain medical advice as early as possible as to the prognosis and what support may help them return to work.
4.2 “Trigger Points”
The “trigger points” are those where managers are required to take appropriate action according to the circumstances of the case i.e.:
- Meeting the employee to discuss
- their sickness absence and attendance and the impact at work
- support that may be available e.g. Staff Welfare line or parental leave see Appendix 2
- Encourage the employee to contact Access to Work (ATW) or refer them to Occupational Health (after discussion with the Human Resources Employee Relation Team
- Progress to a formal Absence Review
Managers should take into account the reason(s) for sickness absence and the employee’s attendance record i.e. if they have not taken any sickness during the previous three years and a certified period of absence e.g. for flu, then takes them past the “trigger points”, it may not be appropriate to progress to a formal Absence Review on that occasion but it may be if there is any further absence.
It is important to note that the “trigger points”:
i. are not for referrals to Occupational Health and managers should only refer employees where they need specific medical advice; ii. may exclude absence agreed as a reasonable adjustment for time-off taken to attend appointments or rehabilitation specifically related to disability, (or whilst waiting for agreed adjustments to be implemented).
The amount that may be allowed as a reasonable adjustment will depend on the individual circumstances of the case and the needs of the service. iii. will exclude absence specifically related to maternity or pregnancy but advice must be sought from the Human Resources, Employee Relations Team in these cases.
Managers should take advice from the Human Resources, Employees Relations Team as to what absence may be excluded. Pregnancy related illness should not be included when using the trigger points.
The minimum “trigger points”, (which will be reviewed annually), for entry to the formal stages as follows;
- 3 separate occasions of sickness within any 12 month rolling period; or
- 7 days sickness absence within any 12 month rolling period or
- any absence or pattern of absence that causes concern \*
- A points level (to be agreed) based on the number of days and periods of absence, using the “Bradford factor”
* this includes sickness immediately before or after annual/flexi leave, weekends or public holidays; or on days where requests for leave have not been approved; or during events e.g. Wimbledon or World Cup; or where employees reached the sickness absence trigger points in previous years)
4.3 Absence Review
Managers must consult Human Resources before proceeding to an Absence Review.
The Absence Review will be conducted by the employee’s line manager and a Human Resources Adviser will attend to provide procedural advice.
The manager may arrange for a note-taker to be present where they agree this is necessary, following discussion with Human Resources Employee Relation Team. (If notes are taken and the employee disagrees with these, they can ask for their version to be attached).
The manager will write and give the employee a minimum of 5 working days notice of the date and arrangements for the Absence Review including:
- a copy of their sickness record, including the dates and reasons given;
- details of any reasonable adjustments agreed and provided;
- their right to be represented;
The employee may be accompanied by a fellow work colleague or a trade union official and is responsible for arranging their representation. If the employee’s chosen representative is unable to attend, the Absence Review will be rescheduled to a mutually convenient time no more than 5 working days after the date originally proposed. The employee will be notified in writing that if they fail to attend the re-arranged Absence Review without good reason, or to arrange representation, the review may be heard in their absence.
The purpose of the Absence Review is to:
- Confirm the dates and periods of sickness absence in the previous 12 month period and ensure that the records are accurate and up to date.
- Review the employee’s sickness absence and explore any underlying causes.
- Give the employee an opportunity to explain the circumstances of their absence and to bring to their manager’s attention any disability or any other circumstances that may affect their health or attendance at work.
- Explain and ensure that the employee understands the effects of any period of sickness absence on the work of the team, group, department and the ability of the Council to meet its service delivery objectives.
- Consider further options to help reduce the employee’s level of absence. These include referral to Occupational Health or Access to Work following discussion with the Human Resources Employee Relations Team.
- Review the type of work that they do including exploring the option of reasonable adjustments for a defined period and/or where appropriate, redeployment.
- Explain why the absence levels are unacceptable and that formal action and dismissal under the Procedure is likely to result if they continue to breach the “trigger” levels or are unable to return to their substantive post.
The manager will notify the employee in writing of the outcome of the Absence Review within 5 working days, and inform them that any further absence during the following monitoring/review period of up to 12 months may result in a further review meeting or the convening of an absence hearing.
In long term sickness cases, a date should be agreed for another absence review meeting or an absence hearing depending on the circumstances of the case and likely date of return.
The outcome letter will include:-
- The period of absence(s)
- The employee’s reason(s) for absence.
- The action plan, including arrangements for the monitoring/review period.
- Where dismissal may be considered i.e, if they fail to meet the required improvement, or, are unlikely to return from long-term absence.
A copy of the letter should be passed to Human Resources Employee Relation Team to place on their personal file. Monitoring/Review Period
The manager must continue to monitor the employee’s sickness absence and/or attendance during the review period and ensure that any support and training agreed is provided.
Where at the end of the review period, the employee has achieved the required improvement no further action will be taken.
4.4 Absence Hearing
The arrangements for the Absence Hearing follow the same process as for a Absence Review but will be conducted by a Corporate or Divisional Director or Manager with the authority to chair a hearing and to issue any sanctions e.g. issue warnings or dismissal (or Member Panel for JNC Officers).
The management case should normally be presented by the line manager who will arrange for the employee to be formally advised in writing of the date and arrangements for the Absence Hearing, including the right to be accompanied by a fellow work colleague or a trade union official.
The arrangements for the Absence Hearing are detailed at Appendix 3.
Outcome
The purpose of the Absence Hearing is to:
- Confirm the dates and periods of sickness absence and ensure that the records are accurate and up to date.
- Review the employee’s absence record and the latest medical opinion.
- Give the employee an opportunity to explain the circumstances of their absence and to bring to the Hearing Officer’s attention any disability or other relevant issues affecting their health or attendance at work and/or any mitigating circumstances.
- Review the type of work that the employee does and the impact of sickness absence on service delivery and work colleagues.
- Review the support that has been provided and any previous efforts to help the employee back to work and/or improve attendance, including reasonable adjustments.
- Where appropriate, consider the availability of suitable alternative work if requested by Occupational Health.
Each case will be considered on its merits and when considering an outcome the Hearing Officer should take into account:
- The overall attendance record;
- The latest medical advice which may include Occupational Health reports;
- The likelihood of an improved attendance record being achieved by the employee or the employee returning to work; • The effect of the employee’s ill health or absence on the needs of the service; • The employees explanation and any mitigating circumstances; • Consideration of adaptations to the work and/or working environment, including any further reasonable adjustments; • Options for redeployment if suggested by Occupational Health; • Whether the employee has previously been advised that there is a risk to their continued employment and that they may be dismissed; • Whether the proposed decision is reasonable in all the circumstances (taking into account the individual’s service history and action taken in similar cases).
The Hearing Officer may decide from the following options:
i) **Adjournment**
To adjourn the Hearing pending further consideration/ investigation of issues raised before reconvening to decide on the outcome.
Where the employee wants to present additional medical reports, these must be submitted within 2 weeks of the date of the Hearing or the timescale agreed with the Hearing Officer and manager.
ii) **No Further Action**
Where it is decided there is no need for further action at this time but the situation will be kept under review.
iii) **Written warning - (Not for continuous long-term absence cases)**
The Hearing Officer should ensure that the employee is clear about the reasons for the warning, and the consequences of failure to meet and maintain the required attendance. The letter will set out the:
- details of the sickness absence and/or unsatisfactory attendance
- employee’s explanation and/or reasons
- attendance improvement plan and monitoring arrangements
- arrangements for any support during the Review Period
- timescale for the Review Period
The duration of the Review Period will depend on the circumstances of each case and is normally up to 12 months, starting from the date of the letter notifying the employee of the outcome. The employee should be informed that any further absence during the review period will normally result in the matter being referred directly to an Absence Hearing where dismissal could be a possible outcome.
Note: Managers must ensure that any support agreed is provided as it will be unfair to progress the case back to an Absence Hearing if they themselves have not complied with the outcome. iv) **Dismissal**
If it is considered that all agreed support mechanisms have been put in place and/or the employee cannot confirm a return to work date, the Hearing Officer may decide to dismiss; the employee will be paid in lieu of notice.
The Hearing Officer will notify the employee in writing of the outcome of the Hearing within 5 working days, including any recommendations, along with the right to appeal.
**4.5 Appeals**
Employees have the right to appeal against a warning or dismissal and if they wish to do so, they should write to HR Manager, Employee Relations within 10 working days of receiving the letter confirming the outcome of the Review or Hearing, stating the grounds for the appeal.
Appeals against written warnings will be heard by a Corporate or Divisional Director. Appeals against dismissal will be heard by the Personnel Board.
The Officer/Panel hearing the appeal may vary or confirm the decision made at an Absence Hearing but cannot increase the sanction.
**Note:**
i) A Director or Head of Service with the responsibility to chair an Appeal Hearing will hear appeals against sanctions against officers up to and including LSMR posts. Appeals against final warnings and dismissal will be heard by Members at a Personnel Board.
ii) A Member Panel consisting of at least two Cabinet Members, one of whom shall be appointed as Chair, plus two other councillors, subject to none having participated in any previously appointed Panel relating to the case in question, to:
(i) consider appeals in respect of dismissal and disciplinary action from JNC Officers; (ii) consider, with the involvement of a separate independent person, appeals in respect of disciplinary action against the Chief Executive (Head of Paid Service), Monitoring Officer and Chief Financial Officer (Section 151 Officer); and (iii) in the case of dismissal, this will be subject to recommendations to the Assembly
**This is the final stage; there is no further right of appeal.**
Human Resources will automatically update the Procedure to comply with any changes to legislation and / or ACAS guidance and notify employees of the amendments. Appendix 1: Managing Attendance at Work (Sickness Absence) Procedure – Flowchart
Supervision (Informal)
Employee Supervision (Return to Work Interviews / Monthly supervision / “1-1’s”) Line Manager carries out return to work interviews immediately after each absence and records this on Oracle Line Manager raises any concerns as to employee’s attendance with them as soon as possible at the return to work interview or during the supervision process; managers should
- ensure employees are aware of the EAP and other support arrangements
- consider reasonable adjustments for disabled employees
Employee reaches the “Trigger Points” Line Manager must meet with the employee to discuss their absence and take action as follows: i) Make sure that the employee knows what support is available; ii) Refer to Occupational Health if appropriate (after discussion with HR Employee Relation Teams); and iii) Decide that no further action is required at this time and record the reason(s) why; or Progress to a formal Absence Review
Absence Review (Formal)
Absence Review Line Manager explains concerns, including details of attempts to resolve these, with the employee and sets revised targets and timescale (up to 12 months) for improvement and/or review. In long-term sickness cases, a date should be set for another Absence Review (or an Absence Hearing) depending on the circumstances of the case and likely date of return.
Review / Monitoring Period Line Manager continues to monitor employee’s sickness and/or attendance, and ensure that any support and/or training agreed is provided and being followed and/or used. Note: The Line Manager does not have to wait to the end of the review period to reconvene an Absence Review or progress to an Absence Hearing where the employee is not meeting the targets or using the support provided.
No Further Action where the employee reaches and maintains required improvement
Absence Hearing (Formal)
Absence Hearing Where employee has not met and maintained the required improvement or is unlikely to return to work
No Further Action where the employee reaches and maintains required improvement
Written / Final Warning (excluding long-term cases) with review period (up to 12 months)
Dismissal
Appeal Appendix 2: Details of Support Arrangements
i) OHS&W support http://lbbdstaff/HR/Pages/OHandHS.aspx
ii) Staff welfare line http://lbbdstaff/HR/Pages/Employee-Welfare-Line.aspx
iii) Links to guidance on reasonable adjustments and the BDF practical guides http://lbbdstaff/HR/Pages/equality.aspx
iv) Access to Work
Further information
- www.gov.uk/access-to-work
- Access to Work Factsheet
- Employer’s Guide to Access to Work
Contact: Telephone: 020 8426 3110 Textphone: 020 8426 3133 Email: [email protected]
v) Special Leave and Time-off Arrangements http://lbbdstaff/HR/Pages/Holidayleave.aspx Appendix 3: Absence Hearing - Procedure
1. Introduction
- The person hearing the case at the Hearing (the “Hearing Officer”) will; clarify the roles of those present; check both sides have copies of the documentation (and where appropriate, details of any witnesses to be presented); and outline the process to be followed.
- The Hearing Officer will not normally allow any further documentation, (or witnesses), to be presented unless both sides agree.
- The manager presenting the case, the employee and their representative will be present throughout the Hearing except for any adjournment and when the Hearing Officer is considering their decision.
- Any witnesses will only be present when they are called to give their evidence and to be questioned by the Hearing Officer, the management and staff sides.
- The Hearing Officer and HR Adviser can ask questions of the manager, the employee and/or their representative (and witnesses) at any time.
2. Management case
- Management will present their case and call witnesses and refer to documents as appropriate
- After the presentation, the employee and/or their representative can ask the management questions
- Management will then have the opportunity to clarify any points raised during questioning.
3. Employee case
- The employee and/or their representative will present their case and call witnesses and refer to documents as appropriate.
- After the presentation, management can ask the employee and/or their representative questions.
- The employee and/or their representative will then have the opportunity to clarify any points raised during the questioning.
4. Summaries
- Both sides, starting with management, will have the opportunity to summarise their case if they wish. This is not a rehearing of the whole case and neither side will be allowed to ask any further questions.
- Both sides will then withdraw whilst the Hearing Officer considers their decision. If it is necessary to recall the employee, manager or a witness to clarify points of uncertainty as to the evidence presented, this must be done in the presence of both parties who will be called back together.
5. Outcome
- The Hearing Officer will recall both sides together to notify them of the outcome. If further time is needed to consider the matter, both sides will be recalled and given an indication as to when a decision is to be made and allowed to leave.
- The Hearing Officer will confirm the decision and any recommendation(s) in writing within 5 working days and arrange for the notes of the meeting to be issued to both parties and the Human Resources Adviser as soon as possible afterwards.
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c84cd6dae3057056ee40b9b6f4f4219c105d05cb | Internal Audit Report
Pensions Administration January 2018
To: Assistant Chief Executive Strategic HR Lead Barnet Partnership Director, CSG Operations Director, CSG Business Manager, CSG HR Solutions Head of Business Assurance, CSG Employee Benefits Head of Public Sector Pensions, Capita
Copied to: Director of Finance Head of Finance Head of Governance Governance Service Team Leader Operational Delivery Manager, CSG HR Director, CSG Operations Director, CSG
From: Head of Internal Audit
We would like to thank management and staff of Capita Employee Benefits for their time and co-operation during the course of the internal audit.
Cross Council Assurance Service Executive Summary
| Assurance level | Number of recommendations by risk category | |-----------------|------------------------------------------| | LIMITED ASSURANCE | Critical | High | Medium | Low | Advisory | | | - | 2 | 6 | 1 | - |
Scope
This report sets out the findings of our work undertaken in October and November 2017 to review the design and operating effectiveness of controls in place in relation to pensions administration, in line with our terms of reference agreed on 9 October 2017. The scope of work and controls identified are summarised in Appendix 3.
Summary of findings
The administration of London Borough of Barnet’s pension fund (“the fund” or “the scheme”) is outsourced to Customer Support Group (“CSG”, part of Capita) who are responsible for working with scheme employers to ensure that the records are kept up to date and that members are supplied with correct information regarding their pension entitlements. The Council, as administering authority, is currently subject to scrutiny by The Pensions Regulator (“TPR”) in light of concerns raised when it investigated the Council’s failure to submit its 2016 annual return. Correspondence between the Council and TPR highlights several weaknesses in the control environment of the fund and the Council are in regular correspondence with them to provide evidence that controls have been developed and are being embedded. The Council issued CSG with a contractual remedy notice on 25 August 2017 in light of the issues being experienced with the service. The Council also agreed a service improvement plan in August 2017 with CSG as a result of these enquiries, covering the quality assurance, project management and communications improvements needed to ensure the scheme complies with TPR’s requirements. Progress against this plan is being regularly monitored at monthly senior officer meetings. It was reported to the Local Pensions Board that the 2017 scheme return was submitted on 10 November 2017, ahead of the 22 November 2017 deadline.
We found that scheme member transactions are mostly well managed through Hartlink, the pension fund administration system, but that there are weaknesses in the processes which take place outside Hartlink, such as the annual benefits statement process, and governance of scheme administration. A review of data quality has also identified significant issues and the arrangements with scheme employers means that the scheme currently has limited ways of encouraging compliance with scheme working practices. The scheme will need to invest in improving the quality of existing data and the data gathered in future. We acknowledge that this may be a costly exercise, however, the scheme has the ability to charge scheme employers for this data quality work both now and in the future under regulation 70 of The Local Government Pensions Scheme Regulations 2013, providing the reason for the rectification work is due to scheme employers failing to meet its obligations. Going forward, the scheme will also need to work more closely with employers, for example by engaging proactively when changes to membership are detected, and will need to consider both exercising its right to report employers to TPR if employers do not comply with legal requirements and charging additional costs incurred resolving issues to employers as permitted by the scheme regulations.
This audit has identified two high, six medium and one low risk findings.
We identified the following high risk-rated issues as part of the audit:
- **Scheme data quality (finding one)** – A data quality review undertaken by CSG, on behalf of the Council, in October 2017 identified that the quality of data held to identify team members is below the standards expected by TPR, with 85% of records created before June 2010 containing missing information compared to a target of 95%. We also identified that a data quality review of the data used to calculate benefits and value the fund has not been undertaken, but a review is currently being scoped. We also found that there were issues in the data provided to CSG by employers for 60% of the employers reviewed and that there was no reporting on the nature and extent of data quality issues noted. This increases the risk of inaccurate data being held by the scheme and delays in preparing annual benefits statements not being identified.
- **Preparation of annual benefit statements (finding two)** – We found that there were weaknesses in the project management of the annual benefits statement process which meant that the results of data quality checks for a number of employers, from whom data was received in May 2017, were not communicated until mid-July 2017 reducing the period available to resolve any issues from three months to one month. We also found that there were a number of active member records for which no benefit statement was prepared due to a lack of data. This led to some members receiving annual benefit statements after the statutory deadline of 31 August 2017, or not at all. This was an area of concern raised by TPR when it considered the 2015/16 annual benefit statements process.
We identified the following medium risk-rated issues as part of the audit:
- **Retirement benefit calculations (finding three)** – A number of retirees received their benefits over 30 days after they retired as a result of delays in notifying the scheme of their intention to retire, either by the employee or employer. We also found that annual benefit statements did not communicate the timescales involved in retirements leading to members not being aware of the timescales involved. There is a risk that retirees may not receive their benefits promptly leading to financial hardship.
- **Governance of scheme administration (finding four)** – We found that contract monitoring meetings held to monitor the pension administration section of the CSG contract were not formally recorded by the Council and that the employer targets for the scheme administration strategy are not monitored. This could lead to the Council not identifying breaches of laws and regulations.
- **Communication strategy (finding five)** – There was no scheme communication strategy or agreed fund administration strategy in place during the period under review. This could lead to scheme members having an expectation gap between what they expect and what is provided by the scheme or scheme records may be incomplete as a result of employers not working effectively with the administration team.
- **New members and impact on data quality (finding six)** – The scheme does not follow up on new joiners identified outside of the usual notification process and there were duplicate records. This could lead to members not being aware of their entitlement or leading to breaches of legal requirements in relation to transfers out.
- **Transfers (finding seven)** – There were some delays in the payment of transfers out of the fund and issuing letters to scheme members once the transfer took place. This could lead to members not being aware of their entitlement or leading to breaches of legal requirements in relation to transfers out.
- **Breaches of law (finding eight)** – The Council did not have a breaches of law policy in place until late October 2017 and does not receive reporting on possible breaches of law. TPR also identified that CSG did not report a breach of law when 2016 annual benefit statements were issued late. The Council may not report matters required to TPR leading to them being exposed to fines or other civil action by TPR.
We identified the following low risk-rated issue as part of the audit:
- **Creation of new members records (finding nine)** – A large number of records were created and authorised outside of the timespan stated in the scheme administration strategy. This could lead to the scheme’s membership numbers and record of benefits earned being understated.
## 2. Findings, Recommendations and Action Plan
| Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 1. | **Scheme data quality**<br><br>*Control design*<br>The Council’s pension fund is required to hold a large amount of data on scheme members. This data is used to contact members and calculate benefits. The scheme is now a career revalued earnings (CARE) scheme, for benefits earned after 1 April 2014 which means that the scheme is required to hold data on pensionable pay for each year since that date to calculate each member’s pension entitlements correctly. TPR expect that schemes review their data annually and implement improvement plans where poor quality or missing data is identified. Prior to this year, no reviews had been undertaken of data held. During the audit, we noted that:<br><br>- One data quality review was undertaken by CSG on behalf of the Council during the period to identify whether data held by the scheme is complete. This focused on “common data”, a dataset specified by TPR as being data required to uniquely identify scheme members. Data held passed for 85% of members for whom records were created before June 2010 and 91% for records created after June 2010. These are below TPR’s target of 95% and 100% respectively. At the time of our fieldwork (October/November 2017), the results were being communicated to the Council. CSG are currently working with the Council to agree a plan to resolve the data quality issues noted as part of the agreed service improvement plan.<br>- There has been no recent review of the quality of<br> | If inaccurate or incomplete data is held on scheme members, then benefits paid to members may be incorrect or members may be provided with incorrect information on their pension entitlement. If inaccurate or incomplete data is provided to the scheme’s actuary, the valuation of the scheme may be inaccurate which could lead to scheme employers being under or overcharged deficit reduction contributions. The extent of data quality issues may not be known leading to unexpected delays in providing information to scheme members. | HIGH | **Agreed Action:**<br>a) We will deliver the improvement plan, as agreed with the scheme manager, to improve data quality so as to meet TPR’s target standards. We will also consider recovering the cost of this from employers, where the reason for the data quality issues is their failure to fulfil their obligations to the scheme and if employers are unable to assist with the update of members’ records we will consider if this is a breach of law reportable to TPR.<br>b) We will review the quality of conditional data by 28 February 2018 as per the agreed service improvement plan and will update this data, as agreed with the scheme manager, prior to the triennial review of the fund due as at 31 March 2019.<br>c) We will discuss how to complete employer’s end of year returns at the planned employers’ forum to ensure that employers are aware of requirements. We will inform | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | “conditional data”, defined by TPR as being the data required to calculate pension benefits. The service improvement plan specifies that a review of conditional data quality will be completed by 28 February 2018. In order to update data held by the scheme, CSG receives an annual submission from scheme employers which includes current full time equivalent salary, qualifying pay in the period and contributions deducted in the period. This return is used to update Hartlink and is used to prepare annual benefit statements. This exercise usually identifies data quality issues, for example, 12/20 employer returns that we reviewed identified new members who had not been notified to the scheme. For each of these employers, CSG wrote to employers to request the appropriate forms were supplied to allow CSG to create new member records. We found that: | | | employers that they will need to sign a statement saying that what has been submitted is accurate, and that they have done their own checks prior to submission. We will also ensure scheme employers are aware of our ability to charge them the cost of undertaking work to rectify issues in their initial submissions. d) We will ensure analytical reviews are undertaken over contributions received and reported to ensure movements reported are reasonable and reconciliations will be performed between amounts reported and the general ledger. We will consider if any further assurance is required over the accuracy of contributions received, considering whether sufficient assurance is provided by reviews undertaken by internal audit and external audit both at the Council and employers. e) We will create a checklist which will be used to evidence the review of end of year returns. These checks will include reviewing whether data is provided for all active member records. f) We will log data quality issues identified by type of issue and both record and monitor the number of | | | | | | | • The pensions administration team does not have a detailed checklist of items it reviews for each submission which is retained with the submissions to evidence the completion of their review; • The pensions administration team does not perform a check on each employer submission to ensure that all employees who are logged as active members of the scheme for that employer have information provided; • There is no monitoring and reporting of the nature and extent of data quality issues identified in the submissions made by employers, such as new members not notified to the scheme and unusual salaries, and the subsequent resolution of these issues; and • The pensions administration team does not undertake | | | | | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | to ensure that the correct contributions have been deducted by employers for employees. This is due to employee contribution rates fluctuating month on month and this would require them to undertake a detailed review of monthly pay to confirm contributions are correct. It should be noted that responsibility for deducting the correct contributions lies with the individual employer. These data issues are most likely to affect the actuarial valuation of the scheme as most data held is validated with scheme employers before benefits are paid. However, for benefits earned after 1 April 2014, the start of the CARE scheme, this check may become ineffective as the period between benefits being earned and benefits paid increases. | records not loaded to Hartlink. A summary of issues encountered will be presented annually to the Local Pension Board and employers. | HIGH | Responsible officer: (Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits) | | | | | | Target date: | | | | | | a) 31st August 2018 | | | | | | b) 28th February 2018 (analysis completed) / 31st March 2019 (data rectification complete) | | | | | | c) 28th February 2018 | | | | | | d) 30th June 2018 | | | | | | e) 30th April 2018 | | | | | | f) 31st May 2018 |
2. **Preparation of annual benefit statements**
*Control design and operating effectiveness*
The scheme is required to issue annual benefit statements, which report each member’s accumulated pension entitlements at the end of the financial year, by 31 August of each year. There are a number of steps involved in the process including, uploading of end of year returns and uplifting accumulated benefits in the CARE section of the scheme by the index.
We noted the following control design deficiencies in the process to collect returns for the year-ended 31 March
| | | | | Agreed Action: | | | | | | a) We will prepare a detailed project plan for the provision of annual benefit statements, as well as the other key milestones in the Scheme Year Planner and the Triennial valuation, and this will be approved by the Council. Progress will be monitored and managed by | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 2017: | • Chasing of late end of year returns by the pensions administration team took place one month after forms became due, reducing the time to resolve any data quality issues by 3½ months to 2½ months; • The vast majority of data quality issues required to be resolved by scheme employers were communicated to employers in mid-July 2017. Given that a large number of employers are schools, this makes it less likely that responses will be received in time to meet a 31 August 2017 deadline; • There is no documented process for reviewing and evidencing the review of the accuracy of calculations performed within Hartlink which are used to populate annual benefit statements; and • There is no formal monitoring and reporting to the Local Pension Board of the number of benefit statements not issued. We tested a sample 25 active member records to ensure that statements were issued on time. We found that: • 4/25 statements were not issued before 31 August 2017 as a result of issues identified and being resolved with employers; and • 5/25 statements were not issued as no end of year return data was held. This is thought to be due to employers not notifying the scheme of leavers. CSG management have identified that there are potentially over 1,000 such records. Through discussions with CSG management, we note that there is an intention to allocate specialist project managers to the 2018 annual benefits statement process. | | | specialist project managers. Progress against the agreed plan will be reported to the monthly CSG pensions administration contract monitoring meetings.(see finding 5) b) We will introduce a process for reviewing calculations used to populate annual benefit statements. This will include sampling of calculations and also how this is evidenced c) We will work with scheme employers to close active records where no employment data has been reported in 2016/17. d) We will consider how we can change the relationship with employers and their payroll providers to encourage compliance with scheme requirements, such as reminding employers of the scheme’s ability to recharge the cost of any rectification work undertaken by the fund, and reporting employers to TPR for breaches of law. Responsible officer: (Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits) Target date: | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | | | | a) 31<sup>st</sup> March 2018 | | | | | | b) 31<sup>st</sup> May 2018 | | | | | | c) 31<sup>st</sup> August 2018 | | | | | | d) 28<sup>th</sup> February 2018 |
3. **Timeliness of the notification of planned retirements**
*Control design and operating effectiveness*
The draft fund administration strategy (see finding 6) states that scheme employers are expected to notify the pension administrations team at least 30 days before a scheme member’s expected retirement. Scheme members are then issued with retirement option forms and these are returned before payment can be authorised. Final calculations are released within 10 working days of receipt of completed option forms.
We noted the following:
- There are no communications to scheme members regarding the requirement to notify the scheme, via their employer, of any intention to retire. This means that scheme members may not be aware of the time required to complete retirement processes.
We reviewed a sample of 20 retirements in the period and found that:
- 10/20 retirees were paid lump sums more than 30 days after their retirement date. The root cause of the delays were one or a combination of: late notification by the employer; employers failing to promptly answer queries on information provided; or delays in receiving completed option forms from members.
If benefits are not calculated correctly or paid to retirees promptly then retirees may suffer financial hardship and the Council may suffer reputational damage
**Agreed Action:**
a) Scheme members will be informed of retirement timescales by including this information in newsletters sent with annual benefit statements and other communications.
b) We will remind employers of the need to promptly notify the scheme of potential retirements and use information provided by employers to proactively identify potential retirees.
c) The scheme’s communication strategy will include communicating with members nearing retirement to proactively engage with them regarding their retirement.
**Responsible officer:**
(Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits) | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | | | | Target date: | | | | | | a) 31st March 2018 | | | | | | b) 28th February 2018 | | | | | | c) 31st January 2018 |
4. **Governance of scheme administration**
*Control design*
The Council’s Pension Fund Committee is the ‘scheme manager’ and as such has overall responsibility for the pension scheme. It has been agreed that the Local Pension Board will oversee the administration of the scheme, including the performance of CSG.
CSG are responsible for managing the administration of the scheme. There is a group, comprising senior Council officers and CSG staff, who meet monthly to monitor the pensions administration part of the CSG contract.
We found that:
- During the period under review, meetings of the group which monitors the pensions administration part of the CSG contract were not formally minuted by the Council;
- A formal risk register reviewing scheme administration risks did not exist before August 2017 and was first reported to the Local Pensions Board on 11 September 2017; and
- The draft fund administration strategy specifies certain targets to be met by scheme employers, including the provision of data to the administrator at the end of each scheme year and the provision of information regarding new members. Compliance
If management information does not monitor compliance with the fund administration strategy then the Council may breach legal requirements leading to fines and further reputational damage.
**Agreed Action:**
a) We will review the risk register at each governance meeting and ensure these meetings are minuted.
b) We will agree a Terms of Reference for the monthly governance meetings.
c) We will investigate how we can report on the compliance of employers and payroll providers with the fund administration strategy, once adopted and report management information produced to the Local Pensions Board.
**Responsible officer:**
a) and c) (Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits)
b) (Head of Business Assurance, CSG Employee Benefits) / | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | with these targets is not monitored and reported to the Council or the Local Pensions Board. There are also regular meetings between CSG, the Council and the Trade Union to discuss the actions being taken to address a number of issues the Trade Union has raised. | | | (Strategic HR Lead) | | | | | | Target date: | | | | | | a) 11th January 2018 | | | | | | b) Complete | | | | | | c) 31st March 2018 |
5. **Communication strategy**\
*Control design and operating effectiveness*
The pension fund is required to communicate with its stakeholders, including scheme members and scheme employers. It is normal practice for key information on the fund to be held on the Council’s website so that employers and scheme members, whether active, deferred or pension members, can access the information. TPR requires that the scheme has a strategy to communicate with members and identifies that members should receive information when they join the scheme and as scheme terms vary.
We found that:
- There is no strategy for communication with scheme employers and members beyond requesting the information required, such as the end of year return information. This has been identified within the service improvement plan and is due to be agreed and implemented before the start of 2018.
- The LGPS section of the Council’s website was last updated in 2014 and does not contain up to date information on the scheme or contact information for the current administration team.
- There was no agreed fund administration strategy, If there is not a clear communication strategy with scheme members then there may be an expectation gap between what members expect and what is provided leading to increased complaints.
- If there is no clear communication strategy with employers, then scheme members may receive a below standard service or scheme records may be inaccurate or incomplete leading to under or overpayments of benefits.
**Agreed Action:**
- A communication strategy, including the provision of sufficient quality assurance over communications with members and employers, will be developed and agreed by the Local Pensions Board.
- A flowchart will be created for retiring members to enhance clarity around what they should expect to happen when.
- Responsibility will be agreed for keeping the LGPS section of the Council’s website updated regarding the operation of the LGPS scheme and a process for ensuring this remains up to date will be included in the communications strategy.
- The fund administration strategy | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | specifying what is expected of scheme employers, in place during the period under review. However, a draft strategy was approved, subject to consultation with employers, at the 11 September 2017 meeting of the Local Pension Board. | | | will be finalised and issued to scheme employers. We will also ensure employers are aware of the scheme’s ability to recover costs incurred through not complying with the administration strategy and that non-compliance with the strategy could be construed as a breach of law, reportable to TPR. | | | • Annual benefits statements issued and scheme website do not give contact details of the CSG team responsible for pensions administration to allow them to raise any queries directly to CSG. | | | e) We will ensure that annual benefit statements and the website include contact details for the CSG pensions administration team. | | | | | | f) We will change the format of the presentation of estimates so that the Annual Benefit Statements are easier to understand. | | | | | | **Responsible officer:** | | | | | | (Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits) | | | | | | **Target date:** | | | | | | a) 14th February 2018 | | | | | | b) Complete | | | | | | c) 31st January 2018 | | | | | | d) 31st January 2018 | | | | | | e) 28th February 2018 | | | | | | f) 31st March 2018 | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 6. | **New members and impact on data quality**\
*Control design and operating effectiveness*\
Some scheme employers also provide CSG with a listing of employees and contributions paid each month. These are checked to ensure that all employees have records in Hartlink, the pension fund administration system. In addition, there is an interface between the payrolls administered by CSG and Hartlink. This is designed to identify potential duplicates and create new member records where new members are identified.\
We found the following control deficiencies:
- There is no central log of new joiners identified from a review of monthly contributions paid to the scheme. This means that records for new members may not be created promptly, leading to issues with the annual end of year returns process.
- We found that there is no review of potential duplicate records created when data is loaded to Hartlink by the interface with CSG managed payrolls. This can lead to duplicate member records, overstating the number of pension accounts.\
We tested a sample of 25 new members records created in the period. We found that:
- 1/25 records was a duplicate record. In this case, a record was created by the employer submitting a new member form and the second record by the interface between the payroll system and Hartlink. The duplicate has now been deleted. The agreement of pay and service before retirement ensures that members do not receive duplicate payments. | If records are not created for new members identified then their entitlement to future benefits may not recorded.\
Duplicate records may lead to the fund’s membership numbers being overstated and confusion for scheme members. | MEDIUM | **Agreed Action:**\
a) We will use monthly scheme returns to identify new members and potential leavers and record this in Hartlink, so as to create a task to request paperwork from employers to support the change in status of members.\
b) We will review records created by the interface between the payroll system and Hartlink to ensure that duplicate entries are resolved before Annual Benefit Statements are issued.\
**Responsible officer:**\
(Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits)\
**Target date:**\
a) 31st January 2018\
b) 30th June 2018 | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 7. | **Transfers**\
*Operating effectiveness*\
Scheme members can transfer their benefits into and out of the scheme so that their benefits sit with their current employer’s pension scheme. The Council’s draft fund administration strategy states that tasks relating to transfers should be completed by CSG within 10 working days.\
We tested a sample of two transfers into the fund to ensure that the above timescales were met and found that:
- In both cases, letters were issued to fund members more than 10 working days after completion of the transfer.\
We tested a sample of five transfers out of the fund to ensure that the above timescales were met and found that:
- In 2/5 cases, payments to other schemes were made after more than 10 working days. In one case, the transfer took over two months to be approved due to the size of the transfer.\
It should be noted that compliance with best practice turnaround times are monitored and reported to the Council and the Local Pensions Board. This best practice guidance is incorporated in the draft administration strategy which now form part of contractual SLAs.\
The most reporting to the Local Pension Board, as at the 31 October 2017, identified that there were 42 transfers which had yet to be completed which were over three months old. 4 of these related were awaiting Capita action and 38 of these were awaiting third party action. | If transfers are not updated promptly then members may have inaccurate knowledge of their pension entitlements.\
If transfers out are not actioned promptly, then the scheme may be fined by TPR and the Council may suffer reputational damage. | MEDIUM | **Agreed Action:**\
a) Work will be allocated so that the targets set in the administration strategy, which are SLA targets, are achieved.\
b) We will work with third parties to clear the backlog of transfers.\
**Responsible officer:**\
(Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits)\
**Target date:**\
a) Complete\
b) 31st March 2018 | | 8. | **Breaches of law** | | | | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | | **Control design**<br>It is a legal requirement that breaches of the law of material significance to TPR are reported to TPR. We found that: | If members or officers of the Council or the pensions administration team are not aware of the need to report breaches of law then breaches may not be reported promptly which could expose the Council to fines or other civil action. | MEDIUM | **Agreed Action:**<br>a) We will train members of staff at the Council and CSG on the scheme’s policy on breaches of law<br>b) We will maintain a record of identified breaches of law which will include any breaches of scheme requirements by employers which are breaches of law. This will be included in the monthly reporting to the governance meeting.<br>c) The Council will review breaches identified and report breaches considered to be of material significance to TPR. |<br>**Responsible officer:**<br>a) and b) (Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits)<br>c) (Strategic HR Lead)<br>**Target date:**<br>a) 31st January 2018<br>b) 11th January 2018<br>c) Ongoing and monitored through monthly reporting | | Ref | Finding | Risks | Risk category | Agreed action | |-----|---------|-------|---------------|---------------| | 9. | **Creation of new member records**\
*Operating effectiveness*\
The fund’s draft administration strategy requires that the scheme’s employers inform the pension administration team of new scheme members within 10 days of the employee becoming eligible or by the end of the month they joined, and new records should then be created within 10 days. These timescales are considered best practice for schemes.\
We tested a sample of 25 new members to confirm that new member records were established and authorised in Hartlink within 20 days of joining or 10 days of month end.\
We found that:
- 19/25 had records created outside of the period identified in the fund’s draft administration strategy. This was due to delay by employers in informing the pensions administration team of new members with the correct paperwork to create new records and delays in processing the interface between the Council’s payroll and Hartlink. Of these 12 of the new records related to members whose pay and pension arrangements are managed by CSG. | If records are not created promptly, then records of members and benefits due may be incomplete which could result in the scheme being undervalued at triennial revaluations. | LOW | **Agreed Action:**\
a) Employers will be reminded of the need to notify the scheme of new joiners promptly.\
b) We will use data provided to us by employers to identify potential new members of the scheme and log new members identified in Hartlink, pending paperwork.\
**Responsible officer:**\
(Head of Public Sector Pensions, Capita) / (Head of Business Assurance, CSG Employee Benefits)\
**Target date:**\
a) 28th February 2018\
b) 31st January 2018 |
## Appendix 1: Definition of risk categories and assurance levels in the Executive Summary
### Risk rating
| Risk rating | Immediate and significant action required. A finding that could cause: | |-------------|---------------------------------------------------------------------| | **Critical** | • Life threatening or multiple serious injuries or prolonged work place stress. Severe impact on morale & service performance (e.g. mass strike actions); or\
• Critical impact on the reputation or brand of the organisation which could threaten its future viability. Intense political and media scrutiny (i.e. front-page headlines, TV). Possible criminal or high profile civil action against the Council, members or officers; or\
• Cessation of core activities, strategies not consistent with government’s agenda, trends show service is degraded. Failure of major projects, elected Members & Senior Directors are required to intervene; or\
• Major financial loss, significant, material increase on project budget/cost. Statutory intervention triggered. Impact the whole Council. Critical breach in laws and regulations that could result in material fines or consequences. | | **High** | Action required promptly and to commence as soon as practicable where significant changes are necessary. A finding that could cause: | | | • Serious injuries or stressful experience requiring medical many workdays lost. Major impact on morale & performance of staff; or\
• Significant impact on the reputation or brand of the organisation. Scrutiny required by external agencies, inspectorates, regulators etc. Unfavourable external media coverage. Noticeable impact on public opinion; or\
• Significant disruption of core activities. Key targets missed, some services compromised. Management action required to overcome medium-term difficulties; or\
• High financial loss, significant increase on project budget/cost. Service budgets exceeded. Significant breach in laws and regulations resulting in significant fines and consequences. | | **Medium** | A finding that could cause: | | | • Injuries or stress level requiring some medical treatment, potentially some workdays lost. Some impact on morale & performance of staff; or\
• Moderate impact on the reputation or brand of the organisation. Scrutiny required by internal committees or internal audit to prevent escalation. Probable limited unfavourable media coverage; or\
• Significant short-term disruption of non-core activities. Standing orders occasionally not complied with, or services do not fully meet needs. Service action will be required; or\
• Medium financial loss, small increase on project budget/cost. Handled within the team. Moderate breach in laws and regulations resulting in significant fines and consequences. | | **Low** | A finding that could cause: | | | • Minor injuries or stress with no workdays lost or minimal medical treatment, no impact on staff morale; or\
• Minor impact on the reputation of the organisation; or\
• Minor errors in systems/operations or processes requiring action or minor delay without impact on overall schedule; or\
• Handled within normal day to day routines; or\
• Minimal financial loss, minimal effect on project budget/cost. |
### Level of assurance
| Level of assurance | | |--------------------|---------------------------------------------------------------------| | **Substantial** | There is a sound control environment with risks to key service objectives being reasonably managed. Any deficiencies identified are not cause for major concern. Recommendations will normally only be Advice and Best Practice. | | **Reasonable** | An adequate control framework is in place but there are weaknesses which may put some service objectives at risk. There are Medium priority recommendations indicating weaknesses but these do not undermine the system’s overall integrity. Any Critical recommendation will prevent this assessment, and any High recommendations would need to be mitigated by significant strengths elsewhere. | | **Limited** | There are a number of significant control weaknesses which could put the achievement of key service objectives at risk and result in error, fraud, loss or reputational damage. There are High recommendations indicating significant failings. Any Critical recommendations would need to be mitigated by significant strengths elsewhere. | | No | There are fundamental weaknesses in the control environment which jeopardise the achievement of key service objectives and could lead to significant risk of error, fraud, loss or reputational damage being suffered. | Appendix 2 – Analysis of findings
| Area | Critical | High | Medium | Low | Total | |----------------------------------------------------------------------|----------|------|--------|-----|-------| | | D | OE | D | OE | | | Managing risks | - | - | - | - | 1 | | Administration – scheme record keeping | - | - | 1 | - | 1 | | Administration – providing information to members | - | - | 1\* | - | 1 | | Administration – providing information to and receiving information from employers and other admitted bodies | - | - | 1\* | 1 | 3 | | Resolving issues – resolving disputes and breaches of law | - | - | - | - | 1 | | Governing the scheme – submitting returns | - | - | - | - | - | | Total | - | - | 2 | - | 5 |
\*Includes finding relating to control design and operating effectiveness
Key:
- Control Design Issue (D) – There is no control in place or the design of the control in place is not sufficient to mitigate the potential risks in this area.
- Operating Effectiveness Issue (OE) – Control design is adequate, however the control is not operating as intended resulting in potential risks arising in this area.
Timetable
| Terms of reference agreed: | Fieldwork commenced: | Fieldwork completed: | Draft report issued: | Management comments received: | Final report issued: | |----------------------------|----------------------|----------------------|----------------------|-----------------------------|---------------------| | 9 October 2017 | 9 October 2017 | 1 December 2017 | 5 December 2017 | 8 January 2018 | 9 January 2018 |
## Appendix 3 – Identified controls
| Area | Objective | Risks | Identified Controls | |---------------|---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Managing risks | There are defined arrangements to ensure oversight over pension administration activity and the fulfilment of requirements. | Governance arrangements may not support the Council effectively fulfilling pension administration requirements if:
- Governance responsibilities, including key accountabilities, are not clearly defined;
- Compliance with internal SLAs (for example between payroll and pensions) is not monitored to mitigate operational issues arising due to dependencies;
- Management information is not accurate or is not produced to facilitate oversight and scrutiny;
- Target timeframes are not in place to process transfers and compliance against targets is not measured.
- Action plans to address wider issues identified through complaints are not formulated leading to underlying issues, |
- Scheme administration is overseen by the Local Pensions Board
- There is a governance group, made up of members of the Council and CSG, who oversee administration of the scheme (see finding 4)
- There is a clear scheme of responsibilities in the pensions administration team
- There are SLAs in place for queries which are reported to the Local Pensions Board
- Reporting includes compliance against SLAs and the number cases outstanding, and their ageing
- Management information relating to task management is prepared in Hartlink and targets are embedded into task management processes (see finding 4)
- A service improvement plan is in place to address issues identified
- Actions are logged as part of governance group meetings (see finding 4)
- A risk register exists and is reported to the governance group and the Local Pensions Board (see finding 4) | | Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | Administration – scheme record keeping | Contributions made to the fund by employers and employees are accurate, timely and complete for all new joiners. | • Inefficient processes may lead to applications not being processed on a timely basis resulting in a delay in members joining the scheme.\
• Inaccuracies in information supplied (such as salary details) may lead to an incorrect contribution rate upon enrolment leading to over or underpayments of contributions.\
• Duplicate members are not identified leading to members’ pension entitlement not being calculated accurately. | • Members information is supplied by employers and records created within 20 working days of starting or 10 days after the end of the month the employee joins the employer (see findings 6 and 9).\
• Hartlink identifies potential duplicate records (see finding 7). | | Administration – scheme record keeping | Data recorded on the pensions system in respect of active members (Hartlink) is accurate and complete. | Data held on the system may not be accurate or up to date resulting in inaccurate data submissions to the regulator and inaccurate calculation of the scheme’s funding status if:\
• Information is not received from scheme employers in | • Employers are notified in advance of the requirement to supply information and deadlines specified for the provision of data (see finding 2)\
• Employers are chased to provide information if provided late (see finding 2)\
• Submissions are reviewed by CSG prior to data upload and queries on data returned to employers (see findings 1 and 3) | | Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | records | line with required timeframes; • Inaccurate or incomplete submissions are not identified and resolved; • Information is not uploaded accurately in to the underlying system; and • Membership records are lost and not promptly replaced. | • Data is uploaded direct from spreadsheets to Hartlink | | Administration – scheme record keeping | Data recorded on the pensions system in respect of pensioner members (Hartlink) is accurate and complete. | • A lack of a systematic approach to updating the pension records may mean that pension payments may continue to be made in respect of deceased individuals. | • Deaths identified/reported are recorded on Hartlink and pension payments blocked for these members • Results from the National Fraud Initiative and “Tell us once” are used to identify possible deaths | | Administration – scheme record keeping | Accurate and timely pension payments are made to retired scheme members. | • Use of incorrect final salary information and/or CARE pension account value may mean calculation of pension benefits to retirees is inaccurate leading to over- or underpayment. • Delays in processing the retirement information may mean that payments to retirees may be inaccurate or delayed. • Inaccurate benefit | • Forms are received from employers containing final pay figures to enable pensions to be calculated • Calculations are reviewed to ensure that scheme rules are applied correctly • Final calculations are issued within 10 working days of receipt of relevant paperwork (see finding 3) • Exception reporting on pension increases proposed are reviewed before increases are approved | | Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | | | payments are made as a result of draft information being used in benefit calculations\
• Inaccurate calculations of annual increases of pensions in payment are not detected leading to over- or underpayment. | Data is requested to support transfers in using a standard template to enable the scheme to receive sufficient information to provide an indication of the size of benefits to members transferring into the scheme\
• Transfer value received and information is used to calculate the value of benefits transferred in\
• Transfer out calculations are reviewed before these are issued to ensure they are accurate (see finding 7) | | Administration – scheme record keeping | Transfers in and out of the pension scheme are processed accurately and in a timely manner. | Transfers may not be processed accurately and on a timely basis, leading to complaints from scheme members and/or inaccuracies in the financial records maintained by the fund if:\
• Insufficient information is not received/provided in a timely manner to support the transfer leading to inaccuracies in member records; and\
• Inaccurate calculations to support transfers out are not identified and resolved. | | | Transfers in/out | | | | | Administration – providing information to members | Accurate annual benefit statements are provided annually in line with scheme requirements. | Scheme members may not receive accurate information regarding their pension in a timely manner resulting in service user dissatisfaction if:\
• Officers are not aware of scheme requirements in relation to annual benefit statements;\
• Responsibility for producing annual benefit statements is | There is an annual scheme plan which sets out tasks to be completed in the period – this includes the requirement to produce annual benefit statements\
• Annual benefit statement preparation is assigned to an officer at CSG\
• A plan to collect appropriate data and load data was in place (see finding 2)\
• Data is taken from annual returns and added to CARE accounts\
• A sample of benefit statement calculations are reviewed to ensure accuracy before being issued (see finding 2) | | Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | | | not assigned; | • Various entitlements of members are set out on benefit statements (see finding 3) | | | | • Operational plans are not in place to ensure data required is provided in line with required timeframes; | • Staff are allocated to the pensions administration team during busy periods | | | | • Incorrect or incomplete figures are added to or held for members career average revalued earnings pension accounts leading to inaccurate benefit calculations; | | | | | • Benefit statement calculations are inaccurate; | | | | | • Benefit statements are insufficiently detailed to allow members to identify and report errors; and | | | | | • Operational plans do not take account of seasonal workload fluctuations to ensure the service is sufficiently resourced at peak times. | | | Administration – providing information to members | Information about the scheme, such as changes to terms and conditions, are communicated to members. | Scheme members may not receive accurate information regarding their pension in a timely manner resulting in service user dissatisfaction if: | • The service improvement plan requires that CSG produces a communication strategy (see finding 5) | | | | • Officers are not aware of scheme requirements in | | | Area | Objective | Risks | Identified Controls | |------|-----------|-------|---------------------| | Administration – providing information to and receiving information from employers and other admitted bodies | Information about the scheme, such as timeliness of data returns for new joiners, retirees or other changes are communicated and a comprehensive communication plan is in place for all stakeholders | Scheme employers and other admitted bodies may not be aware of data requirements and timescales resulting in employer dissatisfaction with the scheme administration, over/underpayments, inaccurate benefits statements and reputational damage to the Council if:
- Employers and other admitted bodies are not aware of scheme requirements in relation to member data;
- Employers and other admitted bodies are not aware of key cut off dates for data returns (e.g. new joiners, actuarial review); and
- Employers and other admitted bodies are not aware of changes |
- Templates are used to ensure data is provided in line with scheme requirements
- Cut-off dates are communicated to employers in advance
- Emails are sent to employers and payroll providers in the event of scheme changes (see finding 5) | | Area | Objective | Risks | Identified Controls | |-------------------------------------------|---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Resolving issues – resolving disputes | Scheme members are kept informed when they have raised a query. | Scheme members may not receive accurate information regarding their pension in a timely manner resulting in service user dissatisfaction if: | • Tasks relating to scheme members are actioned by CSG within 10 working days\
• Casework levels are reported to team leaders using a live dashboard and reported in performance reporting to the Council and the Local Pensions Board\
• Queries and complaints are responded to in line with contractual SLAs\
• Meetings are held between trade union representatives and CSG to resolve any issues raised by members | | | | • Communications to members are inaccurate or not made in a timely manner;\
• Casework processing levels are not monitored;\
• Queries and complaints are not processed in a timely manner; and\
• Queries and complaints are not resolved accurately and in a timely manner. | | | Resolving issues – breaches of law | Breaches of law are reported to regulators promptly and accurately. | Breaches of law may not be reported in line with requirements resulting in regulatory action including fines and reputational damage if: | • There is a breach of law policy for the scheme (see finding 8) | | | | • Officers are not aware of reporting requirements; and\
• Reportable breaches or errors are not reported promptly to the appropriate regulator. | | | Area | Objective | Risks | Identified Controls | |-------------------------------------------|---------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Governing the scheme – submitting returns | Accurate data is supplied in accordance with relevant deadlines to ensure compliance with scheme conditions. | Data may not be provided in line with requirements resulting in regulatory action including fines and reputational damage if:
- Officers are not aware of scheme requirements in relation to data submissions;
- Responsibility for producing the returns is not assigned; and
- Operational plans are not in place to ensure data is provided in line with required timeframes. |
- There is an annual scheme plan which sets out tasks to be completed in the period – this includes the requirement to complete the annual return
- Preparation of the annual return is assigned to an officer at CSG and is referenced in the allocation of staff. | Appendix 4 – Internal Audit roles and responsibilities
Limitations inherent to the internal auditor’s work
We have undertaken the review of Pensions Administration, subject to the limitations outlined below.
Internal control
Internal control systems, no matter how well designed and operated, are affected by inherent limitations. These include the possibility of poor judgment in decision-making, human error, control processes being deliberately circumvented by employees and others, management overriding controls and the occurrence of unforeseeable circumstances.
Specifically we will not:
- Provide assurance over controls in place around the investment of funds in relation to LGPS regulations.
- Provide assurance over controls in place around the receipt of contributions, including controls monitoring the receipt of contributions on a timely basis.
- Provide assurance over controls in place around the payment of pensioner payroll.
Future periods
Our assessment of controls is for the period specified only. Historic evaluation of effectiveness is not relevant to future periods due to the risk that:
- the design of controls may become inadequate because of changes in operating environment, law, regulation or other; or
- the degree of compliance with policies and procedures may deteriorate.
Responsibilities of management and internal auditors
It is management’s responsibility to develop and maintain sound systems of risk management, internal control and governance and for the prevention and detection of irregularities and fraud. Internal audit work should not be seen as a substitute for management’s responsibilities for the design and operation of these systems.
We endeavour to plan our work so that we have a reasonable expectation of detecting significant control weaknesses and, if detected, we shall carry out additional work directed towards identification of consequent fraud or other irregularities. However, internal audit procedures alone, even when carried out with due professional care, do not guarantee that fraud will be detected.
Accordingly, our examinations as internal auditors should not be relied upon solely to disclose fraud, defalcations or other irregularities which may exist.
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ca99d98b3e988ef80497ea9ce5f92928ed8866fb | CODE OF CONDUCT FOR EMPLOYEES – DECLARATION OF INTERESTS
This form should be completed and signed by all new employees and those accepting new contracts of employment. This form must be returned after the selection process but before you start work.
Please read the Staff Guidance Notes before completing this form.
Please print clearly in black ink
Name: ...........................................................................................................
Work Address: ..............................................................................................
Directorate: ...................................................................................................
Ext No: ..........................................................................................................
PART A
1. Employment
1.1 I am applying for: Job Title ..................................................................
Post Ref .................................................................................................
Additional Work (see paragraph 7 of the Code of Conduct)
2.2 I also work as:
Name and nature of business
3.3 Self-employed
I am self-employed as:
I trade under the following name(s) 2. Directorships (see paragraph 7 of the Code of Conduct)
2.1 I hold the following Directorships in the following companies:
FINANCIAL INTERESTS
3. Shareholdings (please see staff Guidance Notes paragraph 2.3)
3.1 I or my nominees own shares in the following companies:
4. Grant Aid (Please see Staff Guidance Notes paragraph 2.4)
4.1 I have recently applied or intend to apply for a grant on my own behalf from Barnet Council
YES / NO
If ‘YES’ specify nature and amount.
4.2 A group or organisation in which I am involved in the running (and in the decision making process) has applied for and/or intends to apply for a grant from Barnet Council
YES / NO
If ‘YES’ specify nature, amount and your position in group/organisation. PART B – Personal Interests of Employee
1. Clubs, Associations and Societies (Please see Staff Guidance Notes Paragraph 2.5)
1.1 I have a personal interest in or membership of the following clubs, associations and societies which has the potential to conflict with the interests of the Council.
(If you believe conflict of interest may exist state name and nature of any local clubs, associations and societies in which you have a personal interest/membership, including any chamber of commerce, trade association, rotary club, friendly society, townswomen’s guild, Royal British Legion, Inner Wheel, Round Table, Lions, TOCH, Special interest society, Amenity Society, Cultural Association, any other Charitable body and any other social clubs or societies).
2. Professional Bodies (See Staff Guidance Notes paragraph 2.6)
2.1 I am involved in the decision making process of the following bodies: (Please state name, nature of any professional body/bodies in which you are a member).
3. Select Societies (Please see paragraph 8 of the Code of Conduct)
3.1 I have a personal interest in/or membership of a select society: (Please state name and nature of any select societies in which you have a personal interest/membership, such as Freemasons, Knights of St Columbus.) I am involved in the running of a select society and in the decision making process. YES / NO
If ‘YES’ specify nature of role.
4. Housing Association (Please see Staff Guidance Notes paragraph 2.7)
4.1 I am a member of a Housing Association. YES / NO
If ‘YES’ specify name(s) and registered office(s):-
4.2 I am a member of a Tenants/Residents’ Association in the Borough of Barnet. YES / NO
If ‘YES’ specify name(s) of associate(s):-
5. Other Interests (Please see Code of Conduct paragraph 7)
5.1 I or my partner are associated with a limited company YES / NO
Specify nature of association 5.2 I am involved in the decision making process of a charitable trust
YES / NO
If ‘YES’ specify which trust and nature of relationship with the trust
I have another interest which may impact on my work
YES / NO
Please specify
5.3 I have been appointed by a Government Minister as a member of a statutory undertaking or other body which is constituted in order to discharge or assist in discharging a statutory function.
YES / NO
If ‘YES’ specify body(ies):
5.4 I am a Councillor in a Local Authority
YES / NO
If ‘YES’ specify which authority: 5.5 I am a co-opted member of a Local Authority Committee(s) or Sub-Committee(s)\
YES / NO
If ‘YES’ specify which authority(ies) and which committee(s):-
5.6 I am a member of a school governing body in the Borough of Barnet\
YES / NO
If ‘YES’ specify school(s):-
5.7 I am on the controlling body of a parent/teachers association in the Borough of Barnet\
YES / NO
If ‘YES’ specify which association(s):-
5.8 I am a Board member of a Hospital trust/Health Authority\
YES / NO
If ‘YES’ specify Hospital/Health Authority:- 5.9 I serve as a Magistrate (in Barnet or neighbouring area) YES / NO If ‘YES’ specify which Court:-
6. Recruitment of Relatives (Please see Staff Guidance Notes paragraph 2.9)
Are you related to/or have an association with a Member of the Council or anyone working for the Council YES / NO If ‘YES’ specify name(s) and work area(s)
Please see Guidance Note for Staff re: inspection of information (Paragraph 7).
I declare that to the best of my knowledge and belief the answers given above are truthful, accurate and complete. I undertake to inform my Director of any change to these answers within 28 days of that change taking place.
Signed .............................................................. Date ..................................
When completed, please return this form to HR who will forward it to your Chief Officer
FOR OFFICE USE
Noted by Director/Divisional Head ..............................................
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ac0c3b28d141193de06e126ce5c1c291b36d9437 | VEHICLE AND TRAVELLING ALLOWANCES
1. CAR ALLOWANCES
1.1 Introduction
Vehicle allowances are allocated to a particular post, not to the postholder and apply to permanent, temporary, part time and job share employees. Allowances are paid at two rates based on the engine cubic capacity of the car used by the postholder as follows:-
- 441 - 999cc
- 1000cc and over (NJC category 1000 - 1199cc)
The top rate paid for cars in the 1200-1450 engine size band was withdrawn in 1997 with existing users paid on this band until they had changed their car or moved into another post.
Chief Officers may, however, authorise, under delegated powers, the use of a car in the 1200-1450 engine size band at the top rate in the following circumstances only
- for disabled employees or employees with medical conditions that necessitate the use of a larger vehicle
- on safety grounds for employees who are required to carry equipment/tools etc as part of their duties that can only safely be carried in a larger vehicle
1.2 Categories
There are three categories of designated car users,
- Essential Users
- Casual Users
- Occasional Users
1.3 Essential Users
Essential users are employees whose duties are of such a nature that it is essential for them to have a car at their disposal whenever required. The criteria for allocation of an Essential User Car Allowance are:-
- business mileage in excess of 3500 miles per annum; or
- regular (at least weekly) transport of passengers or bulky materials/equipment; or
- regular (at least weekly) journeys for which public transport would be impractical.
For a post with an Essential User Car Allowance the provision of a car by the employee and the ability to drive each working day on the Council’s business are contractual obligations on the employee. 1.4 Casual Users A designated Casual User Allowance is attached to those posts where it is desirable that a car should be available when required. This is designed for employees who require a car an infrequent basis.
1.5 Occasional Users All existing employees are set up on SAP as Occasional car users and may claim for mileage undertaken on an occasional casual user basis which is paid at a lower rate called the Barnet Vehicle Allowance Rate (BVAR). The BVAR is reviewed annually by HR in line with changes to the Car Allowance rates set nationally.
1.6 Payments when the car is not in use For essential users only, in line with national terms and conditions, where a car is not in use as a result of either a mechanical defect or the absence of the employee through illness;
The essential user lump sum payments should be paid for the remainder of the month in which the car first became out of use, and for a further three months thereafter. For the following three months, payment will be made at the rate of 50% of the lump sum payment.
During the period when a car is off the road for repairs, reimbursement in respect of travel by other forms of transport will be made.
1.7 Payment Procedure All payments are made through salary and all essential users receive the lump sum element in monthly instalments.
Claims for actual mileage incurred should be submitted monthly as follows:
- **Electronically through SAP**- on the expenses claim e-form, completed up to the 15th of the month, or if there is no access to SAP
- **Manually** - on the Monthly Mileage Claim Form, completed up to the 15th of the month
It is recognised that in practice claims will not always be submitted on a monthly basis, however, claims which exceed a period of 4 months will be refused unless there are exceptional circumstances such as a long sickness absence, a long period of special leave etc and only approved following agreement by a Chief Officer.
1.8 Review The type of allowance allocated to a post and will be reviewed:
- following a change in work location
- following a restructure
- following a change in work patterns • whenever a post is vacated.
In addition, Resources will review all positions that have an essential user allowance on an annual basis and withdraw the allowance for those staff who do not meet the criteria.
1.9 Claims All officers undertaking journeys on Council business are required to use the shortest practicable route and to submit their claims on this basis. Attached at Appendix A are the single and return distance charts for travel between the main Council sites which should to be used for claims.
Where more than one vehicle is in use by an employee any lump sum element or lump sum allowance payable will be based on the cc group of the smallest engine. Mileage claims however will be paid on the cc group of the vehicle actually used. Separate claim forms should be submitted for each vehicle where more than one has been used within a claim period.
1.10 Travel Direct between Home and Alternative Work Place, First or Last Visit Employees who submit claims for vehicle allowances, who are making their first call of the day (outside their normal workplace) direct from home or returning direct to home from their last call of the day, are entitled to claim any excess mileage above their usual home to workplace or workplace to home journey.
2. CYCLE AND MOTOR CYCLE ALLOWANCES
2.1 Employees occupying posts within essential or designated casual user car allowances may:-
I. switch to the use of a bicycle for specific journeys by agreement with their line manager without loss of car allowance, or II. substitute, by agreement from the relevant Chief Officer the permanent use of a bicycle with an annual flat rate allowance of £400 per annum or, for designated casual users, the aggregate of the last 12 months claims\*, whichever is the lower; III. substitute by agreement from the relevant Chief Officer the permanent use of a motorcycle at the locally determined allowance rates.
\*A new employee with no claim record may be required to submit regular claims and will be paid at casual user rate (441 - 999cc) to a maximum of £400 per annum to establish the correct level of payment.
2.2 Employees in post without any form of car allowance may make authorised occasional use of a bicycle and claim an allowance at the bicycle allowance daily rate which will be reviewed annually. 2.3 Cycle and motorcycle allowances will be reviewed annually by the Director of Resources in line with the national Car Allowance rates.
3. MISCELLANEOUS CLAIMS
3.1 Journeys to Central London Where it is necessary for a vehicle user to travel to Central London, public transport should normally be used and the expenses of the journey will be made through salary after submission of a claim using SAP e-forms. Where the use of a vehicle is essential, any congestion charge payments will be refunded on production of proof of payment.
3.2 Training/Seminars & Conferences Additional car mileage incurred by employees travelling to training courses located within the Borough boundary will be reimbursed at the appropriate car allowance rate.
3.3 Staff attending Training Courses located outside the Borough boundary will be reimbursed their additional travelling expenses at the most economic public transport rate. When difficulties would be experienced by travelling on public transport, the line manager may give prior authorisation for reimbursement at the BVAR. When BVAR is to be claimed for attendance at a Conference, the Conference Expenses form is to be used.
3.5 Weekend and Bank Holiday working Where staff are required to attend work at the weekend or on Bank Holiday where attendance does not form part of their contractual hours, the use of a car for travel from home will be reimbursed at the BVAR. Such weekend/Bank Holiday work must be authorised by management. Reimbursement of home to workplace travel do not extend to staff undertaking voluntary overtime at weekends/Bank Holidays.
3.6 Call-Outs Any member of staff who is called out on an emergency, when not normally contracted to do so, will be reimbursed approved mileage from home to work and return at the BVAR.
3.7 Attendance at Evening Meetings Employees who are recalled to attend an evening meeting, where they are not contracted to do so, will be reimbursed approved mileage from home to meeting place and return at the BVAR.
3.8 Mobile Staff Staff normally on mobile duty should calculate first/last visit mileage from their home (if residing in the Borough) or the Borough boundary nearest their home (if residing outside the Borough). 4. **ADMINISTRATION**
4.1 Before any payment can be paid, each designated or authorised car user must complete a Vehicle Allowance - Permanent Information Form and produce a copy of a current Insurance Certificate that includes use for business use by the designated car user. A new Permanent Information Form should also be completed in the following circumstances:-
- change of post
- change of work location
- change of home address
- change of vehicle
- change of allowance category (the relevant authorisation should be completed)
- use of an additional vehicle
4.2 When Insurance details are changed a copy of the new certificate should be shown to the manager.
5. **POLICY REVIEW:**
This policy will be reviewed annually. Appendix A
Vehicle & Travelling Allowances
Single Journey
\*Hendon Town Hall includes Fenella
| Barnet House | 5 | |--------------|---| | Colinhurst | 2 | | | 4 | | Copthall | 2 | | | 2 | | Avenue House | 3 | | | 2 | | Mill Hill | 4 | | | 2 | | NLBP | 6 | | | 6 | | Hendon Town Hall | 2 |
Return Journey
\*Hendon Town Hall includes Fenella
| Barnet House | 10 | |--------------|----| | Colinhurst | 3 | | | 9 | | Copthall | 4 | | | 3 | | Avenue House | 3 | | | 2 | | Mill Hill | 3 | | | 4 | | NLBP | 8 | | | 6 | | Hendon Town Hall | 11 |
E18 – Vehicle and Travelling Allowances – Updated January 2008 What are the Benefits in Working for Barnet – E 18
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f831b61771c35165e2cb1110ee194b18936e828f | 1. INTRODUCTION
This procedure applies to all school based staff employed by community schools and schools that have chosen to adopt Barnet Council's policies and procedures.
A separate policy exists for council staff who provide contracted services to schools e.g. catering and cleaning staff. The council procedure will also be used where school based staff wish to raise a grievance against council staff and vice versa.
Agency, casual, supply, consultancy staff and serving governors are also required to comply with the principles outlined in this policy.
This procedure aims to ensure that grievances are resolved sensitively, consistently and within reasonable timescales.
Employees have an absolute right to raise a grievance relating to their employment with the school with the following exceptions:
- matters relating to the grade and/or designation of their posts
- matters relating to tax and/or national insurance
- the operation of the pension scheme
- disciplinary matters
- early retirement, ill health retirement and selection for redundancy
and any other matters for which separate appeal arrangements operate.
Employees may, however, use the grievance procedure when the Headteacher or Governing Body have failed to make a decision which would have given rise to a right of appeal under matters listed above.
When a grievance relates to an important policy issue, either of the Joint Secretaries of the Corporate/Teachers Joint Negotiation and Consultation Committee may place that matter on the agenda for consideration. Employees wishing to raise such matters should do so via the Employee’s Side Secretary. In the event of a failure to agree, advice will be sought from the Joint Secretaries of the Greater London Provincial Council for support staff. For teaching staff it may be possible to refer to the National Conditions of Service for School Teachers in England and Wales Collective Disputes Procedure.
If, as a result of the investigation of a grievance, it is found that a disciplinary offence may have been committed by another person, action will be taken in accordance with the schools adopted disciplinary procedures as appropriate. Equally, if an investigation concludes that a grievance has been maliciously raised disciplinary action may also be invoked.
Occasionally grievances may be lodged by an employee who is subject to a capability or disciplinary process for an unrelated matter. Both processes will normally run at the same time, however, consideration may be given to suspending the capability or disciplinary procedure if considered appropriate.
Management must ensure that those dealing with the disciplinary or capability case are not involved in the investigation of the grievance and vice versa. Relevant matters arising from a grievance may be submitted as evidence in any disciplinary process by the employee. This would be without prejudice to an employee's right to have the grievance dealt with under this procedure. 2. GRIEVANCE FLOW CHART
Stage 1
Grievance raised informally with * line manager/ headteacher/ nominated Governor
Conciliation/ Mediation
Successful, case closed
Not appropriate/ Not successful
Monitor/Review
Stage 2
Formal Grievance made in writing, to Chair of Governors\*
Chair of Governors to acknowledge receipt of grievance and advise name of nominated investigating officer
Investigation carried out by investigating officer. Investigation should commence as soon as possible
Decision made by Investigating officer and circulated to all parties
Decision accepted
Case closed, manager/headteacher/ nominated governor to provide mediation/support and to monitor/review where necessary
Stage 3
\*Appeal heard by a panel of governors
Decision at Stage 3 is final
expected time scale: 4 working weeks
expected time scale: 8 working weeks
expected time scale: 12 working weeks
- If the grievance is against an employee or a line manager, the case will normally be referred to the headteacher (who may delegate it to a senior manager).
If the grievance/appeal is against the headteacher, then the case is referred to the governors who will nominate a governor or governing panel.
If a grievance is against a governor, the general principles in this procedure will be followed. 3. TYPES OF GRIEVANCE
Grievances are concerns, problems or complaints that employees raise with their line manager/headteacher/nominated governor. The following list identifies the main types of grievances that can be brought under this procedure:
- the application of terms and conditions of employment
- health and safety concerns
- work relations
- new working practices which it is felt may have a detrimental effect
- indirect or direct discrimination
- equal opportunities
- working environment
- a collective grievance (a grievance or grievances submitted by a team or group of employees where a common complaint or theme can be identified and dealing with these collectively will enable a more appropriate and effective resolution)
Please note that school may have adopted separate procedures for dignity at work issues (e.g. harassment, bullying and victimisation).
This list provides the main types of employment related grievances that staff may have. To provide an exhaustive list is not possible and staff should use their judgement when applying school standards and policies but, should also be guided by the principle that the determining issue is how the member of staff is affected, not the intent.
4. CONFIDENTIALITY
All grievances must be dealt with in the strictest confidence. Managers, headteachers, governors, staff and union members involved in cases must not breach confidentiality beyond those involved in the management of the grievance, without the specific agreement of the parties.
5. RECORD KEEPING
In the interests of both employer and employee, written records must be kept throughout the grievance process. Records should include:
- the nature of the grievance raised
- a copy of the written grievance
- the management response
- action taken
- reasons for action taken
- where there was an appeal and if so, the outcome and subsequent developments
- minutes of meetings (school to provide a minute clerk for meetings). Records should be treated as confidential and kept in accordance with the Data Protection Act 1998, which gives the individuals the right to request and have access to certain personal data. Copies of meeting records should be given to the employee including any formal minutes that may have been taken. In certain circumstances, for example to protect a witness, some information may be withheld.
6. THE PROCEDURE
6.1 STAGE ONE – INFORMAL RESOLUTION
- Informal procedures concentrate on conciliation, not sanctions. The Council offers a mediation service to help with conciliation and this should be considered before making a formal grievance.
- Most grievances should be resolved informally with either, manager/headteacher/nominated governor.
- Four working weeks would normally be considered a reasonable time scale to deal with a grievance at Stage 1. If the complainant is not satisfied with the handling of the grievance, timeliness or response they may submit a formal grievance.
Grievances may be raised verbally or in writing. However, a grievance received in writing will only be considered as ‘formal’ if Stage One, Informal Resolution, has been followed and the complainant is dissatisfied with the handling of the grievance at that stage.
The manager dealing with the grievance should confirm the action points agreed and any follow up action in writing, in accordance with section 5.
6.1.1 MEDIATION
Mediation should be considered if both parties are willing and the matter is appropriate for mediation.
The aim of mediation will be for both parties to reach a mutually acceptable outcome and to feel able to maintain their working relationship. Here are some examples of the types of disputes that could be solved through mediation are:
- behaviour, management/work styles
- working arrangements
- environmental conditions
The manager/headteacher/nominated governor may need to carry out an assessment to determine whether mediation is appropriate. The manager/headteacher/nominated governor can contact the Council's Employee Assistance Officer for advice on this process.
The Council’s Employee Assistance Officer is a trained mediator and can offer support as part of the Human Resources Service Level agreement (if where the school buys into the full HR Traded Service). If more than one mediator is required the Employee Assistance Officer can arrange this through People at Work. A further charge will be made for this service.
If mediation is suitable, then both parties should confirm that they understand what this involves and are happy to proceed. If there is agreement on this, the manager should contact the Employee Assistance Officer to arrange a mediator.
If mediation is not possible, the grievance can still be dealt with under the formal procedure.
6.2 STAGE TWO – FORMAL GRIEVANCE
6.2.1 GRIEVANCE IN WRITING
A grievance should only be raised at the formal stage if the complainant is dissatisfied with the handling of the grievance through stage 1 of this procedure.
This grievance process commences formally when the matter is raised in writing, normally on a Staff Grievance Form (Appendix A). Grievances should, normally be raised within 12 working weeks of the event or issue occurring. The complainant should send their Grievance to the Chair of Governors.
The Chair of Governors will delegate the investigation of the grievance to a governor, the headteacher or to a senior manager not involved in the grievance or not closely associated with the complainant or any person complained about. The Chair of Governors should write to acknowledge receipt of the grievance and advise the name of the investigation officer.
If the complainant is dissatisfied with the response, or if no response has been received within 10 working days of receipt of the grievance form or letter, the complainant can proceed to stage 3 of the procedure.
6.2.2 INVESTIGATION
- Any investigation must begin as soon as possible. For complex cases a time period of 8 working weeks is reasonable to conclude a grievance.
- The investigation process must gather all the facts which are relevant to the matters under consideration.
- Those conducting the investigation will be guided by the principles for investigations contained in the ACAS code of practice on disciplinary and grievance procedures. In summary all parties must:
- know the details of the grievance raised against them
- have the opportunity to state their side of the case before any decision is made
- have the opportunity to be represented and
- must be dealt with fairly, reasonably and impartially at all times • The complainant should be kept advised of progress and given an explanation for any delay. They should also be told when a response can be expected.
6.2.3 REPRESENTATION
• If either the complainant or person subject to the complaint is invited to a hearing/meeting to discuss the grievance, they should be advised of their right in writing to be accompanied by a Trade Union representative or a colleague. Both parties can be represented throughout the process.
• The representative must be permitted to address the hearing and to confer with the person they are representing during the hearing in order to clarify issues. The representative is not, however, entitled to answer questions on behalf of that person.
• The complainant must attend the meeting/hearing. If the complainant's representative can not attend on the proposed date an alternative date can be proposed so long as it is within a reasonable timescale.
• It is not appropriate for someone to insist on a representative whose presence would prejudice the hearing or who might have a conflict of interest.
• Disabled employees may request additional assistance/representation.
6.2.4 MAKING A DECISION
• The investigation and decision making must be thorough and objective. The decision and what action is to be taken must be based on evidence collected as part of the investigation. Decisions will be reached on the balance of probabilities rather than the burden of proof.
• If the investigating officer reaches the conclusion that disciplinary action is warranted then formal disciplinary proceedings should be invoked.
6.2.5 TIMESCALES
An essential feature of this procedure is making sure that we deal with grievances quickly:
• Action may be required immediately to ensure the safety of the complainant. Such action could include reorganising or relocating work to avoid close or regular contact. In serious cases, following initial assessment, the subject of the complaint may have to be suspended as a precautionary measure in line with the disciplinary rules and procedures.
• Following receipt of the written grievance, the investigating officer should contact the complainant in writing (normally within 5 working days) to set up a meeting to discuss the grievance and the arrangements for investigation. Where it is not possible to respond within specified time periods the complainant should be given an explanation for the delay and told when a response should be expected. 6.2.6 POST INVESTIGATION
- At the end of the investigation, the investigating officer will inform all parties that the investigation has been concluded. Within 10 working days of this a written outcome will be circulated to all parties. This document will outline the process followed, the decisions reached, the reasons for the conclusion and the procedure for appeal.
- This investigative response will be the basis of the case file. It may also be included as evidence for any formal disciplinary hearing or used at any appeal hearing under this Grievance Procedure.
- The school must retain, in confidence details of grievances and the outcomes for monitoring purposes.
- If an allegation cannot be substantiated following a formal investigation and there is a reasonable belief that the complainant acted maliciously, disciplinary action may be taken against him or her. The complainant should be advised before the investigation begins that making a malicious allegation constitutes a disciplinary offence. This should be handled in a sensitive manner that does not discourage a grievance being raised.
- If there is no case to answer all written records will be destroyed.
6.3 STAGE THREE - APPEAL
- The complainant may appeal against the decision following the investigation. This appeal must be made to the clerk to the governors in writing within 5 working days of receiving the written decision. The clerk to the governors will arrange for a panel to hear the appeal. The panel should consist of three governors and should exclude any governors who have had any direct involvement in the grievance, or where there may be a conflict of interest.
- The panel will consider all relevant documents and witness statements and will give all parties concerned (accompanied by a Trade Union representative or colleague) the opportunity to make submissions to the panel in person.
- The panel dealing with the appeal hearing should give a decision within 5 working days.
- The person who is the subject of the grievance can also appeal against the decision, using the above appeal process unless the decision was to implement the disciplinary procedures against them, where a separate right of appeal exists.
7. MODIFIED STATUTORY GRIEVANCE PROCEDURE
Wherever possible a grievance should be dealt with before an employee leaves the school. If an employee has already left before the grievance procedure was invoked or completed a modified grievance procedure can be used if the former employee and the line manager/headteacher/nominated governor agree to this in writing. Under the modified procedure the former employee should write to the school setting out the grievance, as soon as possible after leaving employment and the employer must write back setting out their response.
The full statutory procedure is set out in Schedule 2 to the Employment Act 2002.
**FURTHER INFORMATION CAN BE OBTAINED FROM:**
Schools can purchase the Council's Human Resources Service where an Employee Relations Advisor can advise on all aspects of this policy. They can also accompany investigating officers who have been asked to deal with grievances throughout, stages 1, 2 and 3.
ACAS: [www.acas.org.uk](http://www.acas.org.uk) DTI: [www.dti.gov.uk](http://www.dti.gov.uk) CIPD: [www.cipd.co.uk](http://www.cipd.co.uk) FORMAL STAFF GRIEVANCE FORM
Your Name: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
School: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Job Title: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Your work address: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Your work telephone number: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
What is your Grievance? (Please continue on separate sheet if required and attach supporting documents if available)
______________________________________________________________________
______________________________________________________________________
______________________________________________________________________
A written grievance should normally only be raised after you have tried to resolve your grievance informally with your line manager/Headteacher or a nominated governor. This would usually involve conciliation/mediation. Has this been done? Yes/No
If yes, on what date was the last meeting? \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Why are you dissatisfied with the outcome of this process? \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
______________________________________________________________________
______________________________________________________________________
If no, why do you think an attempt to resolve your grievance through conciliation/mediation would be inappropriate? \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
______________________________________________________________________
What do you think could be done to resolve this grievance? \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
______________________________________________________________________
______________________________________________________________________
______________________________________________________________________
Your Signature: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_ Date: \_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_\_
Please send this form to the Chair of Governors of your school.
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f8cdb4aa33dea9a0393a8a96ac9398a095a204b7 | The following guidelines relate to the management of pregnancy and maternity leave within Barnet Council and should be read in conjunction with the Maternity Policy.
Contents:
01. Maternity Leave
02. Time Off for Antenatal Care
03. Returning from Maternity Leave
04. Statutory Maternity Pay
05. Council Maternity Pay
06. Allowances
07. Health and Safety
08. Keeping in Touch Days
09. Grievances Relating to Maternity
10. Holidays
11. Management Briefing
12. Additional Paternity Leave
13. Employee Briefing
Keeping in Touch Checklist
July 2011 1 Maternity Leave
1.1 When a pregnancy is confirmed the employee should notify her line manager and HR, in writing, of the following:
- that she is pregnant
- of the expected week of childbirth (EWC)
- of the expected date of the commencement of maternity leave, which must not be a date earlier than the 11th week before the EWC.
1.2 EWC means the week, beginning with midnight between Saturday and Sunday, in which it is expected that the child will be born.
1.3 As soon as practicable after the notification of pregnancy, arrangements will be made for the employee to meet with her line manager. This will be an informal interview, the purpose of which is to ensure that:
- the right to ordinary maternity leave and additional leave, including the requirements to give appropriate notice is understood
- the right to return is explained, together with any potential opportunities for flexible working
- arrangements for time off are known, and any possible health and safety concerns are aired
- entitlements to payment during maternity leave are understood.
1.4 It is recognised that adequate arrangements for cover during the period of maternity leave and also for enabling the employee to keep in touch with any developments at work are important for ensuring smooth transitions at each stage. Accordingly, prior to the commencement of maternity leave the employee will be informed of the arrangements for covering her work and also for providing her with opportunities to remain in contact whilst on leave. As far as possible, such arrangements will be finalised in consultation with the employee. In addition, the employee will usually remain on circulation lists for internal memos and other documents, and will be included in invitations to work-related social events, as though still at work. 1.5 The Council will ensure that the employee will not suffer detriment of any kind as a result of her pregnancy, including being excluded from such opportunities as training and development. It is equally unlawful under the Sex Discrimination Act to pass over a woman for promotion because she is pregnant.
1.6 The employee has the right to return to her own job after ordinary maternity leave or to a suitable alternative one if this is not practicable after additional maternity leave. The Council will seek to avoid potential redundancies during periods of maternity leave. In accordance with statutory requirements, where job losses are unavoidable, the employees on maternity leave will be given first consideration for any suitable alternative employment that may arise, in accordance with the Council’s Managing Organisational Change Policy.
1.7 At least two weeks before the return to work, the employee will be invited for an informal meeting with her line manager in order to provide an opportunity for discussion of any material points concerning the return to work. These include:
- updating on developments at work
- considering whether any retraining needs have arisen, because of new technical or other developments
- providing the opportunity for a flexible working discussion in relation to the Council’s Flexible Working Policy
1.8 The interview will also provide an opportunity to discuss and explain any necessary and unavoidable changes to her work that may have taken place.
2 Time off for antenatal care
All pregnant employees are entitled to take paid time off during normal working hours to receive antenatal care. Antenatal care includes appointments with the Midwife, GP, hospital clinics, relaxation classes and parentcraft classes. Evidence of appointments must be produced if requested by her line manager. Line managers must be advised of the appointment as far in advance of the appointment as possible. 3 Returning from maternity leave
3.1 The employee has the right to return following ordinary leave or within 26 weeks to the same job on the same terms and conditions as if she had not been absent. If there is a redundancy situation, she is entitled to be offered a suitable alternative job, if one exists. If for health and safety reasons she was doing a different job from her usual one while she was pregnant, she may be required to return to that different job for a short time if she is still considered at risk.
3.2 Provided the employee has completed one year’s service she may extend her entitlement to maternity leave, ordinary or additional, by adding a period of unpaid parental leave to the end of it. A maximum of four weeks parental leave may be taken in any one year. If a woman extends her ordinary leave by up to four weeks’ parental leave, the same return-to-work rights apply.
3.3 If she extends her leave by more than four weeks' parental leave, then if it is not reasonably practicable for her to return to the same job, an alternative can be offered but on the same terms and conditions.
3.4 After additional maternity leave the employee is also entitled to return to the same job, on the same terms and conditions as if she had not been absent. However, if there is some reason why it is not practicable for the employee to return to the same job she must be offered a similar job on terms and conditions that are no less favourable than her original job.
3.5 If there is no such suitable vacancy or if the employee unreasonably refuses to take a vacancy that is suitable, the Council can refuse to take the employee back. However, the Council cannot assume that the employee has resigned. If she does not do so voluntarily the employer must dismiss her. The potentially fair reason for the dismissal will normally be some other substantial reason.
3.6 If the employee does not want to return to work at the end of her maternity leave, she should submit the requisite contractual notice to terminate her contract.
3.7 If the employee wishes to return to work before maternity leave has ended she must give the Council at least eight weeks’ notice of the date on which she intends to return.
3.8 If annual salary reviews occur during the period of absence, the employee will be notified of her reviewed salary at this time. She will receive the reviewed salary upon her return to work. 4 Statutory Maternity pay
4.1 If the employee has at least 26 weeks’ continuous service and average weekly earnings, at the start of the 15th week before the child is born, are above the lower earnings limit for National Insurance then she will normally be entitled to receive Statutory Maternity Pay (SMP) whether or not she intends to return to work.
4.2 SMP is payable at two rates for a maximum of 39 weeks. For the first six weeks the higher rate will be paid which is 90% of salary. After this time the lower statutory rate will be paid for 33 weeks or 90% of normal weekly earnings if lower.
4.3 If an employee becomes eligible for a pay rise between the start of the original calculation period and the end of her maternity leave the higher or standard rate of Statutory Maternity Pay will be recalculated to account for the employee’s pay rise, regardless of whether Statutory Maternity Pay has already been paid. The employee will be paid a lump sum to make up any difference.
4.4 To be entitled to maternity pay, the employee must give 28 days’ notice in writing of her absence on maternity grounds (as above). If it is intended only to take maternity leave then the written notice, as referred to above, is required.
4.5 Maternity pay will be paid into the bank account on the same date that the employee would have received her salary and will be subject to the usual deductions for tax, National Insurance and pension contributions.
4.6 If an employee does not qualify for maternity pay then she may be able to claim state maternity allowance. HR will be able to give advice on how to claim this.
5 Council Maternity Pay
5.1 To qualify for Council Maternity Pay the employee must have one year’s continuous local government service at 11 weeks before the EWC.
5.2 Council maternity pay comprises: i. Full normal weekly pay for the first 4 weeks and then 2 weeks at 9/10 of normal weekly salary. ii. The following 12 weeks at half pay plus standard rate Statutory Maternity Pay, if she declares her intention to return to work after maternity leave. This is conditional on returning for at least 13 weeks on existing hours or if on different hours, a period that equates to 13 weeks. This is without deduction unless the combined half pay and Statutory Maternity Pay or Maternity Allowance exceeds normal full pay. Working for Barnet
Or:
12 weeks at the standard rate of Statutory Maternity Pay when not intending to return to work
Then in both cases:
21 weeks at the Statutory Maternity Pay rate (or 9/10 of weekly pay if paid less than the weekly Statutory Maternity Pay rate).
5.3 Leave after the 39th week will be unpaid.
5.4 If the employee does not qualify for Council Maternity Pay she will still receive Statutory Maternity Pay.
5.5 Employees will be asked to sign an undertaking to confirm that they intend to return to work for at least three months full time following maternity leave, or a part time equivalent undertaking. If the employee subsequently chooses not to return she will be required to pay back the 12 weeks half pay from the Council Maternity Pay.
6 Allowances
6.1 Essential Car User Allowance – Under national conditions employees continue to receive the basic lump sum element of the essential car user allowance for the first three months and then half rate for the subsequent three months of the paid maternity period. If the return to work is delayed for medical reasons, the lump sum element will be paid at half rate for an extended period of up to a maximum of 4 weeks.
6.2 Car Loans- Salary deduction for car loans continue only for the duration of paid leave. There is no requirement to continue repayments during the period of unpaid maternity leave. Employees may elect to continue their repayments pending their return to work.
6.3 Pension – Pension contributions will be deducted on the day that pay is awarded. The length of service for pension purposes will be credited at its full calendar length (or pro rata for part timers). Contributions will stop during unpaid leave but can be ‘bought back’ once an employee returns to work over an agreed period by contacting HR.
6.4 Season Ticket Loan – There is a requirement to repay any season ticket loan to the Council before starting maternity leave.
6.5 Childcare Vouchers – For further information refer to the Council’s Childcare Voucher Scheme as depending on circumstances suspension of childcare vouchers during paid maternity leave may be preferable to increase the maternity pay she will receive. 7 Health and safety
7.1 The Management of Health and Safety at Work Regulations 1999 require the Council to conduct 'suitable and sufficient' assessments of risks. This requirement includes a specific obligation, where a workforce includes women of childbearing age, to assess the safety issues that may pose a risk to a new, expectant or breastfeeding mother or her baby. This requirement applies regardless of whether there are employees of this nature at any particular time.
7.2 A maternity risk assessment must be competently performed, any employer who fails to carry out an adequate maternity risk assessment risks a successful sex discrimination claim.
7.3 When conducting an assessment of risk, the Council will need to take account of risks that could arise from any process or working conditions, including any physical, biological or chemical agents. All reasonably practicable steps should be taken to prevent exposure to risks through removing the hazard or through implementing controls. New and expectant mothers cannot be required to work nights if they have a medical certificate stating that such work could damage their health. Alternative suitable work or hours of work should be offered, if possible, at no loss of pay to the employee. If a risk is identified that cannot be avoided and no suitable work is available elsewhere in the organisation, the Council can suspend the employee from work on full pay. This is known as maternity suspension.
7.4 It is for these reasons that pregnant employees are required to notify their line manager’s as soon as they are aware that they may be pregnant. Arrangements will then be made to alter working conditions if necessary or, if that is not possible, a suitable alternative job will be offered for the duration of the pregnancy.
7.5 The alternative arrangements may continue for six months after the birth of the child if the mother is still considered to be at risk.
8 Keeping in Touch Days
8.1 During maternity leave both parties may make reasonable contact with each other as they see fit. The Council must keep the employee informed of promotion opportunities, or changes affecting the workplace.
8.2 The ‘Keeping in Touch (KIT) provision allows an individual on maternity leave to go into work for up to ten days, which may be separate days or a single block, without losing any Statutory Maternity Pay or triggering the end of the maternity leave. This provision does not allow the line manager to insist that a employee on maternity leave should come into work, nor does it confer a right on the employee to be offered any work. For this provision to work, both the line manager and employee must agree: Working for Barnet
- that the employee will do some work
- the type of work, for example attendance at a training course.
8.3 The employee will be paid her normal daily rate in respect of the work done, this is offset against the Statutory Maternity Pay paid in respect of the working days against wages / salary.
8.4 Any work done on any day during the maternity leave period will count as a whole KIT day. If an employee comes in for a half-day's training or part of a conference she will have used one KIT day.
9 Grievances related to maternity rights
If there is dissatisfaction with any decision made in respect of an employee's maternity rights, she should instigate the formal grievance procedure as set out in the Council's Grievance Policy.
10 Holidays
Both the full statutory annual leave entitlement and any additional contractual entitlement are accrued throughout both ordinary maternity leave and additional maternity leave.
11 MANAGEMENT BRIEFING
The following information can be used by managers to help them support their employees throughout their pregnancy and maternity leave.
11.1 Introduction
This briefing sets out your responsibilities and what you and your member of staff must do to benefit from the maternity provisions available to her.
Talking to your employee about her plans at an early stage will help you both. The check list below sets out what you should do or consider to help you both to manage her work during pregnancy, maternity leave and her return to work. As maternity provisions are complicated, you should maintain regular contact with HR to ensure that the process is managed effectively and that statutory provisions are met.
11.2 When your employee tells you she is pregnant
Talk to her about what action you need to take now:
- You must carry out a risk assessment to identify any risk to your employee’s health or that of her child. If there is a risk you must remove it or make alternative arrangements. The risk assessment applies while she is pregnant and after she has had her child and returned, particularly if she will be breastfeeding. Working for Barnet
- You must allow your employee paid time off to attend ante-natal appointments. Apart from the first appointment, she must show you an appointment card if you ask for one.
- You must make sure that your employee is not treated unfairly.
11.3 Planning
- She will be entitled up to 52 weeks’ maternity leave – does she know now whether she will be taking the full leave entitlement?
- Does she have annual leave to take before her maternity leave?
- How will you manage her absence?
- You must not allow her to work for the first two weeks after the birth or for 4 weeks if her role includes manual handling.
11.4 Points to consider when she goes on maternity leave:
- Reallocate work or take on a temporary member of staff – You must consider the possible implications of stress placed on staff covering for employees on leave with little or no cover.
- You must hold her job open. If she is taking her entire leave entitlement, you can offer her a suitable alternative job if it is not reasonably practicable for you to keep her original job open. Seek advice from HR where necessary
- If your employee is returning during or at the end of the first 26 weeks (ordinary maternity leave) she is entitled to return to the same job and terms and conditions as if she had not been away.
- If she takes more than 26 weeks (additional maternity leave) she is entitled to return to the same job on the same terms and conditions. If that is not reasonably practicable she is entitled to return to a suitable job on terms and conditions at least as good as her previous job.
- If you take on a temporary member of staff and you expect their employment to end when your original employee returns you must tell them on appointment, and remind them of the employees expected date of return.
11.5 Within 28 days of receiving the maternity leave dates
- HR will write to your employee telling her when she is due back at work.
- HR will confirm to your employee whether she is entitled to SMP and if so, how much. Your employee will qualify for SMP if she has been employed by you continuously for 26 weeks by 15 weeks before the week her baby is due and earns at least enough to qualify for National Insurance purposes. SMP is paid for 39 weeks. HR will tell her if she does not qualify for SMP by giving her a form SMP1 that will help her to apply for Maternity Allowance.
11.6 Employee responsibilities
11.6.1 By the 15th week before the week her baby is due your employee must tell you:
- She is pregnant
- When her baby is due
- When she wants her maternity leave and pay to begin.
She must confirm her plans in writing. Your response makes sure you both are clear when the maternity leave will end. She must give you at least 28 days’ notice of when she wants her Statutory Maternity Pay to start and of any change to her plans on starting maternity leave. If she does not, you may postpone the start of her leave unless there is a good reason for less notice being given.
11.6.2 If your employee is absent due to her pregnancy in the four weeks before the week her baby is due, you may start her maternity leave and pay from the day after the first day of her absence.
11.6.3 If she later changes her mind, she must give you eight weeks’ notice and you may postpone her return if you wish until you have had that notice, although you cannot postpone it past the end of the 52-week period. If you do not respond to her notification of leave she will be entitled to change her mind and return when she wants without giving any notice.
11.7 Keeping in Contact
11.7.1 You and your employee are encouraged to make reasonable contact during maternity leave. You should agree with her what kind of contact you will have, example;
- How you will let her know about any changes happening at work, including job vacancies?
- Will there be opportunities for her to work or attend training, team briefings or other events during her maternity leave? If so you can agree that she works for up to 10 days during her leave for which she can be paid without losing her Statutory Maternity Pay. These days are known as ‘Keeping in Touch Days’, see below.
11.7.2 Keeping in touch can help to make it easier for both of you when she returns to work. She is not obliged to do any work or attend any events during maternity leave but if you both agree she can do up to 10 days’ work for you during her maternity leave. These are Working for Barnet
known as Keeping in Touch days. Further information is contained in the Policy, Operational Guidelines and a checklist attached at Annex A.
11.8 Return to Work
11.8.1 Before your employee returns
You should talk to your employee to plan her return to work and think about the practicalities.
If you employed a temporary worker to cover her absence you should consider when you need to give notice.
If your employee changes her mind about her return date, she must give you 8 weeks’ notice of the change. If she has not and you need more notice you can postpone her return until you have had eight weeks’ notice, although you cannot postpone this past the end of the 52-week period.
If your employee makes a written request under the statutory right to request flexible working you must follow the set procedure. It may be deemed to be potentially unfair discrimination if she is unjustifiably refused a change to her working pattern. You must consider her request carefully. You can refuse on genuine business grounds or agree to a different arrangement. It would be advisable to speak to HR if you are intending to refuse her request and look at the Flexible Working Policy.
If your employee lets you know she will be breastfeeding, you must talk to her about any arrangements you will need to make, complete a risk assessment and address any risks. You must provide facilities for your employee to rest and to store expressed milk.
If your employee has taken additional maternity leave and there is a good reason why she cannot return to her original job, you must offer her a suitable employment on terms at least as good as her original job. You should let your employee know the reasons and what job she will be returning to.
11.8.2 When your employee returns
On the first day back into work following Maternity Leave the employee should have a return to work meeting to address:
- her general well being
- a discussion about the role that she is returning to Working for Barnet
- possible training that may be required arising from any changes whilst the employee has been away from the workplace
- agreement on a settling in period
- whether a risk assessment needs to be completed
- to ensure that the employee is fully aware of their leave entitlements e.g. Parental Leave, Leave for Dependents and the possibility of requesting flexible working in the future should this be required.
11.8.3 The qualifying week is either:
- the 15th week before the expected date of birth
- the week the adopter was matched with a child for adoption (for UK adoptions)
- the later date of either: the end of the week in which official notification is received or the end of the week in which they complete 26 weeks' continuous employment (for overseas adoptions).
At the end of the meeting you keep notes of the discussion.
12. Additional Paternity Leave
12.1 When an employee on maternity leave returns to work, additional paternity leave may be possible for eligible employees. This will enable the father of the baby and/or the husband or partner (including same sex partner or civil partner) to take up to 26 weeks' leave to care for their new child. This leave and pay is only available to qualifying employees if the mother, or co-adopter, has returned to work. Special provisions apply if the mother or co-adopter dies during their maternity or adoption leave or pay period.
12.2 Eligible employees can start their additional paternity leave any time from 20 weeks after the child is born. The leave must have finished by the child's first birthday. A minimum of two weeks and a maximum of 26 continuous weeks' leave can be taken. For an employee to qualify for additional paternity leave they must:
- be the father of the baby and/or the husband or partner (including same-sex partner or civil partner) of a woman who is due to give birth on or after 3 April 2011 - a partner is someone who lives with the mother of the baby in an enduring family relationship but not an immediate relative
- have, or expect to have, the main responsibility for the baby's upbringing, apart from any responsibility of the mother
- have at least 26 weeks' continuous employment with the Council ending with the qualifying week - the 15th week before the expected week of childbirth Working for Barnet
- continue to work for the Council from the qualifying week into the week before they wish to take additional paternity leave - weeks run Sunday to Saturday
- be taking the time off to care for the baby.
12.3 Maternity leave and APL do not have to run back-to-back. The mother does not have to take 20 weeks’ leave before returning to work but, if she takes less, there would have to be a gap before the father could start APL (because this cannot start until 20 weeks after the birth). Leaving a gap may mean that some additional statutory paternity pay (ASPP) is lost. The father/partner could be entitled to ASPP if there is at least two weeks of the mother’s 39-week statutory maternity pay, or maternity allowance, period left to run and this period cannot be put ‘on hold’.
12.4 Additional statutory paternity pay is payable to eligible workers who meet the eligibility criteria for additional paternity leave and:
- they are taking time off to care for their child during their partner’s 39 week statutory maternity pay, maternity allowance or statutory adoption pay
- their partners have returned to work.
12.5 To qualify for additional statutory paternity pay the employee must have:
- average weekly earnings at or above the lower earnings limit for National Insurance contributions in force at the end of the qualifying week - currently £97 per week
- at least two weeks of the mother’s or adopter’s statutory maternity pay or maternity allowance period remaining
12.6 Full details on the eligibility and notification process for additional paternity leave can be found in the Paternity Leave Operational Guidelines. 13. MATERNITY - EMPLOYEE BRIEFING
CONGRATULATIONS - WHAT YOU NEED TO KNOW
a. Notification of Pregnancy At the 15th week before your Expected Week of Childbirth (EWC) inform your manager and HR in writing, that you are pregnant, your EWC and when you want your maternity leave to start. Within 28 days of informing your manager, HR will confirm in writing, your entitlements and the dates when you should start maternity leave and when you are due to return to work. You can change your start date but must ensure you give 28 days notice of the change in dates.
b. Maternity Leave You must provide 28 days notice before starting maternity leave
Maternity leave can start no earlier then the 11th week before EWC – up to the actual birth or when trigged by pregnancy related illness
The leave entitlements are;
- 26 weeks ordinary leave, followed by
- 26 weeks additional' leave
c. Pay Depending on the eligibility criteria, you are entitled to Statutory Maternity Pay, Occupational Maternity Pay or Maternity Allowance.
Statutory Maternity Pay (SMP) - to qualify you must;
- have continuous service of at least 26 weeks but less than one year's continuous service by the 15th week before the EWC
- provide HR your manager your MATB1 certificate (available from your midwife after the 21st week of your pregnancy)
- earn above the lower earnings limit for the payment of National Insurance
- still be pregnant at the 11th week before the EWC
You will be paid: Working for Barnet
- 6 weeks pay at 9/10th of normal weekly salary
- Followed by 33 weeks at the SMP rate (or 9/10th of earnings for 33 weeks if paid less than the weekly SMP rate)
- The remaining 13 weeks are unpaid.
Please check with HR for the current SMP rate per week. If you do not qualify for Statutory Maternity Pay, Maternity Allowance which equates to Statutory Maternity Pay can be claimed from Jobcentre Plus.
d. Occupational Maternity Pay
If you have one year’s local government service before the 11th week of EWC and intend to return to work after the birth, you will be entitled to Occupational Maternity Pay, which is paid at
i. full normal weekly pay for the first 4 weeks and then 2 weeks at 9/10th of normal weekly salary
ii. the following 12 weeks at half pay plus standard rate SMP, if you declare your intention to return to work after maternity leave. This is conditional on returning for at least 13 weeks on existing hours, or if on different hours, a period that equates to 13 weeks. This is without deduction unless the combined half pay and SMP or Maternity Allowance exceeds normal full pay.
or
12 weeks at the standard rate of SMP when not intending to return to work.
i. 21 weeks at the SMP rate (or 9/10th of weekly pay if paid less than the weekly SMP rate).
ii. The remaining 13 weeks are unpaid.
e. Keeping in Touch
You will be allowed to work up to 10 days work providing both you and your manager agree to this and agree to what work will be undertaken during this time. For further guidance please refer to the Maternity Policy and the keeping in touch checklist.
f. Return Date
You are encouraged to confirm with your manager of your date of return. If you wish to change of date of return you will need to do this within 8 weeks before the end of ordinary maternity or additional leave. For more detailed information please refer to the Maternity Policy or contact HR. ANNEX A
KEEPING IN TOUCH CHECKLIST
Name: ...........................................................................
Service Area: ...........................................................................
Address for Correspondence: ........................................................................... ...........................................................................
I would like to receive a copy of the following whilst on maternity leave:
*Please delete as appropriate.*
Team Newsletter: Yes / No
New or changes to policies & procedures: Yes / No
Minutes of departmental meetings: Yes / No
New or changes to strategic policies & procedures: Yes / No
Internal secondments or job opportunities: Yes / No
Training and Development opportunities: Yes / No
Any other information - please specify: ........................................................................... ...........................................................................
Suggested action list
Frequency of contact (*please delete as appropriate*)
Weekly / Fortnightly / Monthly / Bi-monthly
Line manager/colleague(s) to pay home visit Yes / No
To receive regular updates on relevant team projects: Yes / No
Reorientation days to be organised on your return to work: Yes / No
Employee Signature: ........................................ Date: ..............................
Line manager Signature: ........................................ Date: ..............................
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8ac850f0c944ad4ea0cbdf703392bf67eeb722d6 | B17 Time Off For Dependents Policy
1 Policy
1.1 The policy aims to give employees, both male and female, the right to reasonable time off for dependants in the event of a birth, illness, illness, an assault, emergency situations, or as a consequence of death. The circumstances have to be unforeseen and the right also extends to making arrangements for the provision of care.
1.2 The above forms the Council’s policy as at November 2010, it should be noted that:
- the policy does not confer any contractual rights
- the Council will retain the right to review the policy at any time. Changes may result from employee, management and trade union feedback and/or from changes in employment legislation. The Council, following consultation with recognised Trade Unions, will implement revisions and updates.
- The policy will cease on the 1 April 2015.
2 Scope
2.1 This policy applies to all Council employees, including Head Teachers, Teachers and Chief Officers.
2.2 A Chief Officer is defined as a Deputy Chief Executive, Assistant Chief Executive, Director or a designated Deputy to one of the Directors.
2.3 This policy excludes the Chief Executive.
2.4 The policy is recommended for implementation by staff directly employed by schools, for example those based in Academies.
3 Principles
3.1 This Policy applies to all eligible employees of the Council regardless of the number of hours worked per week.
3.2 There is no qualifying service period required to entitle an employee to take Dependant Leave.
3.3 The opportunity to take time off for Dependant Leave is in an emergency only. It does not cover such situations as, for example, taking a dependant to a previously agreed hospital appointment.
3.4 The Council expects that leave taken within this Policy should not usually be more than two periods of 1 or 2 days absence in any 6 months, but it will depend on the situation and be up to the line manager’s discretion.
3.5 The Council may not expect the employee to rearrange working hours, or make up time that has been lost.
3.6 During any period when the employee is taking Dependant Leave he or she is not entitled to pay, however continuity of service will continue to accrue.
3.7 Where an employee applies for Dependant Leave and this is declined and he or she subsequently fails to attend for duty this will be recorded as unauthorised absence. Unauthorised absence may be subject to the application of the Conduct Policy and Procedure.
4 Taking Dependents Leave
4.1 A dependant of an employee is defined in the legislation as one of the following:
- husband or wife or partner
- child
- parent
- someone else who is regarded as part of the family and lives with an employee
- anyone else who is reliant on an employee in emergency situations, or
- a person who lives in the same household as the employee, but not a tenant or lodger.
4.2 Employees can request unpaid Dependant Leave to take action that is necessary:
- to provide assistance on an occasion when a dependant falls ill, gives birth or is injured or assaulted;
- to make arrangements for the provision of care for a dependant who is ill or injured;
- in consequence of the death of a dependant;
- because of the unexpected disruption or termination of arrangements for the care of a dependant; or
- to deal with an incident involving a child of the employee that occurs unexpectedly during a period when the child is attending school.
4.3 In determining whether the leave is 'necessary' the Council will consider the following factors:
- the availability of someone else who can help in the circumstance
- the nature of the incident
- the relationship of the employee with the dependant.
- the number of occasions such leave has been sought previously 4.4 In assessing an application for Dependant Leave the Council may choose not to take into account the needs of the business and any disruption that the leave might cause. However, if the employee has taken Dependant Leave on previous occasions the Council will take into consideration the following:
- the number of times the employee has taken time off
- the length of time the employee has taken time off
- when the time off was taken
- whether on each occasion the employer was informed of the absences.
4.5 In many situations the Council will not have the opportunity to refuse the leave, because the employee will be informing the Council after the event of the emergency. However, the Council can consider refusing Dependant Leave with regard to the following:
- where it is not necessary to take the time off, for example, if a child has had a serious accident it would be reasonable for both parents to go to the hospital, but if a child minder was ill it would not be reasonable for both parents to leave their work to care for the child.
- where the amount of time requested by the employee is deemed to be unreasonable.
5 Notice, Dependant Leave
5.1 The opportunity to take time off for Dependant Leave is in an emergency only. The very nature of this means that there should be no planning of the leave in advance. However, the employee is required to inform their line manager as soon as reasonably practicable about the absence, the reason for it and the anticipated length.
5.2 The employee is required to give regular updates if the absence goes on for more than one day, he or she is expected to keep their line manager informed.
5.3 If the employee agrees a length of absence with their line manager, the employee cannot extend this without agreement.
6 Pension Implications
6.1 There are no pension implications for unpaid leave of less than 30 days. The Council does not pay pension contributions for any periods above 30 days, however the employee may elect to continue making pension contributions.
6.2 For teaching staff in the Teachers Pension Scheme unpaid leave will be reflected as a loss of service for those days.
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13e472f574c6ef00d6dfc5eaad2205d2015bb922 | Research Summary Exploring governance in Afghanistan
Summary
- BBC Media Action, with funding from the UK’s Department for International Development through the Global Grant, is working in Afghanistan to deliver a series of political debate/discussion programmes entitled Open Jirga on television and radio.
- Afghans reported that there have been some significant improvements over the past 10 years, particularly in terms of education, healthcare, construction projects and electricity supply.
- Corruption remains a serious issue within the country. This was an issue expressed by many participants. Fighting corruption is seen as a key priority.
- Afghans reported a preference to refer issues to their traditional elders, rather than to the government. Only if elders pass on an issue will Afghans interact with the government.
Context The goal of building a modern, stable functioning state in Afghanistan continues to be a key challenge. After almost three decades of war, the country remains a fragile state, experiencing ongoing conflict and political and social challenges. There have, however, been some positive achievements in recent years. Since 2002, the economy has grown by over 10% per year. Just under 2 million girls are now estimated to be receiving an education, compared to virtually none under the Taliban rule, and health care provision has improved for large numbers of the population. In 2010, the Afghan Ministry of Public Health claimed that 90% of the population was within a two-hour walk of Primary Health Care Services, as opposed to 9% in 2000. As the country prepares for the withdrawal of international combat forces, there are concerns about the sustainability of these achievements.
The project BBC Media Action, with funding from DFID, is working in Afghanistan to deliver a political debate/discussion programme on television and radio. The programme’s title is Open Jirga and aims to increase accountability between citizens and government. The debates will be produced in partnership between BBC Media Action and Radio Television Afghanistan (RTA) with national coverage. The debates will also be supported by governance related scenes in the existing radio drama New Home, New Life, as well as radio educational feature programmes, produced by Afghan Education Production Organisation (AEPO). The BBC Media Action research team conducted formative qualitative research to understand behaviours and attitudes to governance, media and accountability in order to inform and support programme development.
Research methodology
1 Islamic Republic of Afghanistan, Ministry of Public Health, Annual Report 1387. 2 Jirga is Pashtu for an assembly, but the word is also regularly used in Dari. The research consisted of 96 paired depth interviews among men and women aged 18-55 in both urban and rural areas who were both BBC listeners and non-listeners. Interviews were conducted in the broadcast areas across the Kunduz, Wardak, Uruzgan, Nangarhar, Nimroz and Badakshan provinces. The research sampled the main ethnicities within Afghanistan (Pashtuns and Tajiks) as well as minority groups such as the Baluch and Uzbeks, and covered both Pashtu and Dari speakers.
Findings The majority of participants reported corruption to be a major issue in Afghanistan. One participant from Uruzgan stated that: “Official corruption is very strong in Afghanistan, as if it’s an article in the constitution.” Whilst corruption was widely viewed as an issue, people’s reactions to it varied depending upon which province they were from. In the more pro-Government areas (Nangarhar and Kunduz) corruption was viewed with reluctant acceptance, whereas in the areas with an active insurgency (especially Uruzgan but also Wardak) it aroused more hostility.
Ten years after the establishment of democracy in Afghanistan, participants reported they were still reticent to go to their government as they expected to have to bribe officials. Rather, people looked to their traditional tribal or village elders for conflict resolution and the first level of leadership. A participant from Nangarhar commented that: “If the elders could not solve the conflict issue, government cannot solve the issue.” Only if the elders passed on an issue do Afghans seek a resolution involving the government. Participants felt that elders are more trustworthy than the government, although it is still accepted that in some cases, elders too need to be bribed.
Participants perceived progress had been made over the last ten years. Education was highly valued and was consistently viewed as a positive since the fall of the Taliban regime. Construction, particularly of roads, was frequently cited as having improved. An overall increase in healthcare services was also noted, along with the wider availability of electricity. One participant from Kunduz stated that: “Despite issues, there have come many changes in the last 10 years that can’t be ignored. Girls can go to school and women can work. Private universities, schools, clinics and hospitals are built, roads are paved.”
Implications Afghans generally have had negative direct experiences with their government, thereby devaluing democracy to many. This raises the issue that simply aiming to improve understanding of the democratic process may not be sufficient to improve public deliberation and interaction between citizens and political leaders, since the democratic process itself holds little currency in the eyes of some of the population. This would seem to be especially true of the people outside of Kabul, particularly in the south and east of the country where the Taliban and other insurgent groups draw their strength. It may be advantageous for the programmes to explore the value of democracy itself before moving onto its checks and balances.
At present, the Afghan population is reluctant to interact with its own government, preferring the traditional leadership of local elders. Therefore, the role of the local elder is an important one for the radio drama. It is also recommended that elders be monitored as a distinct stratum of decision makers within their own communities.
Contact For more information about this research please contact [email protected], +44 (0)20 8008 001.
Craig Robinson, September 2012
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45c2766ac0b644fab1a327aad84ecc321639c136 | STAND FOR WHAT YOU BELIEVE IN BE A COUNCILLOR www.beacouncillor.co.uk Stand for what you believe in
Be a councillor
What matters to you in your local area? Is it the state of the local park, the need for more activities for young people, improving services for older people, making the roads safer or ensuring that local businesses can thrive? Whatever needs changing in your neighbourhood, you could be just the person to change it by becoming a local councillor.
Perhaps you are already involved in your community and local affairs and want to take the next step. Or you may be looking for a worthwhile and rewarding way to help your local community.
There are more than 20,000 local councillors in England and Wales, each representing their local community and all with their own reason for doing so. In order to be truly democratic, councils need to be representative of their community. To make the best decisions, they need to draw on a wide range of skills, experience and knowledge of what the local community wants and needs. Councils need people from all parts of the community who can bring their own perspective on what is needed locally.
Are you ready to help change the face of local government?
No other role gives you the chance to make such a huge difference to the quality of life for people in your local area. Be independent
Did You Know… Independent Councillors, and those from smaller political parties such as the Green Party, UKIP and Plaid Cymru in Wales, play a key role in local government.
There are things that all prospective candidates should know before they embark on an election campaign. This guide will look at some of these issues and help you decide whether to take the plunge and stand for election to your local council.
Tip: the legal requirements and process for becoming a councillor can be found on the Electoral Commission’s website: www.electoralcommission.org.uk/i-am-a/candidate-or-agent
Councillor Gillian Ford Residents’ Association, London Borough of Havering
Having childhood holidays in my parents’ friend's retirement home, I grew up helping out where I could. Aged sixteen, I was invited on to a social committee, representing young people to raise funds and activities for the community. Next came voluntary work in the local school and a position on the school governing body. Being asked to go on the Residents’ Association Committee followed with the request for me to stand as a councillor. This was the obvious next step in influencing, supporting and improving the lives of others. I have found my councillor role incredibly rewarding and a humbling experience.
✔ Volunteer ✔ Artist ✔ Dementia friend champion ✔ Local councillor How do councils work?
Tip: Have a look at your council's constitution, which is the rule book of the council. This provides the framework within which the council conducts its business and makes decisions.
This depends on the type of council. There are several types of local council, for example parish (or community councils in Wales), town, district, borough, county, metropolitan and unitary authorities. Sometimes these are referred to as local authorities. Each area is divided into wards or divisions, and one or more councillors represent each ward.
All councils are led by democratically elected councillors who, working together, set the council’s vision, direction and budget. Most councils are run on a system similar to that of central government, with a small elected executive (or cabinet) to decide on policy and make decisions which other councillors then ‘scrutinise’ or examine in detail. All councillors can research the issues that are affecting their residents and make recommendations. Some councils work with a ‘committee system’, where decisions are made across a range of committees.
All councils (with the exception of town or parish councils) are large organisations that play a big part in the local economy and influence many aspects of the lives of the people who live and work there. Central government still has some influence over councils through controlling some of their funding and through legislation, however, this is lessoning as more powers are devolved locally. Councils vary widely in terms of their style, political leadership and approach to delivering programmes, and it is here that your community links and local knowledge will make a real difference. Depending on the type of local authority it is, a council can be responsible for a range of services, including:
- planning and licensing
- education and lifelong learning
- health and wellbeing
- children’s and adult social care
- housing and regeneration
- community safety and cohesion
- waste collection and recycling
- roads and street lighting
- arts, sports and culture
- transport.
Councils now deliver much of what they do in partnership with other councils, services and agencies, so as a councillor you may have opportunities to sit on partnership boards or committees for health, education, community safety or regeneration.
______________________________________________________________________
**Councillor Bob Dutton**\
Independent, Wrexham County Borough Council
Having served in local government at its senior officer level I had no intention of moving into the world of councillors but I was attracted by being able to do what is best for the individual and communities. I was elected and led our Independent members, eventually collaborating with other groups to take control of the council. It is a fascinating world for the newcomer, opening areas of new interest and training and working with colleagues in all sorts of organisations, finding out how important their local councillor is to everyone. Councils influence decisions made on many services for the person in the street. In Wales if you don't speak Welsh you may find it helpful and enjoyable to learn it as increasingly business may be conducted in both languages as a way of protecting the heritage of the oldest tongue in Europe.
- Chartered civil engineer
- Economic development adviser
- Former council chief executive
- Local councillor Councillor Martin Fodor\
Green Party, Bristol City Council
I worked in local government for many years, dealing with policies around environment, sustainability, economy and community – both locally and nationally. I’ve always been active in my area but was never really involved in party politics. Then more and more friends suggested I should get involved with the Green Party and I helped in our first mayoral campaign in the city. As a 'paper' candidate I was runner up in my ward so everyone asked if I’d stand and get elected. I was already known for getting quite a few things done in the area, working with local traders, community groups and others. After a lot of canvassing I won the seat. Being on the politicians' side of the room was not too much of a shock for me, though it can be.
I find asking questions in scrutiny meetings and quizzing the Mayor at question time can be revealing and influential. There are several jobs to take on as a councillor: dealing with ward case work, to help people who can't get action out of the system; being part of a party group which is known for being well prepared and active in issues across the council; explaining how the council works, so people understand what can be changed locally; helping my local party build its influence and reputation for elections; and pursuing personal projects and interests with persistence to make a difference to the development of our city.
- Enjoys local art and music
- Created a home energy saving course
- Runs home energy efficiency workshops
- Local councillor What do councillors do?
Councillors are elected to a council to represent their local community, so they must either live or work in the area. Becoming a councillor is both a rewarding and privileged form of public service. You will be in a position to make a difference to the quality of people's daily lives and to their prospects.
Being an effective councillor requires commitment and hard work. Councillors must listen to the views of residents, other councillors and experts and work to bring them together to a common aim.
Residents, outside bodies and community groups, the party or group you belong to (if applicable) and the council, will all make legitimate demands on a councillor's time, on top of the demands and needs of their personal and professional lives. If you are considering becoming a councillor it's worth discussing the idea with your family and friends. You will need their support as you will have to spend time attending to council business, and depending on your ambitions this can amount to a substantial amount of time (more on that later).
One council estimates the time commitment as ranging from five to 20 hours a week. Your role within the council will determine how much time you spend on council duties. Joining a planning committee, for example, will increase your workload. As with most things in life, what you get back will depend on what you put in. Who can be a councillor?
The easy answer is almost anyone can be a councillor, as long as you are: • British or a citizen of the Commonwealth or European Union • at least 18 years old • registered to vote in the area or have lived, worked or owned property there for at least 12 months before an election.
You can’t be a councillor if you: • work for the council you want to be a councillor for, or for another local authority in a politically restricted post • are the subject of a bankruptcy restrictions order or interim order • have been sentenced to prison for three months or more (including suspended sentences) during the five years before election day • have been convicted of a corrupt or illegal practice by an election court • have not paid your council tax.
Tip: If you are in any doubt about your eligibility to stand, contact the returning officer in the electoral services department at your local council for advice.
There are many reasons why people decide to become a local councillor. They include: • wanting to be involved in shaping the future of the local community • wanting to ensure that the community gets the right services • wanting to represent the views of local people • wanting to contribute particular skills • concerns about one particular issue. What’s expected of a councillor?
Tip: Look at your council's handbook and code of conduct for members. It is intended to assist councillors in their work at the council.
The councillor’s role and responsibilities include:
• community leadership, engagement and support • making decisions • developing and reviewing council policy • scrutiny and holding the executive/cabinet to account • regulatory, quasi-judicial and statutory duties.
Being available for community members to contact is an important part of a councillor’s job. Many councillors enjoy attending local events and meetings. Some produce newsletters or use social media or blogs. Some hold regular drop-in surgeries, which provide a chance for residents to discuss their problems or concerns. Much of a councillor’s work can be done by telephone, letters or email, though sometimes it is better to arrange meetings with residents or council staff to resolve issues. Sometimes all a resident needs is to be directed to the right information and/ or contacts to enable them to deal with an issue themselves.
All councillors are expected to attend full council meetings, and most attend scrutiny meetings (the process of examining the work and decisions of the executive). Councillors may also choose to sit on quasi-judicial committees, for example planning and licensing committees which take non-political decisions on applications. The timing, number and length of these meetings varies from council to council. Depending on the arrangements within your council, you will have opportunities to join relevant political or Independent Group meetings as well as training events. Do I need any special skills or experience to be a councillor?
It’s important that councils have councillors who reflect and represent the communities they serve, and also have a broad range of skills and life experience. You don’t have to be highly educated or have a profession. Skills gained through raising a family, caring for a sick or disabled relative, volunteering or being active in faith or community groups can be just as valuable.
While you don’t need any special qualifications to be a councillor, having or being able to develop the following attributes will help you in the role:
• communication skills • problem solving and analytical skills • team working • organisational skills • the ability to engage with your local community.
Don’t worry if you don’t yet feel that you have all the skills to be a councillor. All councils provide support, information and training for new councillors.
Councillor Liz Hazell UK Independence Party, Walsall Council
When you hear a politician – do you think that you could do a better job? Do you look around your area and think, I want to improve this? Are you interested in the people and places around you? Do you care? Do you prefer to do something rather than moan about it? Do you believe in democracy, right and wrong? Are you willing to stand up and speak out?
Then your council needs you.
✔ Worked in manufacturing ✔ Past photographer for AutoTrader ✔ Retrained as an electrician ✔ Local councillor Will I get paid for being a councillor?
Tip: Find out more about the allowances scheme run by your local council on their website.
Councillors don’t receive a salary, but they do get a ‘member’s allowance’ (which is taxable) in recognition of their time and expenses incurred while on council business. Each council sets its own rate for these allowances. If you are on benefits, these allowances can affect your entitlement, so get advice before agreeing to stand.
There is also a childcare and dependents’ carers’ allowance for attendance at meetings payable on production of receipts, up to an agreed maximum cost per hour. Council’s I also provide a special responsibility allowance to those who undertake additional duties such as the leader of the council, portfolio holders, scrutiny chairs and opposition leaders.
Councillor Randy Conteh Independent, Stoke on Trent City Council
I have been a councillor for 10 years and although it’s hard work I genuinely enjoy it. My role includes addressing residents’ concerns, responding to local petitions or organising consultation events, combined with fun days. My achievements include improving the facilities for younger people in two local parks – eight years of hard graft from consultation to completion. Being a councillor within an independent group means that we are not subject to any party whip – we are allowed to vote as individuals, and I always vote with my conscience. If you tell the truth, speak from the heart and talk sense, then people will listen.
☑️ Supports Stoke City Football Club ☑️ Active in community groups ☑️ Organises charity events ☑️ Local councillor Can I be a councillor and have a job?
Yes. By law if you are working your employer must allow you to take a reasonable amount of time off during working hours to perform your duties as a councillor. The amount of time given will depend on your responsibilities and the effect of your absence on your employer’s business. You should discuss this with your employer before deciding to stand for election.
Councillor Lyn Ackerman Plaid Cymru, Newbridge Borough Council and Caerphilly County Borough Council
I wanted to become a councillor to improve my community. I had done a few trips into England due to sporting interests and they always seemed to have much nicer facilities than us. It made me question what was happening to our council’s budget and where and how it got spent.
I had been involved in politics quite young due to my father’s interest and it was a natural progression to follow him in that regard. You soon realise that women are under-represented in councils, but the population figures show we are more in number. It gave me the drive to make sure that women’s voices got heard.
- Volunteers for people with learning disabilities
- Plays darts
- Former rugby player and referee
- Local councillor I have a disability, can I be a councillor?
The Public Sector Equality Duty, places a specific duty on public bodies, including Local Authorities, to consider all individuals when carrying out their day-to-day work, from shaping policy, to delivery of services and in relation to their own employees.
Councils are required to make 'reasonable adjustments' to accommodate the needs of disabled councillors, who would otherwise be placed at a disadvantage compared to non-disabled councillors. It is an ‘anticipatory duty’ meaning that councils must think in advance about the needs of disabled people and make reasonable adjustments.
Once you become a councillor, your council will work with you to overcome any barriers you come across as a result of your disability and will make sure you can be fully involved. Being a councillor is not a full-time job and may not affect any benefits you receive, but individual cases will vary so do check this with your benefits office.
Government Guidance to the Equality Act 2010 www.gov.uk/guidance/equality-act-2010-guidance
The Government Equalities Office www.gov.uk/government/organisations/government-equalities-office
The Equality and Human Rights Commission www.equalityhumanrights.com/en What support is available to elected councillors?
Councils have staff, known as officers, available to provide support and assistance. Exactly what facilities you get will depend on the council. Many will provide a computer for your home and some may pay for internet access and an additional telephone line and/or mobile phone. Councils also provide induction and training for new councillors.
Once elected, independent councillors can find it useful to formally link up with other Independent members of the council. Joining an Independent Group will help you to gain the maximum number of seats on council committees and increase your influence.
If you stood for a smaller political party, representatives from that party will give you guidance on group working locally. Next steps
If you are interested in being a councillor here’s some next steps to consider:
1. Put yourself forward as a candidate
If you choose to put yourself forward as a candidate and want to stand as a representative of a group, association or political party, you will need to make contact with their local office. You will be able to find their contact details online, via the council’s electoral services department or via the LGA’s Independent Group Office.
Your council’s electoral services department can tell you when elections are next taking place. They can also point you towards useful sources of information in the council and the steps you need to take to be formally nominated.
Once you’ve decided to put yourself forward as a candidate you need to be prepared to put in the hours, both during the campaign and after.
2. Start building your profile so that voters know who you are
Now that you’ve decided to stand you will need to work out your position on local ‘hot’ issues such as crime, traffic, the environment and schools.
You will need to know what the council is doing about these issues and how your opinion differs from other candidates. Nearer election time, as you start going door to door persuading people to vote for you, you will be challenged on your opinions.
You may also want to begin building a network of supporters who will help with your election campaign.
Once you have identified the key issues and determined your key messages, get leafleting and door knocking early and often. 3. Ensure you are officially nominated as the election date draws nearer
This means getting 10 people to sign your nomination papers (signatories must be registered electors in the ward where you wish to stand). These papers are available from your local council’s democratic services department.
You must also give your consent in writing to your nomination.
The council will also confirm dates for nomination papers and elections, as occasionally the pattern might change. However usually all the necessary documents should be submitted 19 working days before the day of the election.
For more information, visit www.beacouncillor.org.uk or the Electoral Commission website: www.electoralcommission.org.uk
The timescale
Most councillors are elected for four-year terms, but councils run different electoral cycles. To find out when local elections are due to take place in your area, contact your local council or visit its website.
Ideally, you will need to begin campaigning at least a year before an election so that you can get to grips with the important local issues, meet as many voters as possible and raise your profile before the election takes place. Further information
If you want to be an Independent Councillor or represent an established party, outside of Labour the Conservatives or Liberal Democrats you can receive support from the LGA Independent Group office. They cannot provide direct help with election campaigning but can offer general advice and assistance. Once elected, you can access their regular regional meetings, information and development seminars, bulletins, training and peer support.
LGA Independent Group Office Telephone: 020 7664 3224 Email: [email protected] Website: www.lgaindependent.local.gov.uk
@LGA_Independent
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58b5bc74a76af872afeca3e83aeb09b9bcbeac98 | Appendices to the Religious Archives Survey 2010
Appendix I: List of respondents 2 Appendix II: Organisations not included in the survey 8 Appendix III: Tables of results 9 Appendix IV: Religious Archives Survey questionnaire 24 Appendix V: Religious Archives Survey covering letter 32 Appendix VI: Survey of personal papers: survey letter and form 34 Appendix I: List of respondents
Note: This list of respondents to the Religious Archives Survey includes organisations submitting negative returns as they did not hold, or had not deposited, any archives. Another eight organisations indicated that they did not wish for any publicity and 13 sent in late returns. Information from the latter could not be included in the published results but, where permission has been given, details of their historical records will be added to the National Register of Archives.
Buddhist
Atisha Kadampa Buddhist Centre, Darlington Birmingham Buddhist Vihara Bodhisattva Buddhist Centre Buddhapadipa Temple Buddhist Publishing Group Cambridge Buddhist Centre, Cambridge Clear Vision Trust Croydon Buddhist Centre Dharmachakra Archives, Cambridge Edinburgh Theravada Buddhist Group Friends of the Western Buddhist Order, Norwich Glasgow Theravada Buddhist Group London Buddhist Centre Maitrikara Centre, Brighton Marpa House, Ashdon
Christian: Anglican
All Saints Educational Trust Belfast Cathedral Birmingham Cathedral Bristol Cathedral Bradford Cathedral Broken Rites Canterbury Cathedral Carlisle Cathedral Cathedral Church of St John the Divine (Oban) Cathedrals Plus Chelmsford Cathedral Chester Cathedral Library Chetham’s Library Children’s Society Christ Church Oxford Church Housing Trust Church of England Evangelical Council Church Society Church Times Church Union College of Readers Community of All Hallows Community of St Denys Community of St Francis Community of St Peter, Horbury Community of the Holy Name Community of the Sacred Passion Community of the Servants of the Will of God Confraternity of the Blessed Sacrament Crosslinks Derby Cathedral Dromore Cathedral Elland Society English Clergy Association Evangelical Alliance Exeter Cathedral Archives Forward in Faith Gloucester Cathedral Guildford Cathedral Keswick Convention Trust Keychange Charity Liverpool Cathedral Manchester Cathedral Marshall’s Charity Mothers’ Union Newcastle Cathedral Newton Trust Nikaean Club Parish Clerks, Worshipful Company of Pilsdon Community Portsmouth Cathedral Pusey House Reform Revd Dr George Richards Charity Ridley Hall Rochester Cathedral Royal Martyr Church Union Rural Theology Association Sheffield Cathedral Shrine of Our Lady of Walsingham Simeon’s Trustees Sisters of Bethany, Southsea Society of Faith Society of St Francis Society of St. Francis, Third Order Society of the Precious Blood Society of the Sacred Mission Society for Promoting Christian Knowledge (SPCK) St Columb’s Cathedral, Londonderry St George’s Chapel Archive, Windsor St John’s College, Nottingham St John’s Guild St John The Divine Cathedral, Oban St Margaret’s Convent, Uckfield St Mary’s Abbey, West Malling St Michael’s Convent, Richmond St. Paul’s Cathedral St Peter’s Home Sisterhood St Peter’s Saltley Trust Wakefield Cathedral Wells Cathedral Westminster Abbey Worcester Cathedral
Dr John Ward Trust Ealing Trinity Church Methodist Circuit Eastbourne College Edgehill College Epworth Old Rectory Evangelical Presbyterian Church in England and Wales Evangelical Lutheran Church of England/ Westfield House of Theological Studies Evangelical Fellowship of Congregational Churches Fellowship of Independent Evangelical Churches Ltd Fernley Hartley Trust General Conference of the New Church Grace Baptist Mission Harris Manchester College Henry Martyn Centre for Mission Studies Huguenot Library Independent Methodist Archives Resource Centre John Rylands University Library Kendal and Sedbergh area meeting Leighton Park School Lutheran Church in Great Britain Mainstream Methodist Chapel Aid Ltd Methodist Youth Activities Ltd Moravian Church Archive and Library National Church Association Nazarene Theological College Norwegian Church and Seamen’s Mission The Park School Particular Baptist Fund Pennar Community Church (formerly Bethany Baptist) Pilots (United Reformed Church Youth Organisation) Plymouth Methodist Central Hall Oxford Brookes University Reformed Presbyterian Church of Scotland Quaker Homeless Action Quakers and Business Group Salt and Light Ministries Salvation Army International Heritage Centre Scottish Baptist College Scottish Baptist History Archive Scottish Church History Society
Christian: Nonconformist
Ashwell United Reformed Church Association of Teetotallers in Methodism Baptist Missionary Society (BMS) World Mission Bookham Baptist Church Bootham School Centre for the Study of World Christianity, University of Edinburgh Christadelphian Magazine and Publishing Association Ltd Church of England (Continuing) Donald Gee Centre for Pentecostal and Charismatic Renewal Sidcot School Society of Friends of St Andrews Jerusalem Spectrum Engage Stansted Hall: Arthur Findlay College Strict Baptist Historical Society Union of Welsh Independent Churches United Reformed Church Caravan Fellowship United Reformed Church History Society Wesley College, Bristol Wesley House, Cambridge Wesley Historical Society in Ireland Westminster and Cheshunt College Library World Methodist Historical Society (British Section) Wycliffe Centre
Christian: Roman Catholic
Adorers of the Sacred Heart of Jesus of Montmartre, Order of St Benedict Aid to the Church in Need, Scotland Aid to the Church in Need, UK Archdiocese of Glasgow Archdiocese of Liverpool, Liverpool Metropolitan Cathedral Archives of the British Province of the Society of Jesus, London Arundel Cathedral Church of Our Lady and St Philip Howard Assumption Convent, London Augustinian Recollects Bar Convent, York Belmont Abbey, Hereford Benedictine Abbey, Curzon Park South, Chester Benedictine Monastery, Largs Birmingham Archdiocesan Archives Brentwood Diocesan Archives Brentwood Ursulines Campion Hall, Oxford Canonesses of Saint Augustine, Congregation of Our Lady Canonesses of the Holy Sepulchre, Colchester Cardinal Tomas O’Fiaich Memorial Library Carmelite Friars, East Finchley, London Carmelite Monastery, Dolgellau Carmelite Monastery, London Carmelite Monastery, Ware Park Carmelite Third Order Catholic Association Catholic Association of Performing Arts (formerly Catholic Stage Guild) Catholic Bishops’ Conference of England and Wales Catholic Medical Association (formerly Guild of Catholic Doctors) Catholic Missionary Society Congregation of Our Lady of the Missions, UK Province Convent of Notre Dame (Company of Mary, Our Lady), Cobham Convent of Our Lady of Providence, Alton Convent of the Holy Child Jesus, Oxford Daughters of Charity of St Vincent de Paul, Provincial House Daughters of Jesus, Rickmansworth Daughters of Mary and Joseph Daughters of the Heart of Mary, London Daughters of Wisdom Great Britain and Ireland Provincial Archives De La Salle Brothers, Oxford Diocesan Archives, Norwich Diocese of Arundel and Brighton Archives Diocese of Clifton Diocese of Hexham and Newcastle Diocese of Middlesbrough Diocese of Shrewsbury Curial Offices Diocese of Wrexham Dominican Missionary Sisters of the Sacred Heart of Jesus, Crawley Douai Abbey Faithful Companions of Jesus, Pro vincialate, Salford Faithful Companions of Jesus, Generalate, Broadstairs Franciscan Missionaries of the Divine Motherhood, Ladywell Convent, Godalming Franciscan Sisters of St Mary of the Angels Grail Society HCPT – The Pilgrimage Trust Holy Ghost Fathers, Bromley Institute of the Blessed Virgin Mary, Loreto Convent, Llandudno Institute of Our Lady of Mercy Archive, London Josephites, St George’s College, Addlestone Knights of St. Columba Little Company of Mary, Ealing, London Little Company of Mary Generalate, Tooting Bec Medical Mission Sisters, London Medical Missionaries of Mary, Ealing, London Missionaries of the Poor Supporters Association Missionary Sisters of the Sacred Heart, Honor Oak Oakford Dominican Sisters Pastoral Research Centre, Taunton Pluscarden Abbey, Elgin Pontifical Institute of the Religious Teachers, Convent of St Lucy, Alton Poor Servants of the Mother of God, Central Archive Prison Advice and Care Trust Roman Catholic Bishopric of the Forces Sacred Heart Convent, Reasby Sacred Heart Fathers and Brothers of Betharram Sacred Heart of Mary Convent, Upminster Salesian Provincial Office, Bolton Salesian Sisters, London Salford Diocesan Archives Salvatorian Sisters, Divine Saviour Convent, Bristol Scalabrini Fathers, Henley Scottish Catholic Archives Servite Sisters (Servants of Mary), St. Joseph’s Priory, Dorking Salvatorian Sisters, Divine Saviour Convent, Bristol Servite Friars, Province of the Isles, Tyrone Servite Secular Institute Sisters of Charity of Our Lady of Evron, Stockport Sisters of Charity and Mary, Plympton Sisters of Christian Retreat, East Molesey Society of Jesus, British Province Sisters of Jesus and Mary, Felixstowe Sisters of Nazareth General Archive, London Sisters of Providence of Ruille-sur-Loire Sisters of Saviour and Blessed Virgin, Villeneuve d’Ascq, France Sisters of the Poor Child Jesus, Southam
Sisters of the Sacred Hearts of Jesus and Mary (SSHJM) Society of Catholic Artists Society of the Sacred Heart, London Special Projects In Christian Missionary Areas (SPICMA) St Augustine’s Abbey, Ramsgate St Clare’s Convent, Liverpool St Cuthbert’s College, Ushaw St Dominic’s Convent, Stone (English Dominican Congregation of St Catherine of Siena) St Edmund’s College, Cambridge St George’s Cathedral, Southwark St Joseph’s Hospice Association St Margaret’s Children and Family Care Society, Glasgow St Marie’s Cathedral, Sheffield St Mary’s Cathedral, Wrexham St Mary of the Angels Franciscan Friary, Franciscan International Study Centre, Canterbury St Mary’s Abbey, Colwich St Mary’s Convent, Birmingham St Mary’s Metropolitan Cathedral, Edinburgh St Mirin’s Cathedral, Paisley Stonyhurst College, Clitheroe Union of Catholic Mothers Union of Irish Ursulines, Brecon Union of Sisters of Mary, Birmingham Westminster Diocesan Archives Worth Abbey, Crawley Xaverian Brothers, Twickenham Young Christian Workers
Other Christian churches and denominations, interdenominational and ecumenical organisations
Action of Churches Together in Scotland Biblelands British Orthodox Church within The Coptic Orthodox Patriarchate of Alexandria British Transport Christian Fellowship Christian Aid Christian Endeavour Union of Great Britain and Ireland Inc Christian Medical Fellowship Church and Community Work Trust: Avec Resources Churches Together in Britain and Ireland Churches Together in England Creation Science Movement Crosslinks (formerly Bible Churchman’s Missionary Society) Ecclesiological Society (formerly St Paul’s Ecclesiological Society) Ecumenical Patriarchate, Archdiocese of Parishes of Russian Tradition in Western Europe, Deanery of GB and Ireland Eritrean Orthodox Church European Christian Mission Evangelical Protestant Society Faith Mission and the Faith Mission Bible College Greater World Christian Spiritualist Association International Christian College International Miners’ Association Interserve Scotland Interserve England Iona Community Lawyers Christian Fellowship Lay Witness Movement Leprosy Mission International Medical Service Ministries Memo (Message on the Move) National Council of YMCAs Open Air Mission Post Office and Telecommunications Christian Association Trust Ltd Railway Mission Russian Orthodox Church outside Russia Scripture Union England and Wales Soldiers’ and Airmen’s Scripture Readers Association St Michael’s College, Llandaff St Seraphim of Sarov Podvorie and Parish Swedenborg Society The Evangelisation Society (TES) Victoria Institute
World Outreach YMCA Scotland Zambesi Mission
Hindu
Gurjar Hindu Union (GHU) Ltd, Crawley Krishna Yoga Mandir, Enfield Oxford Centre for Hindu Studies Shree Gujarati Hindu Centre
Jewish
South London Liberal Synagogue Anglo Jewish Association Archives of Spanish and Portuguese Jews Congregation London Beis Nadvorne Synagogue Belsize Square Synagogue Beth Shalom Reform Synagogue Birmingham Progressive Synagogue Blackpool Reform Jewish Congregation Board of Deputies of British Jews Bristol Hebrew Congregation Bushey and District Synagogue Czech Memorial Scrolls Trust Ealing Liberal Jewish Congregation Ealing Synagogue Eastbourne Hebrew Congregation Elstree Liberal Jewish Synagogue Exeter Hebrew Congregation Federation of Jewish Services Harrogate Hebrew Congregation Hartley Library, University of Southampton Hull Jewish Archive Jewish Care Scotland Jewish Education Bureau Jewish Memorial Council Jewish Military Museum Jewish Representative Council of Greater Manchester Jewish Vegetarian Society Kahal Chasidim Synagogue, Salford Leicester Hebrew Congregation Liverpool Old Hebrew Congregation Luton Hebrew Congregation Manchester Beth Din Manchester Reform Synagogue Merseyside Jewish Representative Council Montagu Centre, Liberal Judaism Movement for Reform Judaism Newcastle Reform Synagogue North Salford Synagogue Office of the Chief Rabbi Plymouth Hebrew Congregation Romford District Affiliated Synagogue Scottish Jewish Archives Centre Sinai Synagogue, Leeds Society for Jewish Study South London Liberal Synagogue South Tottenham Synagogue Southgate Progressive Synagogue Southport Jewish Representative Council St Albans Masorti Synagogue St John’s Wood Liberal Jewish Synagogue Sumei Hapass, Leeds United Synagogue, Glasgow Welwyn Garden City Synagogue Woodford Liberal Synagogue
Sikh
Medway Towns Gurdwara Sabha Ltd Nanak Sar Sikh Welfare Trust
Other faiths
Baha’i Council for Scotland Council of British Druid Orders Museum of Witchcraft Rastafari Heritage Young Indian Vegetarians (Jains)
Interfaith
Alister Hardy Trust and Religious Experience Research Centre BBC Written Archives Centre Inform – Information Network Focus On Religious Movements International Association for Religious Freedom L’Arche University of Aberdeen Special Libraries and Archives, Library and Historic Collections
Muslim
Association of Muslim Researchers Bilal Mosque, Huddersfield East London Mosque Hastings Mosque Jamia Islamia Mosque and Community Centre, Glasgow Kingston Mosque/Muslim Association Madni Mosque, Blackburn Madrasa Taleem Ul Islam, Glasgow Muslim Community Centre, Woking Wycombe Islamic Mission and Mosque Trust Ltd
Secularist
British Humanist Association, c/o Bishopsgate Institute Center for Inquiry, New York Humanist Reference Library, South Place Ethical Society Rationalist Association, c/o Bishopsgate Institute Appendix II: Organisations not included in the survey
Organisations not normally included in the scope of the Religious Archives Survey
1. Religious bodies whose archives are controlled by ecclesiastical or state legislation and whose place of deposit is therefore known or predictable, or whose archives have already been surveyed including: a) central, diocesan and parish records of the Church of England b) central, diocesan and parish records of the Church in Wales c) central, diocesan and parish records of the Church of Ireland for Northern Ireland d) central, diocesan and parish records of the Episcopal Church in Scotland e) central, presbytery and kirk session records of the Church of Scotland f) central records of the Roman Catholic bishops’ conferences of England, Wales, Scotland and Ireland (for Northern Ireland) and parish records of the Roman Catholic Church.
2. Nonconformist religious bodies whose records above local level are held or deposited in accordance with centralised guidance or arrangements:
Central records of the Methodist, United Reformed Church, Congregational, Unitarian and Baptist churches and of the Society of Friends and Salvation Army; also the central records of the United Reformed Church, Congregational, Calvinistic Methodist (Presbyterian), Baptist and Wesleyan Methodist bodies in Wales and of the Methodist Church in Ireland; the Free Church of Scotland and United Free Church of Scotland.
Methodist circuit records.
3. Records of individual Nonconformist chapels, churches and meetings of the Methodist, United Reformed Church, Unitarian and Baptist churches and the Society of Friends (including individual places of worship of predecessor bodies) which are very numerous and where such material is already well represented in the National Register of Archives.
4. Local records of other major churches with significant structures at regional and national level which have generated records of greater significance at these higher levels.
5. Student religious organisations at individual higher educational establishments as these are unlikely to have long traditions of record-keeping.
6. Records of new religious movements which have no significant administrative centres in the United Kingdom. Appendix III: Tables of results
Response by religion
| Religion | Percentage | |---------------------------|------------| | Buddhist | 4% | | Christian – Anglican | 20% | | Christian – Catholic | 30% | | Christian – Nonconformist | 15% | | Christian – Other | 11% | | Hindu | 1% | | Jewish | 13% | | Muslim | 2% | | Sikh | 0.5% | | Other religion | 1% | | Interfaith | 2% | | Secularist | 1% | Organisations holding archives
| Organisation | Yes | No | |-------------------------------|-----|-----| | Buddhist | 19% | 81% | | Christian – Anglican | 79% | 21% | | Christian – Catholic | 90% | 10% | | Christian – Nonconformist | 76% | 24% | | Christian – Other | 70% | 30% | | Jewish | 62% | 38% | | Muslim | 22% | 78% | | Other religion | 55% | 45% | | Interfaith | 71% | 29% | | Secularist | 100%| 0% | | **Total** | 74% | 26% | Archives which are accruing
| Archives which are accruing | Yes | No | |-----------------------------|------|-----| | Buddhist | 75% | 25% | | Christian – Anglican | 97% | 3% | | Christian – Catholic | 98% | 2% | | Christian – Nonconformist | 93% | 7% | | Christian – Other | 100% | 0% | | Jewish | 91% | 9% | | Muslim | 100% | 0% | | Other religion | 86% | 14% | | Interfaith | 100% | 0% | | Secularist | 100% | 0% | | Total | 96% | 4% | Access in person to the public
| Access in person to the public | Yes | No | |-------------------------------|-----|----| | Buddhist | 75% | 25%| | Christian – Anglican | 56% | 44%| | Christian – Catholic | 47% | 53%| | Christian – Nonconformist | 77% | 23%| | Christian – Other | 48% | 52%| | Jewish | 34% | 66%| | Muslim | 50% | 50%| | Other religion | 29% | 71%| | Interfaith | 20% | 80%| | Secularist | 100%| 0% | | Total | 52% | 48%| Material included in languages other than English
| Material included in languages other than English | Yes | No | |--------------------------------------------------|-----|----| | Buddhist | 50% | 50%| | Christian – Anglican | 37% | 63%| | Christian – Catholic | 82% | 18%| | Christian – Nonconformist | 23% | 77%| | Christian – Other | 32% | 68%| | Jewish | 47% | 53%| | Muslim | 50% | 50%| | Other religion | 86% | 14%| | Interfaith | 60% | 40%| | Secularist | 25% | 75%| | Total | 53% | 47%|
### Administration of the archives
| | Volunteers | Paid administrative staff of your organisation | Professional archivists, librarians or other information managers (paid or unpaid) | |--------------------------|------------|-------------------------------------------------|---------------------------------------------------------------------------------| | Buddhist | 0% | 100% | 0% | | Christian – Anglican | 39% | 31% | 30% | | Christian – Catholic | 42% | 19% | 39% | | Christian – Nonconformist| 46% | 33% | 21% | | Christian – Other | 31% | 54% | 15% | | Jewish | 49% | 41% | 10% | | Muslim | 100% | 0% | 0% | | Other religion | 87.5% | 12.5% | 0% | | Interfaith | 0% | 50% | 50% | | Secularist | 20% | 0% | 80% | | Total | 41% | 31% | 28% | Provision of storage accommodation
| Provision of storage accommodation | Yes | No | |-----------------------------------|------|-----| | Buddhist | 75% | 25% | | Christian – Anglican | 90% | 10% | | Christian – Catholic | 97% | 3% | | Christian – Nonconformist | 89% | 11% | | Christian – Other | 93% | 7% | | Jewish | 81% | 19% | | Muslim | 100% | 0% | | Other religion | 71% | 29% | | Interfaith | 100% | 0% | | Secularist | 100% | 0% | | Total | 91% | 9% | Provision of separate room for consultation of archives
| Provision of separate room for consultation of archives | Yes | No | |--------------------------------------------------------|-----|----| | Buddhist | 33% | 67%| | Christian – Anglican | 46% | 54%| | Christian – Catholic | 58% | 42%| | Christian – Nonconformist | 68% | 32%| | Christian – Other | 24% | 76%| | Jewish | 42% | 58%| | Muslim | 50% | 50%| | Other religion | 43% | 57%| | Interfaith | 80% | 20%| | Secularist | 100%| 0% | | Total | 52% | 48%| Protection of archives against fire, flood and theft
| Protection of archives against fire, flood and theft | All rooms are protected | Most rooms are protected | Some rooms are protected | None of the rooms are protected | |-----------------------------------------------------|-------------------------|--------------------------|--------------------------|--------------------------------| | Buddhist | 75% | 25% | 0% | 0% | | Christian – Anglican | 44% | 10% | 5% | 41% | | Christian – Catholic | 44% | 10% | 8% | 38% | | Christian – Nonconformist | 49% | 11% | 5% | 35% | | Christian – Other | 38% | 10% | 7% | 45% | | Jewish | 45% | 10% | 6% | 39% | | Muslim | 0% | 0% | 0% | 100% | | Other religion | 14% | 0% | 43% | 43% | | Interfaith | 40% | 20% | 20% | 20% | | Secularist | 75% | 0% | 0% | 25% | | Total | 44% | 10% | 7% | 39% | Temperature and humidity levels monitored in storage area
| Religion | Yes | No | |---------------------------|-----|-----| | Buddhist | 50% | 50% | | Christian – Anglican | 22% | 78% | | Christian – Catholic | 31% | 69% | | Christian – Nonconformist | 33% | 67% | | Christian – Other | 19% | 81% | | Jewish | 16% | 84% | | Muslim | 0% | 100%| | Other religion | 14% | 86% | | Interfaith | 60% | 40% | | Secularist | 75% | 25% | | Total | 27% | 73% | Temperature and humidity levels controlled in storage area
| Religion | Yes | No | |---------------------------|-----|-----| | Buddhist | 25% | 75% | | Christian – Anglican | 22% | 78% | | Christian – Catholic | 36% | 64% | | Christian – Nonconformist | 40% | 60% | | Christian – Other | 39% | 61% | | Jewish | 10% | 90% | | Muslim | 0% | 100%| | Other religion | 14% | 86% | | Interfaith | 60% | 40% | | Secularist | 75% | 25% | | Total | 31% | 69% | Archives affected by mould or damp in the last five years
| Religious Group | Yes | No | |--------------------------|-----|-----| | Buddhist | 0% | 100%| | Christian – Anglican | 10% | 90% | | Christian – Catholic | 11% | 89% | | Christian – Nonconformist| 5% | 95% | | Christian – Other | 4% | 96% | | Jewish | 13% | 87% | | Muslim | 0% | 100%| | Other religion | 0% | 100%| | Interfaith | 40% | 60% | | Secularist | 25% | 75% | | Total | 9% | 91% | Expansion space available for archives
| Expansion space for archives | Yes | No | |------------------------------|------|-----| | Buddhist | 25% | 75% | | Christian – Anglican | 69% | 31% | | Christian – Catholic | 62% | 38% | | Christian – Nonconformist | 58% | 42% | | Christian – Other | 57% | 43% | | Jewish | 61% | 39% | | Muslim | 50% | 50% | | Other religion | 29% | 71% | | Interfaith | 60% | 40% | | Secularist | 100% | 0% | | Total | 62% | 38% |
### Cataloguing of archives
| Religion | Wholly uncatalogued? | Partly catalogued? | Fully catalogued? | |-------------------|----------------------|--------------------|-------------------| | Buddhist | 25% | 75% | 0% | | Christian – Anglican | 22.5% | 59.5% | 18% | | Christian – Catholic | 18% | 64% | 18% | | Christian – Nonconformist | 26% | 65% | 9% | | Christian – Other | 31% | 45% | 24% | | Jewish | 45% | 32% | 23% | | Muslim | 100% | 0% | 0% | | Other religion | 29% | 57% | 14% | | Interfaith | 0% | 100% | 0% | | Secularist | 25% | 75% | 0% | | Total | 25% | 58% | 17% |
### Published descriptions of archives
| Published descriptions of archives | Yes | No | |-----------------------------------|------|-----| | Buddhist | 50% | 50% | | Christian – Anglican | 19% | 81% | | Christian – Catholic | 18% | 82% | | Christian – Nonconformist | 25% | 75% | | Christian – Other | 7% | 93% | | Jewish | 21% | 79% | | Muslim | 0% | 100%| | Other religion | 14% | 86% | | Interfaith | 60% | 40% | | Secularist | 0% | 100%| | Total | 19% | 81% | Appendix IV: Religious Archives Survey questionnaire
Religious Archives Survey 2010
The Religious Archives Group and Society of Archivists in association with The National Archives
The purpose of this survey is to identify significant archives, whether institutional records or papers of individuals and families, held by religious organisations (including charities and educational foundations which are inspired by specific faiths) in order to promote future preservation. The survey covers material generated by religions currently practised within the United Kingdom. The project is being carried out with the assistance of a generous grant from the Pilgrim Trust.
Please note: access to your archives will remain entirely a matter for your own discretion and answering this questionnaire will not in any way affect your ownership or control over the archives in your custody.
If you have any queries, or need help in answering the questions, please contact the project’s Resource Discovery Officer:
Claire Muller Resource Discovery Officer Archives Sector Development The National Archives Kew TW9 4DU 02083925330 ext. 2603 [email protected]
Please ask whoever you consider the most appropriate person to fill in the form or to provide you with the necessary information.
In answering this questionnaire, your institution will fall into at least one of three categories:
- No archives have survived. Please respond to Q. 1 only by answering ‘NO’.
- The archives which have survived have been deposited elsewhere with another institution. Please answer Q. 1-2.
- Your institution has retained its archives and historical records. Please answer all questions apart from Q. 2.
If some archives have been deposited and some retained, please answer all questions.
If you find insufficient space in the comment box when answering a question, please continue on a separate piece of paper and attach this when returning the survey.
Your details:
Name and position
Name and address of institution:
Email:
Telephone:
Governing body:
1. Does your institution or organisation hold archives itself (these will usually be over 20 years old as opposed to modern records in current use)?
Please mark ‘x’ in one box
Yes [ ] No [ ]
Note: archives can include any quantity of material relating to all aspects of an organisation, family or individual’s activities including worship, membership, property and financial affairs, as well as governance and legal matters. They can be written on paper, parchment or other materials or exist in the form of photographs, computer discs and films, videos, tape recordings, CDs or in other audio-visual or electronic form.
Please do not include printed book collections or printed periodicals/magazines. While historical records will usually be at least 20 years old, some relating to an anniversary, visits from dignitaries or a special event, may be more recent.
2. If you have deposited such archives with another institution, please give its name and address and, if possible, the nature and covering dates of the archives.
E.g. Berkshire Record Office/ Library of the School of Oriental and African Studies 3. If you have retained archives, please indicate their nature, covering dates, format (paper, digital or other materials) and approximate quantity (linear metres or, for smaller archives, boxes, bundles, files, volumes and other storage units). Please specify in your answer any papers of any prominent individuals, families or organisations which you also hold among your archives.
*e.g.*\
Wessex Mosque financial records, deeds and photographs mid 19th-20th century (100 banker’s boxes)\
Poplar Jewish Relief Committee minutes c. 1910-80 (4 files, 3 volumes)\
Personal papers of Dr Anthony Proudie (1810-1890), Bishop of Barchester
If you have any further information about the papers of prominent individuals or families which remain in private hands, please tick the box below and our Resource Discovery Officer will contact you to discuss whether we can follow this up with the owner or custodian.
Please give details of any important series of statistical data that are among your archives: 4. Do you allow the general public to consult your archives in person?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
5. Are these archives continuing to be added to as material passes out of current use?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
6. Do your archives include material written in languages other than English?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
If yes, please specify below.
*e.g. Latin, French, Welsh, Gaelic, Pali, Arabic, Farsi*
7. Are your archives administered on your premises by:
*Please mark ‘x’ in all boxes that apply*
| Volunteers? | Paid administrative staff of your organisation? | Professional archivists, librarians or other information managers (paid or unpaid)? | |-------------|-----------------------------------------------|-----------------------------------------------| | | | | 8. Is accommodation provided for the archives in terms of:
| Please mark ‘x’ in two boxes | |-----------------------------| | Storage? | | A separate room where they can be consulted? |
Please qualify as necessary:
*e.g. There is a strong room in which the archives are held but they need to be consulted in the archivist’s office/ in the library/ at a desk in the administration manager’s office.*
9. Are all the rooms in which the archives are kept protected against flooding, fire and theft?
| Please mark ‘x’ in one box | |---------------------------| | All rooms are protected | | Most rooms are protected | | Only some rooms are protected | | None of the rooms are protected |
If only some areas are protected, please estimate the proportion of your archives kept in storage areas protected against risk.
*e.g. 50% of areas are protected against such risks but the rest of the archives are kept in unsuitable lock-up garages used as outstores.*
10. Are temperature and relative humidity levels:
| Please mark ‘x’ in all boxes that apply | |----------------------------------------| | Monitored in the storage areas? | | Controlled in the storage areas (e.g. by radiators with thermostats or air conditioning)? | 11. Have your archives been affected by mould or damp in the last five years?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
12. Do you have expansion space to house additions to your archives for the foreseeable future?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
*Please give details:*
*e.g. Our space for archive storage will run out in 1/3/5 or more years’ time.*
13. Are your archives:
*Please mark ‘x’ in one box*
| Wholly un-catalogued? | Partly catalogued? | Fully catalogued? | |----------------------|--------------------|-------------------|
*If your archives are catalogued in some way, please specify the format:*
*e.g. card indexes, word processed or other typed lists, electronic catalogues.*
Please tick the box if you would be prepared to send lists or inventories of your archives to the National Register of Archives at the National Archives in London, or, for material relating to Scotland, the National Register of Archives for Scotland at a later date. *Ticking ‘yes’ will indicate that The National Archives can contact you to arrange the sending of lists.*
| Yes: am happy to be contacted | No: I do not wish to be contacted | |------------------------------|---------------------------------| 14. Are there published descriptions of your archives?
*Please mark ‘x’ in one box*
| Yes | No | |-----|----|
If there is a published guide please give details below.
If not, we would be grateful if you would send us any short article, leaflet or other description which gives details of your archives (see address at end).
15. Please provide any other comments about current major achievements, challenges or development needs for the preservation or accessibility of your archives in the future.
*E.g. ‘We organised a major centenary exhibition last year based on material drawn from our archives’ or ‘we need someone to sort and catalogue the archives’, ‘some of our material has been damaged by damp and needs to be treated’, ‘our buildings are unsuitable for the long-term storage of archives’.* Thank you for answering this questionnaire. Your response is greatly appreciated.
The data will be held by The National Archives on behalf of the project partners including the Society of Archivists and the Religious Archives Group. Unless you cross the box below, summary information supplied in answer to questions 2 and 3 or complete lists supplied in answer to question 13, will be added to the National Register of Archives which researchers may consult. As a public body, The National Archives may have to consider disclosing other information in the responses if a request is received under the Freedom of Information Act but it will only do so after consulting you.
Access to your archives will remain entirely a matter for your own discretion and answering this questionnaire will not in any way affect your ownership or control over the archives in your custody.
I do not want this information added to the National Register of Archives.
If you do cross the box, please indicate if any of the information can be made available:
e.g. Contact details may be made available but not lists of the archives provided in Q.13
Please return to:
Claire Muller Resource Discovery Officer Archives Sector Development The National Archives Kew TW9 4DU Appendix V: Religious Archives Survey covering letter
21 July 2010
Dear Colleague
Religious Archives Survey 2009-10
We are writing to invite your participation in the first comprehensive survey of religious archives ever to be conducted in the United Kingdom. Our constituent countries have a rich and diverse religious history, but the written records tracing its development are at present only partially known. The survey will cover the historical records, in all formats, of all faith communities and of organisations which have their roots in religion. It does not extend to records in current use but covers those which are likely to be of continuing long-term importance.
The survey is a joint initiative of the Religious Archives Group (a voluntary association of individuals responsible for, or users of, religious archives), the Society of Archivists and The National Archives (which maintains the National Register of Archives). It is being substantially funded by the Pilgrim Trust, a national charity.
The survey has been entirely conceived for the 'common good'. It is totally unconnected with any particular political, religious or other viewpoint. The survey is being overseen by an independent project board with an appropriate combination of faith, archival and academic expertise. Its members are listed below.
The survey aims to improve the coverage of religious archives in the National Register of Archives, with a view to promoting the long-term preservation of the records of faith-based communities and organisations. These continue to shape our national heritage and society. The Register already includes several thousand lists of historical records created by religious organisations, but its coverage in this area is uneven and far from complete.
A better knowledge of which religious archives have survived, and where they are located, will benefit the creators and owners of such archives, as well as the wider archival and user communities. In particular, such knowledge should assist the creators and owners to realise the full potential of their archives in advancing the objectives of their own organisations and faith communities. It will also help them to identify opportunities, including collaborative ones, for the improved maintenance of such historical records.
Accordingly, we would be very grateful if you could find time to complete the enclosed questionnaire about those archives you may be responsible for. Any information which you can supply will assist us greatly in mapping out the existence and future needs of such material. Your reply will not affect your ownership or control over your archives in any way.
A stamped addressed envelope is enclosed for returns on paper but there is also an electronic form on the Religious Archives Group’s website for those who would prefer to use it at http://rylibweb.man.ac.uk/rag2/activities/RAGQuestionnaire.html.
If you could return the completed questionnaire within a month of despatch it would be appreciated.
Please contact our Resource Discovery Officer (details below) by email, telephone or post if you need further help in filling out the questionnaire.
Yours sincerely,
Dr Clive Field OBE Chair of the Religious Archives Survey Steering Committee (University of Birmingham)
Committee members: Professor Humayun Ansari OBE (Royal Holloway, University of London) Dr Rachel Cosgrave (Lambeth Palace Library) Dr Norman James (The National Archives) Jenny Moran (Society of Archivists) Andrew Nicoll (Scottish Catholic Archives) Dr Michael Pearson (The National Library of Wales) Karen Robson (Hartley Library, University of Southampton) Rosemary Seton (Religious Archives Group)
Claire Muller (Resource Discovery Officer) Archives Sector Development The National Archives Ruskin Avenue Kew, Richmond TW9 4DU
Email: [email protected] Telephone: 020 8392 5330 x2603.
Unfortunately, we are currently unable to provide the questionnaire in languages other than English. Please notify us if you cannot complete this questionnaire in English. Appendix VI: Survey of personal papers: survey letter and form
29 May 2010
Dear
The Religious Archives Group, in association with the Society of Archivists, and The National Archives, is currently carrying out a comprehensive survey of religious archives in the United Kingdom with funding from the Pilgrim Trust, a national charity. A description of the project is attached. However, we are conscious that much of the record of religious life in this country is captured not in the official archives of faith organisations, but in the personal papers of religious leaders and other prominent members of faiths practised in the different parts of the UK.
We are therefore writing to ask if you have considered the issue of the future disposition of any personal papers which you have retained. These may be letters written to you, personal diaries, unpublished writings or papers accumulated in the course of your own activities, together with photographs, recordings and other working papers remaining in your possession and ownership (rather than official papers relating to work on behalf of religious bodies or organisations and retained by them as part of their current records or archives). It would also be beneficial if you would tell us whether you would find it helpful if more general guidance was provided about the significance and preservation of religious figures’ papers and the options for their future care. This could be provided under the auspices of the Religious Archives Group or your own religious tradition.
We have no wish to interfere in any way with your personal property, affairs or the disposition of papers which you may currently retain. Nor are we acting as collecting agents for individual record offices and other institutions which can provide permanent homes for such papers. However, we do wish to encourage and promote the safe preservation of such material which is likely to form an important body of sources for studying the religious history of the United Kingdom in the future. It is also quite understood that such papers will normally be closed to research while they remain in your custody, or if retained by your family or executors in the future, and that only when deposited with a record office, specialist library or other institution and specifically opened for research are they likely to become more widely available for study.
If you would be kind enough to spare a few minutes to fill in the boxes on the enclosed form, this would greatly assist us in shaping our future guidance and advice in this area. The information will be held at The National Archives in accordance with the principles of the Data Protection Act 1998, which will safeguard your confidentiality. The information will be held for the purposes of assessing and promoting the preservation of the UK’s heritage in the field of religious archives and will not be divulged to third parties beyond the Religious Archives Group, its survey steering committee and The National Archives without first consulting you.
Yours sincerely
Dr Clive Field OBE, Chair of the Religious Archives Group Steering Committee (University of Birmingham)
Committee members: Professor Humayun Ansari OBE (Royal Holloway, University of London) Dr Rachel Cosgrave (Lambeth Palace Library) Dr Norman James (The National Archives) Jenny Moran (Society of Archivists) Andrew Nicoll (Scottish Catholic Archives) Dr Michael Pearson (The National Library of Wales) Karen Robson (Hartley Library, University of Southampton) Rosemary Seton (Religious Archives Group) RELIGIOUS ARCHIVES SURVEY 2010: PERSONAL PAPERS
Please tick the following boxes where applicable and return to the following in the pre-paid envelope provided:
Philip Gale Religious Archives Survey Project Private Archives Team c/o Archives Sector Development The National Archives Kew Richmond TW9 4DU
Your name (block capitals please):
I have already made, or intend to make [delete as appropriate], arrangements for the preservation of my personal papers.
☐
I would welcome further general advice from the Religious Archives Group on its website about the preservation and care of personal papers.
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I would welcome general advice from an appropriate official body within my own religious community instead of/ in addition to [delete as appropriate] guidance in published form from the Religious Archives Group about the preservation and care of personal papers.
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I would not welcome any further initiatives in respect of personal papers.
☐ Any additional comments or information? Please add below.
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Thank you very much for your assistance. A reply-paid envelope is enclosed for your convenience.
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c70c3f703444368b908010325fa4bd656ca0e47c | Appendix G: Epilepsy12 clinical audit results Epilepsy12
National Clinical Audit of Seizures and Epilepsies for Children and Young People
Combined organisational and clinical audits: Report for England and Wales, Round 3 Cohort 1 (2018-19)
The Healthcare Quality Improvement Partnership (HQIP) is led by a consortium of the Academy of Medical Royal Colleges, the Royal College of Nursing and National Voices. Its aim is to promote quality improvement in patient outcomes, and in particular, to increase the impact that clinical audit, outcome review programmes and registries have on healthcare quality in England and Wales. HQIP holds the contract to commission, manage and develop the National Clinical Audit and Patient Outcomes Programme (NCAPOP), comprising around 40 projects covering care provided to people with a wide range of medical, surgical and mental health conditions. The programme is funded by NHS England, the Welsh Government and, with some individual projects, other devolved administrations and crown dependencies.
www.hqip.org.uk/national-programmes
© 2020 Healthcare Quality Improvement Partnership (HQIP)
Published by RCPCH September 2020.
The Royal College of Paediatrics and Child Health is a registered charity in England and Wales (1057744) and in Scotland (SCO38299). Appendices
The Epilepsy12 combined report for 2020 includes a description of key findings, recommendations, quality improvement activities, and patient involvement in Epilepsy12. It is available to download from Epilepsy12.
Appendix: Full Epilepsy12 organisational audit results for Round 3, includes the publication of the structure of services and available workforce for paediatric epilepsy service staff within Health Boards and Trusts with England and Wales. It is available to download from Epilepsy12.
Appendix G: Full Epilepsy12 clinical audit results for Round 3, Cohort 1 5 Appendix H: List of clinical data figures & tables 87 Appendix I: Data completeness 92 Appendix J: Participating Health Boards and Trusts by OPEN UK region 95 Appendix K: Glossary of terms and abbreviations 100 The 16 OPEN UK Regional Paediatric Epilepsy Networks are named in the following table. The abbreviated regional network names appear in the regional network results of both the clinical and organisational audits in this report.
| OPEN UK Regional Paediatric Epilepsy Network | Regional Network full name | |---------------------------------------------|-----------------------------| | BRPNF | Birmingham Regional Paediatric Neurology Forum | | CEWT | Children's Epilepsy Workstream in Trent | | EPEN | Eastern Paediatric Epilepsy Network | | EPIC | Mersey and North Wales network 'Epilepsy in Childhood' interest group | | NTPEN | North Thames Paediatric Epilepsy Network | | NWEIG | North West Children and Young People's Epilepsy Interest Group | | NI | Northern Ireland epilepsy services | | ORENG | Oxford Region Epilepsy Interest Group | | PENNEC | Paediatric Epilepsy Network for the North East and Cumbria | | SETPEG | South East Thames Paediatric Epilepsy Group | | SPEN | Scottish Paediatric Epilepsy Network | | SWEP | South Wales Epilepsy Forum | | SWIPE | South West Interest Group Paediatric Epilepsy | | SWTPEG | South West Thames Paediatric Epilepsy Group | | TEN | Trent Epilepsy Network | | WPNN | Wessex Paediatric Neurosciences Network | | YPEN | Yorkshire Paediatric Neurology Network | Appendix D: Full Epilepsy12 clinical audit results for Round 3, Cohort 1
Participation and case ascertainment
Participation
Table 47 provides a breakdown on Epilepsy12 Round 3 participation by Paediatric Epilepsy Networks and by country.
- There are 149 registered Health Boards and Trusts in Round 3 of Epilepsy12.
- 113 out of 149 (75.8%) Health Boards and Trusts submitted a record of the first year of care clinical data for one or more children and young people in cohort 1.
Table 47: Participation in Round 3 of Epilepsy12.
| Country/network | Number of registered Health Boards and Trusts | Number of Health Boards and Trusts that have submitted clinical audit data | |-----------------|-----------------------------------------------|--------------------------------------------------------------------------| | England & Wales | 149 | 75.8% (113/149) | | England | 143 | 76.2% (109/143) | | Wales | 6 | 66.7% (4/6) | | BRPNF | 15 | 73.3% (11/15) | | CEWT | 6 | 100% (6/6) | | EPEN | 15 | 66.7% (10/15) | | EPIC | 9 | 100% (9/9) | | NTPEN | 17 | 70.6% (12/17) | | NWEIG | 13 | 84.6% (11/13) | | ORENG | 7 | 100% (7/7) | | PENNEC | 9 | 77.8% (7/9) | | SETPEG | 11 | 45.5% (5/11) | | SWEP | 5 | 60.0% (3/5) | | SWIPE | 11 | 54.5% (6/11) | | SWTPEG | 7 | 71.4% (5/7) | | TEN | 6 | 100% (6/6) | | WPNN | 9 | 77.8% (7/9) | | YPEN | 9 | 88.9% (8/9) | Case ascertainment
Table 48 shows between 5th July 2018 and 8th January 2020, a total of 10,649 children and young people were registered via an EEG service and a further 3,954 registered by the Health Boards and Trusts.
- By download date (8th January 2020) 10,954 children and young people were verified for inclusion in Round 3 and beyond cohorts.
- In addition to the registered children and young people, 1,280 children and young people were excluded at verification stage because they did not meet the audit inclusion criteria,
- 22 families had requested their children to be opted out of the audit post verification stage.
Table 48: Shows the flow of children and young people through the data capture system i.e. entry via EEG or Health Boards and Trusts through to inclusion in Round 3 cohorts.
| Country/network | No. registered by EEG | No. registered by Health Boards and Trusts | No. verified by Health Boards and Trusts | No. not yet verified by Health Boards and Trusts | No. opt out | No. excluded | |-----------------|-----------------------|-------------------------------------------|------------------------------------------|-----------------------------------------------|-------------|--------------| | England & Wales| 10649 | 3942 | 10954 | 3615 | 22 | 1280 | | England | 10228 | 3823 | 10542 | 3488 | 21 | 1177 | | Wales | 421 | 119 | 412 | 127 | 1 | 103 | | BRPNF | 919 | 299 | 967 | 251 | 0 | 154 | | CEWT | 828 | 125 | 743 | 206 | 4 | 60 | | EPEN | 774 | 273 | 648 | 399 | 0 | 144 | | EPIC | 98 | 455 | 508 | 44 | 1 | 68 | | NTPEN | 1602 | 219 | 1189 | 631 | 1 | 188 | | NWEIG | 728 | 296 | 773 | 251 | 0 | 124 | | ORENG | 1278 | 225 | 993 | 510 | 0 | 114 | | PENNEC | 536 | 434 | 841 | 129 | 0 | 35 | | SETPEG | 316 | 275 | 521 | 70 | 0 | 59 | | SWEP | 324 | 100 | 337 | 87 | 0 | 75 | | SWIPE | 887 | 288 | 936 | 231 | 8 | 105 | | SWTPEG | 457 | 350 | 658 | 142 | 7 | 35 | | TEN | 624 | 125 | 592 | 157 | 0 | 32 | | WPNN | 795 | 106 | 483 | 417 | 1 | 65 | | YPEN | 483 | 372 | 765 | 90 | 0 | 22 | Table 49 (below) shows a comparison of the details of the number of children and young people that were assessed as eligible for Round 2 and Round 3 audits. The total number of children and young people allocated to the cohort was higher in Round 3 (4684) than Round 2 (3350) in England and Wales combined.
Of the 4684 children and young people who met the audit criteria in Round 3 and were verified and allocated to cohort 1, 70.8% were successfully entered on the data capture system. The data completeness in Round 3 was lower (70.8%) compared to Round 2 (91.7%).
Table 49: Number of children and young people registered as eligible for the audit
| Description of eligible criteria | Round 2 | Round 3 | |----------------------------------|---------|---------| | | England and Wales | England | Wales | England and Wales | England | Wales | | Children registered (by EEG services and the HBTs) | 12973 | 12391 | 582 | 14591 | 14051 | 540 | | Children excluded (did not meet audit inclusion criteria) | 8832 | 8479 | 353 | 1280 | 1177 | 103 | | Children allocated to cohort (for Round 3 the data refers to only cohort 1) | 3350 | 3174 | 176 | 4684 | 4490 | 194 | | Children allocated to cohort who had their first year of care data successfully entered on data capture system | 3072 | 2907 | 165 | 3318 | 3195 | 123 | | Children allocated to cohort but their first year of care data was not successfully entered on data capture system | 272 | 261 | 11 | 1366 | 1295 | 71 | | Data completeness | 91.7% (3072/3350) | 91.6% (2907/3174) | 93.8% (165/176) | 70.8% (3318/4684) | 71.1% (3195/4490) | 63.4% (123/194) | Health Board and Trust ascertainment
Figure 30 shows the proportion of children and young people who were registered and verified on the data capture system by each of the Health Boards and Trusts by the download date (8th January 2020). One quarter of the Health Boards and Trusts verified all the children and young people that were registered as eligible for the audit. Unverified children and young people includes children who may be allocated to cohort 1, 2 or 3 at verification stage, or who may be excluded.
Figure 30: Percentage of children and young people verified by Health Boards and Trusts in Round 3.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0%. Health Board and Trust data completeness
Figure 31 shows the proportion of children and young people allocated to Round 3, cohort 1, that had their first year of care form submitted and locked on the data capture system, by each of the Health Boards and Trusts by the download date (8th January 2020). Nationally nearly half of the registered Health Board or Trust submitted and locked the first year of care form for all the children allocated to cohort 1 in Round 3.
Figure 31: The percentage of children and young people within cohort 1 with their first year of care form submitted and locked.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0%. Description of cohort 1
Age and sex
Figure 32 shows the number of children and young people in cohort 1 by their age at the time of their first paediatric assessment. The children and young people’s ages are given in whole years, giving their age at their last birthday. The largest age groups in cohort 1 were younger children; infants below one year of age, and children aged one or two years old. The number of children and young people in cohort 1 is highest in infancy and decreases among older year groups, in particular for young people aged 16 or 17. This is likely to reflect some of the older young people in our cohort age range being assessed within adult services. There were more boys than girls in each year group until age 14.
Figure 32: Numbers of children and young people included in cohort 1 by age in years at first paediatric assessment and gender. (This figure excludes 6 children with unknown gender). Figure 33 shows the number of children and young people in cohort 1 who were less than two years of age at first paediatric assessment. This is broken down by age in months and gender. The most common time for children below two years of age to have a first paediatric assessment was in either their first month of life (81) or at seven-months old (59).
Table 50 shows the proportion of children and young people in different age groups, by country or by paediatric epilepsy network area. In cohort 1:
- 25.9% of the children and young people were aged between one month and two years,
- 21.8% were aged between two and four years,
- 32.7% were aged between five and eleven years,
- 19.6% were aged over twelve years of age. Table 50: Number of children and young people in cohort 1 by country, network and age-group.
| Country/network | % \<2 years | % 2 - 4 years | % 5 - 11 years | % >=12 years | |-----------------|------------|---------------|----------------|-------------| | England & Wales (N=3318) | 25.9% (858/3318) | 21.8% (723/3318) | 32.7% (1086/3318) | 19.6% (651/3318) | | England (N=3195) | 26% (832/3195) | 21.6% (690/3195) | 32.7% (1046/3195) | 19.6% (627/3195) | | Wales (N=123) | 21.1% (26/123) | 26.8% (33/123) | 32.5% (40/123) | 19.5% (24/123) | | BRPNF (N=248) | 23.8% (59/248) | 17.7% (44/248) | 33.5% (83/248) | 25.0% (62/248) | | CEWT (N=281) | 27.4% (77/281) | 16.7% (47/281) | 35.2% (99/281) | 20.6% (58/281) | | EPEN (N=210) | 23.8% (50/210) | 23.3% (49/210) | 38.1% (80/210) | 14.8% (31/210) | | EPIC (N=207) | 24.2% (50/207) | 28.5% (59/207) | 32.4% (67/207) | 15.0% (31/207) | | NTPEN (N=298) | 27.9% (83/298) | 18.1% (54/298) | 35.6% (106/298) | 18.5% (55/298) | | NWEIG (N=222) | 25.2% (56/222) | 21.6% (48/222) | 36.0% (80/222) | 17.1% (38/222) | | ORENG (N=299) | 22.4% (67/299) | 20.7% (62/299) | 35.1% (105/299) | 21.7% (65/299) | | PENNEC (N=237) | 27.4% (65/237) | 25.3% (60/237) | 29.1% (69/237) | 18.1% (43/237) | | SETPEG (N=52) | 30.8% (16/52) | 17.3% (9/52) | 23.1% (12/52) | 28.8% (15/52) | | SWEP (N=112) | 21.4% (24/112) | 26.8% (30/112) | 30.4% (34/112) | 21.4% (24/112) | | SWIPE (N=272) | 26.1% (71/272) | 27.2% (74/272) | 26.8% (73/272) | 19.9% (54/272) | | SWTPEG (N=186) | 29.0% (54/186) | 19.9% (37/186) | 31.7% (59/186) | 19.4% (36/186) | | TEN (N=222) | 28.8% (64/222) | 23.0% (51/222) | 29.7% (66/222) | 18.5% (41/222) | | WPNN (N=152) | 28.9% (44/152) | 24.3% (37/152) | 30.3% (46/152) | 16.4% (25/152) | | YPEN (N=320) | 24.4% (78/320) | 19.4% (62/320) | 33.4% (107/320) | 22.8% (73/320) | Table 51 (below) shows the median age of children included in Round 3, cohort 1, was 5 years old. 45.1% of the children were female. There are no clear differences in demographics between England and Wales. The sample window for Round 1, Round 2 and Round 3, cohort 1, was; 6 months, 4 months and 4.5 months respectively, hence the difference in cohort sizes.
Table 51: Demographic characteristics of children included in Round 1, 2 and 3 of Epilepsy12.
| Median age | Round 1 | Round 2 | Round 3 | |------------|---------|---------|---------| | | UK | England | Wales | UK | England | Wales | UK | England | Wales | | N | 4310 | 4085 | 225 | 3072 | 2907 | 165 | 3318 | 3195 | 123 | | % Female | 46.0% | 46.0% | 49.0% | 45.0% | 45.0% | 45.0% | 45.1% | 45.0% | 48.0% | | Median age (years) | + 6.4 | 7.5 | + 5.3 | 5.9 | 5.4 | 5.4 | 5.3 | | 25th centile (years) | + 2.2 | 3.1 | + 2 | 2.5 | 1.8 | 1.8 | 2.3 | | 75th centile (years) | + 10.7 | 12.1 | + 10.2 | 10.3 | 10.6 | 10.6 | 10.7 | | Infants (1 month to < 2 years) | 22.7% | 23.0% | 18.0% | 24.7% | 25.0% | 21.0% | 25.9% | 26.0% | 21.1% | | Pre-school (2-4 years) | 19.8% | 20.0% | 17.0% | 23.8% | 24.0% | 21.0% | 21.8% | 21.6% | 26.8% | | School (5-11 years) | 37.1% | 37.0% | 39.0% | 34.3% | 34.0% | 39.0% | 32.7% | 32.7% | 32.5% | | Young people (12-15 years) | 19.3% | 19.0% | 25.0% | 17.1% | 17.0% | 19.0% | 17.7% | 17.7% | 17.1% |
- UK median and centile values were not available for comparison for this metric
Figure 34 shows the overall proportions of the children by age groups are similar in Round 1, Round 2 and Round 3.
Figure 34: Comparison of the proportion of children and young people by age group in Round 1, Round 2 and Round 3. Deprivation
Table 52 shows the breakdown of children and young people in Epilepsy12 cohort 1 by deprivation quintile. This was derived by matching home postcodes to the English (IMD, 2019) and Welsh (WIMD, 2019) indices of multiple deprivation data. A small proportion 32 (1.0%) of children and young people could not be allocated to a deprivation quintile, because their postcodes had no matching lower super output area (LSOA) in the deprivation datasets. Over half of the children and young people in cohort 1 lived in neighbourhoods that are among the most deprived areas of England and Wales, (50.2% in the top two most deprived quintiles).
Table 52: Percentage and number of children and young people in cohort 1 by deprivation by country and network.
| Country/network | Most deprived | Second most deprived | Third least deprived | Second least deprived | Least deprived | |-----------------|---------------|----------------------|----------------------|-----------------------|---------------| | England & Wales (N=3286) | 28.2% (926/3286) | 22% (724/3286) | 18.8% (619/3286) | 17.3% (567/3286) | 13.7% (450/3286) | | England (N=3166) | 28.2% (892/3166) | 22.0% (698/3166) | 18.7% (591/3166) | 17.2% (545/3166) | 13.9% (440/3166) | | Wales (N=120) | 28.3% (34/120) | 21.7% (26/120) | 23.3% (28/120) | 18.3% (22/120) | 8.3% (10/120) | | BRPNF (N=247) | 37.7% (93/247) | 18.6% (46/247) | 17.4% (43/247) | 15.4% (38/247) | 10.9% (27/247) | | CEWT (N=281) | 27.8% (78/281) | 22.1% (62/281) | 18.9% (53/281) | 17.1% (48/281) | 14.2% (40/281) | | EPEN (N=209) | 15.3% (32/209) | 15.8% (33/209) | 25.4% (53/209) | 24.9% (52/209) | 18.7% (39/209) | | EPIC (N=203) | 43.3% (88/203) | 17.2% (35/203) | 16.7% (34/203) | 16.3% (33/203) | 6.4% (13/203) | | NTPEN (N=295) | 25.4% (75/295) | 31.9% (94/295) | 19.7% (58/295) | 13.2% (39/295) | 9.8% (29/295) | | NWEIG (N=221) | 48.4% (107/221) | 20.8% (46/221) | 10.9% (24/221) | 12.7% (28/221) | 7.2% (16/221) | | ORENG (N=292) | 15.1% (44/292) | 16.8% (49/292) | 16.1% (47/292) | 27.1% (79/292) | 25% (73/292) | | PENNEC (N=234) | 44.4% (104/234) | 24.4% (57/234) | 11.5% (27/234) | 13.2% (31/234) | 6.4% (15/234) | | SETPEG (N=52) | 19.2% (10/52) | 34.6% (18/52) | 21.2% (11/52) | 17.3% (9/52) | 7.7% (4/52) | | SWEP (N=109) | 30.3% (33/109) | 22.0% (24/109) | 23.9% (26/109) | 16.5% (18/109) | 7.3% (8/109) | | SWIPE (N=271) | 12.9% (35/271) | 26.6% (72/271) | 30.3% (82/271) | 17.3% (47/271) | 12.9% (35/271) | | SWTPEG (N=184) | 1.1% (2/184) | 19.6% (36/184) | 15.8% (29/184) | 25% (46/184) | 38.6% (71/184) | | TEN (N=221) | 42.1% (93/221) | 25.3% (56/221) | 15.8% (35/221) | 8.6% (19/221) | 8.1% (18/221) | | WPNN (N=151) | 10.6% (16/151) | 21.9% (33/151) | 33.1% (50/151) | 17.9% (27/151) | 16.6% (25/151) | | YPEN (N=316) | 36.7% (116/316) | 19.9% (63/316) | 14.9% (47/316) | 16.8% (53/316) | 11.7% (37/316) | Figure 35 shows that the proportion of children and young people in cohort 1 living in the most deprived quintiles was significantly higher than the proportion living in the least deprived quintiles of England and Wales.
Figure 36 shows the deprivation indices for children and young people’s home addresses for each of the regional paediatric epilepsy networks. This shows that there are considerable differences between networks, and also variation from the overall picture for England and Wales.
Figure 35: Percentage of children and young people in cohort 1 by deprivation quintile in England and Wales combined. Figure 36 shows a comparison of the proportion of children and young people by deprivation quintile and by country/network.
| Country/Network | Most deprived | Second most deprived | Third least deprived | Second least deprived | Least deprived | |-----------------|---------------|----------------------|----------------------|-----------------------|---------------| | ENG&WAL | 28.9% | 22.0% | 18.8% | 17.3% | 13.7% | | ENG | 28.2% | 22.0% | 18.7% | 17.2% | 13.9% | | WAL | 28.3% | 21.7% | 23.3% | 18.3% | 8.3% | | BRPNF | 37.7% | 18.6% | 17.4% | 15.4% | 10.9% | | CEWT | 27.8% | 22.1% | 18.9% | 17.1% | 14.2% | | EPEN | 15.3% | 15.8% | 25.4% | 24.9% | 18.7% | | EPIC | 43.3% | 17.2% | 16.7% | 16.3% | 6.4% | | NTPEN | 25.4% | 31.9% | 19.7% | 13.2% | 9.8% | | NWEIG | 48.4% | 20.8% | 10.9% | 12.7% | 7.2% | | ORENG | 15.1% | 16.8% | 16.1% | 27.1% | 25.0% | | PENNEC | 44.4% | 24.4% | 11.5% | 13.2% | 6.4% | | SETPEG | 19.2% | 34.6% | 21.2% | 17.3% | 7.7% | | SWEP | 30.3% | 22.0% | 23.9% | 16.5% | 7.3% | | SWIPE | 12.9% | 26.6% | 30.3% | 17.3% | 12.9% | | SWTPEG | 19.6% | 15.8% | 25.0% | 38.6% | 11.1% | | TEN | 42.1% | 25.3% | 15.8% | 8.6% | 8.1% | | WPNN | 10.6% | 21.9% | 33.1% | 17.9% | 16.6% | | YPEN | 36.7% | 19.9% | 14.9% | 16.8% | 11.7% |
Figure 36: Percentage of children and young people in cohort 1 by deprivation by country/network. Diagnostic status
Prior experience of seizures
Table 53 shows 2.7% (91/3318) of children and young people in Round 3, cohort 1, had prior experience of neonatal seizures.
8.4% (279/3318) had prior experience of febrile seizures. 6.2% (205/3318) had prior experience of acute symptomatic seizures. Most children and young people did not have any prior experience of neonatal, febrile or acute symptomatic seizures, (Figure 38).
Table 53: Prior experience of seizures in children and young people in cohort 1 in England and Wales.
| Description of neonatal seizures | % with prior seizures | % without prior seizures | % Uncertain about prior seizures | |----------------------------------|-----------------------|--------------------------|---------------------------------| | Neonatal seizure(s) | 2.7% (91/3318) | 85.3% (2831/3318) | 11.9% (396/3318) | | Febrile seizure(s) | 8.4% (279/3318) | 80.6% (2674/3318) | 11.0% (365/3318) | | Acute symptomatic seizure(s) | 6.2% (205/3318) | 83.4% (2767/3318) | 10.4% (346/3318) | Table 54 shows the diagnostic status of children and young people in cohort 1 in the first year of care. In England and Wales combined, 32.3% (1073/3318), children and young people were diagnosed with epilepsy because they had two or more epileptic episodes more than 24 hours apart. 1.2% (39/3318) of children and young people were diagnosed with epilepsy for other reasons. This means, in total, 33.5% (1112) of children were diagnosed with epilepsy in cohort 1.
For children and young people who had recorded seizure episodes, but were not diagnosed with epilepsy, there were:
- 38.4% (1275/3318) who had non-epileptic episodes only,
- 3.2% (107/3318) who had a single epileptic episode,
- 1.4% (46/3318) who had a cluster of epileptic episodes within 24 hours,
- For 23.4% (778/3318) children and young people, there was uncertainty whether the episodes were epileptic or not.
Figure 38 shows the percentages of children and young people in cohort 1 by diagnostic status in England and Wales. Table 54: Diagnostic status at first year of care by country and network.
| Country/ network | Epilepsy: 2 or more epileptic episodes more than 24 hours apart | Epilepsy: other reason | Not epilepsy: single epileptic episode | Not epilepsy: cluster of epileptic episodes within 24 hours | Non-epileptic episode(s) | Uncertain episodes | |------------------|---------------------------------------------------------------|------------------------|---------------------------------------|----------------------------------------------------------|--------------------------|-------------------| | England & Wales (N=3318) | 32.3% (1073/3318) | 1.2% (39/3318) | 3.2% (107/3318) | 1.4% (46/3318) | 38.4% (1275/3318) | 23.4% (776/3318) | | England (N=3195) | 31.7% (1013/3195) | 1.2% (38/3195) | 3.3% (105/3195) | 1.4% (46/3195) | 39.1% (1248/3195) | 23.3% (745/3195) | | Wales (N=123) | 48.8% (60/123) | * | * | 0.0% (0/123) | 22.0% (27/123) | 26.8% (33/123) | | BRPNF (N=248) | 36.3% (90/248) | * | 2.4% (6/248) | * | 36.3% (90/248) | 22.6% (56/248) | | CEWT (N=281) | 32.4% (91/281) | * | 4.3% (12/281) | * | 42.7% (120/281) | 16.4% (46/281) | | EPEN (N=210) | 30.5% (64/210) | 5.2% (11/210) | * | * | 24.3% (51/210) | 35.7% (75/210) | | EPIC (N=207) | 53.1% (110/207) | * | 2.4% (5/207) | * | 28.5% (59/207) | 14.5% (30/207) | | NTPEN (N=298) | 32.2% (96/298) | * | 4.4% (13/298) | * | 31.2% (93/298) | 30.2% (90/298) | | NWEIG (N=222) | 30.2% (67/222) | * | 4.1% (9/222) | * | 41.9% (93/222) | 23.4% (52/222) | | ORENG (N=299) | 29.1% (87/299) | * | 4.0% (12/299) | * | 37.8% (113/299) | 25.8% (77/299) | | PENNEC (N=237) | 26.6% (63/237) | * | 2.5% (6/237) | * | 43% (102/237) | 25.7% (61/237) | | SETPEG (N=52) | 36.5% (19/52) | * | 0.0% (0/52) | * | 19.2% (10/52) | 34.6% (18/52) | | SWEP (N=112) | 44.6% (50/112) | * | * | 0.0% (0/112) | 24.1% (27/112) | 28.6% (32/112) | | SWIPE (N=272) | 26.1% (71/272) | * | 1.8% (5/272) | * | 50.4% (137/272) | 20.6% (56/272) | | SWTPEG (N=186) | 34.4% (64/186) | * | 5.9% (11/186) | * | 45.2% (84/186) | 12.4% (23/186) | | TEN (N=222) | 23.4% (52/222) | * | 2.7% (6/222) | * | 47.3% (105/222) | 24.8% (55/222) | | WPNN (N=152) | 26.3% (40/152) | * | * | * | 44.1% (67/152) | 25.0% (38/152) | | YPEN (N=320) | 34.1% (109/320) | * | 3.1% (10/320) | * | 38.8% (124/320) | 21.6% (69/320) |
- In accordance with information governance rules, data based on a number less than five has been masked Figure 38: Percentage of children and young people in Cohort 1 by diagnostic status at first year of care, in England and Wales. Table 55 shows the diagnostic status of children and young people in cohort 1 in the first paediatric assessment. The number of children where there remains uncertainty as to whether the episodes were epileptic or not, reduced from 35.8% (1172) in the first paediatric assessment, to 23.4% (778) in the first year of care, (Figure 39).
Table 55: Diagnostic status at first paediatric assessment by country and network.
| Country/ network | Epilepsy: 2 or more epileptic episodes more than 24 hours apart | Epilepsy: other reason | Not epilepsy: single epileptic episode | Not epilepsy: cluster of epileptic episodes within 24 hours | Non-epileptic episode (s) | Uncertain episodes | |------------------|---------------------------------------------------------------|------------------------|---------------------------------------|----------------------------------------------------------|--------------------------|-------------------| | England & Wales (N=3318) | 29.9% (992/3318) | 1.5% (49/3318) | 4.2% (141/3318) | 1.8% (61/3318) | 27.2% (903/3318) | 35.3% (1172/3318) | | England (N=3195) | 29.2% (932/3195) | 1.5% (48/3195) | 4.3% (137/3195) | 1.9% (61/3195) | 27.4% (877/3195) | 35.7% (1140/3195) | | Wales (N=123) | 48.8% (60/123) | * | * | 0.0% (0/123) | 21.1% (26/123) | 26.0% (32/123) | | BRPNF (N=248) | 31.9% (79/248) | * | 4.8% (12/248) | * | 28.6% (71/248) | 29.8% (74/248) | | CEWT (N=281) | 25.6% (72/281) | * | * | 3.6% (10/281) | 29.9% (84/281) | 37.7% (106/281) | | EPEN (N=210) | 32.4% (68/210) | 5.2% (11/210) | * | * | 24.8% (52/210) | 33.3% (70/210) | | EPIC (N=207) | 49.8% (103/207) | * | 2.9% (6/207) | * | 16.4% (34/207) | 27.5% (57/207) | | NTPEN (N=298) | 29.5% (88/298) | * | 7.4% (22/298) | * | 22.8% (68/298) | 38.3% (114/298) | | NWEIG (N=222) | 23.9% (53/222) | * | * | * | 23% (51/222) | 49.1% (109/222) | | ORENG (N=299) | 26.4% (79/299) | 2.0% (6/299) | 7.4% (22/299) | 2.0% (6/299) | 32.4% (97/299) | 29.8% (89/299) | | PENNEC (N=237) | 26.2% (62/237) | * | 3.8% (9/237) | * | 27.8% (66/237) | 40.1% (95/237) | | SETPEG (N=52) | 36.5% (19/52) | * | * | * | 11.5% (6/52) | 40.4% (21/52) | | SWEP (N=112) | 45.5% (51/112) | * | * | 0.0% (0/112) | 23.2% (26/112) | 27.7% (31/112) | | SWIPE (N=272) | 25.7% (70/272) | * | 1.8% (5/272) | * | 34.2% (93/272) | 36.8% (100/272) | | SWTPEG (N=186) | 32.3% (60/186) | * | 10.2% (19/186) | * | 30.6% (57/186) | 25.3% (47/186) | | TEN (N=222) | 25.2% (56/222) | * | 5.0% (11/222) | * | 36.5% (81/222) | 28.8% (64/222) | | WPNN (N=152) | 27.6% (42/152) | * | 4.6% (7/152) | * | 36.2% (55/152) | 29.6% (45/152) | | YPEN (N=320) | 28.1% (90/320) | * | * | 2.8% (9/320) | 19.4% (62/320) | 46.9% (150/320) |
- In accordance with information governance rules, data based on a number less than five has been masked Figure 39: Percentage of children and young people by diagnostic status in first paediatric assessment and first year of care in England and Wales, in Round 3. Figure 40 shows the proportion of children that had uncertain episodes at 12 months and after the first paediatric assessment. There was a higher proportion of children and young people with non-epileptic episode(s) at first paediatric assessment (27.2%), compared to Round 1 and Round 2 (18.0% and 15.0% respectively).
There were a higher proportion of children and young people who had episodes that were considered uncertain after the first year of care in Round 3 (23.4%), compared to Round 1 and Round 2 (14.0% and 9.0% respectively).
The proportion of children and young people diagnosed with epilepsy in the 12 months after their first paediatric assessment is comparable in across Round 1, Round 2 and Round 3 (36.0%, 35.0% and 33.5% respectively).
Figure 40: Diagnosis at first assessment and one year after first assessment in Round 1, Round 2, Round 3. Non-epileptic episodes
Table 56 shows a description of the non-epileptic episodes recorded for children in cohort 1.
Table 56: Description of non-epileptic episodes in children in cohort 1 at one year after first assessment in England and Wales.
| Description of non-epileptic episodes | No. of children and young people in cohort 1 | % of total sample | |---------------------------------------|---------------------------------------------|------------------| | Syncope and Anoxic Seizures | 215 | 6.5% | | Behavioural, Psychological and Psychiatric Disorders | 541 | 16.3% | | Sleep Related Conditions | 77 | 2.3% | | Paroxysmal Movement Disorders | 103 | 3.1% | | Migraine Associated Disorders | 22 | 0.7% | | Miscellaneous Events | 71 | 2.1% | | Other | 535 | 16.1% |
Figure 41: Percentage of children and young people by description of non-epileptic episode Initial referral and examination
Referring service to first paediatric assessment
Table 57 shows the service from which a referral was made for a first paediatric assessment for children and young people who were diagnosed with epilepsy by the end of the first year of care. In England and Wales, 39.6% (440/1112) children and young people were referred by the emergency department (ED). 36.0% (400/1112) had a referral from the general practitioner (GP).
Figure 42 shows the percentage of referrals received from different services in England and Wales.
Table 57: Referring service to first paediatric assessment by country.
| Country | % ED | % GP | % Health Visitor | % Outpatient paediatrics | % Inpatient paediatrics | % PICU | % Neonatal care | % Other | |--------------------------|----------|----------|------------------|--------------------------|------------------------|--------|-----------------|---------| | England and Wales (N=1112) | 39.6% (440/1112) | 36.0% (400/1112) | 0.1% (1/1112) | 7.8% (87/1112) | 12.2% (136/1112) | 0.2% (2/1112) | 1.4% (16/1112) | 2.7% (30/1112) | | England (N=1051) | 39.5% (415/1051) | 35.5% (373/1051) | 0.1% (1/1051) | 8.2% (86/1051) | 12.3% (129/1051) | 0.2% (2/1051) | 1.4% (15/1051) | 2.9% (30/1051) | | Wales (N=61) | 41.0% (25/61) | 44.3% (27/61) | 0.0% (0/61) | 1.6% (1/61) | 11.5% (7/61) | 0.0% (0/61) | 1.6% (1/61) | 0.0% (0/61) |
Figure 42: Referring service to first paediatric assessment in England and Wales. Time since first referral to first paediatric assessment
71.2% (792/1112) of children and young people diagnosed with epilepsy had a valid date entered describing referral to first paediatric assessment.
14.4% (160/1112) of the children and young people diagnosed with epilepsy had not received input from a paediatrician with expertise in epilepsies.
11.0% (122/1112) of the children diagnosed with epilepsy had a date of referral to first paediatric assessment recorded as unknown.
3.4% (38/1112) had an invalid date of referral to first paediatric assessment (date of referral to first paediatric assessment was recorded as occurring after the date input from a paediatrician with expertise in epilepsy was achieved and therefore interpreted as invalid).
NICE guidelines (Quality statement 1) state that children and young people presenting with a suspected seizure are seen by a specialist in the diagnosis and management of the epilepsies within 2 weeks of presentation.
In Round 3, cohort 1, 15.5% (172/1112) children and young people diagnosed with epilepsy were seen by a paediatrician with expertise in epilepsy within 2 weeks of first referral in England and Wales (Table 58).
Table 58: Time in weeks to achieving input from paediatrician with expertise in epilepsy since the first referral to paediatrics by country.
| Country | 0 - 2 weeks | 2 - 4 weeks | 4 - 8 weeks | 8 - 12 weeks | 12 - 16 weeks | >16 weeks | |--------------------------|-------------|-------------|-------------|--------------|---------------|-----------| | England and Wales (N=1112) | 15.5% (172/1112) | 7.8% (87/1112) | 16.3% (181/1112) | 9.4% (105/1112) | 6.7% (75/1112) | 15.5% (172/1112) | | England (N=1051) | 16.0% (168/1051) | 7.9% (83/1051) | 16.4% (172/1051) | 9.0% (95/1051) | 6.6% (69/1051) | 15.2% (160/1051) | | Wales (N=61) | 6.6% (4/61) | 6.6% (4/61) | 14.8% (9/61) | 4.9% (3/61) | 9.8% (6/61) | 19.7% (12/61) |
Only the children with valid date of referral were included in this table. Therefore, the percentages do not add up to 100%. Age at first paediatric assessment
Figure 43 shows the number of children and young people diagnosed with epilepsy by their age and gender at the time of their first paediatric assessment.
The largest age group was younger children; infants below one years of age.
Figure 43: Numbers of children and young people diagnosed with epilepsy by age in years at first paediatric assessment and gender in England and Wales. (This figure excludes 2 children with unknown gender). Setting of the first paediatric assessment
In England and Wales, 47.7% (530/1112) of children and young people diagnosed with epilepsy had their first paediatric assessment in an acute setting.
52.1% (579/1112) had their first paediatric assessments in a non-acute setting. (Table 59).
Figure 44 shows a comparison of the setting of first paediatric assessment in Round 1, Round 2 and Round 3, cohort 1, in England and Wales.
Table 59: Setting of the first paediatric assessment by country.
| Country | % Acute | % Non-acute | % Don’t know | |--------------------------|---------------|---------------|--------------| | England and Wales (N=1112) | 47.7% (530/1112) | 52.1% (579/1112) | 0.3% (3/1112) | | England (N=1051) | 48.0% (504/1051) | 51.8% (544/1051) | 0.3% (3/1051) | | Wales (N=61) | 42.6% (26/61) | 57.4% (35/61) | 0.0% (0/61) |
Figure 44: Setting of first paediatric assessment in Round 1, Round 2 and Round 3 in England and Wales. Appropriate first assessment
Performance indicator 4: Appropriate first paediatric assessment
In Round 3, cohort 1, 61.6% (685/1112) of children and young people diagnosed with epilepsy had appropriate first paediatric assessment, (Table 60). This indicator ranged from 0% to 100% and had an interquartile range of 43.0% to 81.0%. In previous rounds, this performance indicator was applied to the whole cohort, rather than just the epilepsy subgroup, therefore longitudinal comparison is not meaningful.
Table 60: Appropriate first paediatric assessment.
| Evidence of an appropriate assessment | Audit Rounds | England and Wales | England | Wales | |--------------------------------------|--------------|-------------------|---------|-------| | 4 % of all children and young people with evidence of appropriate first paediatric clinical assessment | Round 3 | 61.6% (685/1112) | 60.1% (632/1051) | 86.9% (53/61) | | 4a % of children and young people with evidence of descriptions of episode | Round 3 | 98.4% (1094/1112) | 98.3% (1033/1051) | 100% (61/61) | | 4b % of children and young people with evidence of descriptions of age of child/timing of the first episode | Round 3 | 81.0% (901/1112) | 80.5% (846/1051) | 90.2% (55/61) | | 4c % of children and young people with evidence of descriptions of frequency | Round 3 | 93.5% (1040/1112) | 93.1% (979/1051) | 100% (61/61) | | 4d % of children and young people with evidence of descriptions of general examination | Round 3 | 94.2% (1048/1112) | 93.9% (987/1051) | 100% (61/61) | | 4e % of children and young people with evidence of descriptions of neurological examination | Round 3 | 91.5% (1018/1112) | 91.2% (959/1051) | 96.7% (59/61) | | 4f % of children and young people with evidence of description of developmental, learning or schooling progress | Round 3 | 82.6% (918/1112) | 81.5% (857/1051) | 100% (61/61) | | 4g % of children aged 3 years and over with evidence of consideration of emotional or behavioural problems | Round 3 | 66.0% (734/1112) | 64.7% (680/1051) | 88.5% (54/61) | Figure 45: Appropriate first paediatric assessment by unit, Round 3, cohort 1
Each Health Board or Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Description of episodes
Seizure type
Table 62 shows 91.0% (1012/1112) of the children and young people diagnosed with epilepsy in England and Wales at 1 year, had an epileptic seizure defined. Some children had more than one seizure type identified.
In the children with epilepsy, there were also episodes where there was uncertainty whether the seizures were epileptic or not for 14.7% (164/1112), and 0.9% (10/1112) where there were non-epileptic seizures identified, (Table 62). 28 children and young people diagnosed with epilepsy had more than three seizures by year one in England and Wales, (Table 61).
Table 61: Number of seizures in children diagnosed with epilepsy
| Country | 1 seizure | 2 seizures | 3 seizures | More than 3 seizures | |--------------------|-----------|------------|------------|----------------------| | England and Wales | 908 | 137 | 39 | 28 |
Table 62: Seizure type
| Country | % with epileptic seizures | % with non-epileptic seizures | % with uncertain seizures | |--------------------|---------------------------|-------------------------------|--------------------------| | England and Wales | 91.0% (1012/1112) | 0.9% (10/1112) | 14.7% (164/1112) | Epileptic seizure type
20 children and young people diagnosed with epilepsy had more than three epileptic seizures by year one in England and Wales (Table 63).
Table 63: Epileptic seizure type
| Country | 1 epileptic seizure | 2 epileptic seizures | 3 epileptic seizures | More than 3 epileptic seizures | |------------------|---------------------|----------------------|----------------------|--------------------------------| | England and Wales| 866 | 99 | 27 | 20 |
Figure 46 shows that in England and Wales, in their first year of care, children and young people diagnosed with epilepsy:
- 504 (45.3%) had generalised onset epileptic seizures,
- 370 (33.3%) had focal onset epileptic seizures,
- 126 (11.3%) had unknown onset epileptic seizures,
- 39 (3.5%) had unclassified epileptic seizures.
Figure 46: Percentage of children diagnosed with epilepsy by epileptic seizure type in England and Wales. Focal onset
Table 64 shows the proportion of children and young people diagnosed with epilepsy who had focal onset seizures during their first year of care in England and Wales. There were 174 (15.6%) children and young people who had impaired awareness focal onset seizures, (Table 64), which was the most common characteristic where a focal onset seizure was recorded.
Table 64: Percentage of children and young people diagnosed with epilepsy who had focal onset seizures in England and Wales.
| Focal Onset seizures | Round 3 cohort 1 (N=1112) | |---------------------------------------|---------------------------| | Impaired awareness | 174 (15.6%) | | Focal to bilateral tonic-clonic | | | Left | 78 (7.0%) | | Clonic | 66 (5.9%) | | Right | 64 (5.8%) | | Tonic | 56 (5.0%) | | Centro-temporal | 51 (4.6%) | | Temporal | 40 (3.6%) | | Behaviour arrest | 35 (3.1%) | | Automatisms | 33 (3.0%) | | Frontal | 22 (2.0%) | | Sensory | 18 (1.6%) | | Other | 12 (1.1%) | | Autonomic | 11 (1.0%) | | Occipital | 10 (0.9%) | | Atonic | 7 (0.6%) | | Epileptic spasms | 5 (0.4%) | | Emotional | 5 (0.4%) | | Parietal | * | | Gelastic | * | | Myoclonic | * | | Cognitive | * | | Hyperkinetic | * |
- In accordance with information governance rules, data based on a number less than five has been masked Out of the 370 children and young people diagnosed with epilepsy with focal onset seizures, 47% had impaired awareness seizures in England and Wales, (Figure 47).
Figure 47: Percentage of children and young people diagnosed with epilepsy who had focal onset seizures in England and Wales.
Parietal, Gelastic, Myoclonic, Cognitive, Hyperkinetic are not shown as there were fewer than five children and young people were recorded for each of these focal onset seizures. Generalised onset
258 (23.2%) of children and young people diagnosed with epilepsy had generalised onset tonic-clonic seizures in England and Wales, (Table 65).
Table 65: Percentage of children and young people diagnosed with epilepsy who had generalised onset seizures in England and Wales.
| General Onset Seizures | Round 3 cohort 1 (N=1112) | |----------------------------------------|---------------------------| | Tonic-clonic | 258 (23.2%) | | Typical absence | 138 (12.4%) | | Atypical absence | 46 (4.1%) | | Tonic | 24 (2.2%) | | Epileptic spasms | 14 (1.3%) | | Atonic | 12 (1.1%) | | Myoclonic | 11 (1.0%) | | Absence with eyelid myoclonia | 10 (0.9%) | | Myoclonic-atonic | 9 (0.8%) | | Other | 8 (0.7%) | | Clonic | * | | Myoclonic-tonic-clonic | * |
- In accordance with information governance rules, data based on a number less than five has been masked Out of the 504 children and young people diagnosed with epilepsy with generalised onset seizures, 51.2%, had tonic-clonic seizures in England and Wales, (Figure 48).
Figure 48: Percentage of children and young people diagnosed with epilepsy who had generalised onset seizures in England and Wales. (Clonic and Myoclonic-tonic-clonic are not shown as there were fewer than five children and young people in each).
Unknown onset
85 (7.6%) of children and young people diagnosed with epilepsy had unknown onset seizures in England and Wales, (Table 66).
Table 66: Percentage of children and young people diagnosed with epilepsy who had unknown onset seizures in England and Wales.
| Unknown Onset Seizures | Round 3, cohort 1 (N=1112) | |------------------------------|-----------------------------| | Tonic-clonic | 85 (7.6%) | | Behaviour arrest | 25 (2.2%) | | Other | 16 (1.4%) | | Epileptic spasms | 11 (1.0%) | Out of the 126 children and young people diagnosed with epilepsy with unknown onset seizures, 67.5% had tonic-clonic seizures in England and Wales, (Figure 49).
**Non-epileptic seizure type**
There were 10 children and young people diagnosed with epilepsy who had non-epileptic seizures. 6 (0.5%) of the children and young people diagnosed with epilepsy had non-epileptic seizures and behavioural, psychological or psychiatric disorders. Electroclinical syndrome
Figure 50 shows the electroclinical syndrome classification. Eight children had more than one International League Against Epilepsy (ILAE) classification. ILAE classifications are shown in Figure 50, where the electroclinical syndrome was recorded for at least one child or young person.
Figure 50: Number of children and young people diagnosed with epilepsy by electroclinical syndrome in England and Wales. Certain categories are not shown in Figure 50 as there were fewer than five children and young people. These are: Epilepsy with myoclonic astatic seizures, Benign familial neonatal seizures, Early myoclonic encephalopathy, Ohtahara syndrome, Benign infantile seizure, Late onset childhood occipital epilepsy, Lennox-Gastaut syndrome, Parietal lobe epilepsy, Dravet syndrome, Visual sensitive epilepsies, Childhood epilepsy with occipital paroxysms, Generalized Epilepsies with Febrile seizures and (Benign) Myoclonic epilepsy in infancy.
**Performance indicator 5: Seizure formulation**
In Round 3, cohort 1, 88.0% (979/1112) of children and young people diagnosed with epilepsy had an appropriate seizure classification in the first year of care, (Table 67). Appropriate seizure formulation was defined as having selected an International League Against Epilepsy (ILAE) seizure classification (all ILAE seizure types or ‘unclassified’). At a Health Board and Trust level, this indicator ranged from 25% to 100% and had an interquartile range of 83% to 100%.
**Table 67: Seizure formulation.**
| Seizure Formulation | Audit Round | England and Wales | England | Wales | |---------------------|-------------|-------------------|---------|-------| | % of children and young people with epilepsy with appropriate seizure classification at first year of care | Round 1 | 86.9% (1318/1516) | 86.8% (1235/1423) | 89.2% (83/93) | | | Round 2 | 94.9% (1040/1096) | 95.5% (973/1019) | 94.4% (67/71) | | | Round 3 | 88.0% (979/1112) | 87.4% (919/1051) | 98.4% (60/61) | Figure 51: Seizure formulation, by Health Board and Trust, Round 3, cohort 1.
Each Health Board or Trust is represented by a vertical bar in the order of the percentage score, including any recording 0% of children and young people with epilepsy who had an appropriate seizure classification. Seizure cause
31 (2.8%) children and young people in England and Wales diagnosed with epilepsy had a genetic seizure cause, whilst 84 (7.6%) had a structural seizure cause, (Table 68). The cause of seizure in 221 (19.9%) children and young people diagnosed with epilepsy was unknown.
Table 68: Percentage of children and young people diagnosed with epilepsy by seizure cause in England and Wales.
| Seizure Cause | Round 3 cohort 1 (N=1112) | |---------------------|---------------------------| | Genetic | 31 (2.8%) | | Immune | * | | Infectious | 10 (0.9%) | | Metabolic | * | | Not known | 221 (19.9%) | | Structural | 84 (7.6%) |
- In accordance with information governance rules, data based on a number less than five has been masked
Of the 31 children with genetic cause of their epilepsy, 12 (30.7%) had chromosomal abnormality, 18 (58.1%) had genetic abnormality and fewer than five had Rett Syndrome. Out of the 84 children and young people diagnosed with a structural seizure cause of their epilepsy, 29.8% had a vascular cause (e.g. arterial ischaemic stroke), (Figure 52).
Figure 52: Percentage of children and young people diagnosed with epilepsy who had structural seizure cause. Convulsive seizures
Convulsive epileptic seizures
63% (701/1112) of children and young people diagnosed with epilepsy had convulsive seizures, whilst 37% (411/1112) did not have convulsive seizures in England and Wales, (Table 69/Figure 53). The proportion of children and young people with convulsive seizures in England was similar to Wales.
Table 69: Convulsive epileptic seizures in children and young people diagnosed with epilepsy by country.
| Country | % with convulsive seizures | % with no convulsive seizures | |--------------------|---------------------------|------------------------------| | England & Wales (N=1112) | 63.0% (701/1112) | 37.0% (411/1112) | | England (N=1051) | 63.0% (662/1051) | 37.0% (389/1051) | | Wales (N=61) | 63.9% (39/61) | 36.1% (22/61) |
Figure 53: Percentage of children and young people diagnosed with epilepsy with/with no convulsive epileptic seizures in England and Wales. Prolonged generalised convulsive seizures
Table 70 shows that 16.3% (181/1112) of the children and young people diagnosed with epilepsy, experienced prolonged generalised convulsive seizures in year one. Prolonged seizures are those with a duration of more than five minutes or successive seizures continuing for more than five minutes.
79.8% (887/1112) of children and young people with epilepsy did not experience prolonged generalised convulsive seizures. There was uncertainty whether the seizures were prolonged generalised convulsive seizures or not for 4.0% (44/1112) of children and young people.
Figure 54 shows the percentage of children and young people diagnosed with epilepsy by prolonged generalised convulsive epileptic seizures in England and Wales.
Table 70: Prolonged generalised convulsive epileptic seizures in children and young people diagnosed with epilepsy.
| Country | % yes | % no | % uncertain | |--------------------------|----------------|----------------|-------------| | England and Wales (N=1112) | 16.3% (181/1112) | 79.8% (887/1112) | 4.0% (44/1112) |
Figure 54: Percentage of children and young people diagnosed with epilepsy by prolonged generalised convulsive epileptic seizures in England and Wales. Prolonged focal convulsive seizures
Table 71 shows 10.0% (111/1112) of the children and young people diagnosed with epilepsy, experienced prolonged focal convulsive seizures in their first year of care. Prolonged seizures are those with a duration of more than five minutes or successive seizures continuing for more than five minutes.
There was uncertainty whether the seizures were prolonged focal convulsive seizures or not in 5.8% (65/1112) of children and young people. Figure 55 shows the percentage of children and young people diagnosed with epilepsy by prolonged generalised convulsive epileptic seizures in England and Wales.
Table 71: Prolonged focal convulsive epileptic seizures in children and young people diagnosed with epilepsy by country.
| Country | % yes | % no | % uncertain | |--------------------------|-------------|--------------|-------------| | England and Wales (N=1112) | 10.0% (111/1112) | 84.2% (936/1112) | 5.8% (65/1112) |
Figure 55: Percentage of children and young people diagnosed with epilepsy by prolonged focal convulsive epileptic seizures in England and Wales. Family history of epilepsy
26.8% (298/1112) of children and young people in England and Wales diagnosed with epilepsy had a family history of epilepsy. 73.2% (814/1112) did not have any family history of epilepsy. (Table 72).
Figure 56 shows the percentage of children and young people diagnosed with epilepsy by family history of epilepsy in England and Wales.
Table 72: Family history of epilepsy in children and young people diagnosed with epilepsy by country.
| Country/ network | % with family history of epilepsy | % with no family history of epilepsy | |------------------|----------------------------------|-------------------------------------| | England and Wales (N=1112) | 26.8% (298/1112) | 73.2% (814/1112) | | England (N=1051) | 26.4% (277/1051) | 73.6% (774/1051) | | Wales (N=61) | 34.4% (21/61) | 65.6% (40/61) |
Figure 56: Percentage of children and young people diagnosed with epilepsy with/with no family history of epilepsy in England and Wales. Neurodisability or neurodevelopmental problems
24.4% (271/1112) of children and young people diagnosed with epilepsy had a neurodisability/neurodevelopmental problem described by one year in England and Wales in Round 3, cohort 1. 6.4% (71/1112) had autistic spectrum disorder and 6.3% (70/1112) had an intellectual disability/global development delay/learning disability as shown in Table 73. Figure 57 shows a breakdown of the neurodisability or neurodevelopmental problems among children diagnosed with epilepsy in Round 3, cohort 1. Table 73: Neurodisability/neurodevelopmental problems among children diagnosed with epilepsy in Round 3.
| Country/network | % Autistic spectrum disorder | % Cerebral palsy | % Neurodegenerative disease | % Identified chromosomal disorder | % Attention deficit hyperactivity | % Intellectual disability | % Dyspraxia | % Dyslexia | % Speech disorder | % Other learning difficulty | |-----------------|-----------------------------|-----------------|-----------------------------|----------------------------------|---------------------------------|--------------------------|-------------|------------|------------------|---------------------------| | England & Wales (N=1112) | 6.4% (71/1112) | 3.6% (40/1112) | * | 1.9% (21/1112) | 1.7% (19/1112) | 6.3% (70/1112) | * | 0.7% (8/1112) | 1.6% (18/1112) | 3.4% (38/1112) | | England (N=1051) | 6.7% (70/1051) | 3.6% (38/1051) | * | 2.0% (21/1051) | 1.8% (19/1051) | 6.2% (65/1051) | * | 0.7% (7/1051) | 1.5% (16/1051) | 3.5% (37/1051) | | Wales (N=61) | * | * | 0.0% (0/61) | 0.0% (0/61) | 0.0% (0/61) | 8.2% (5/61) | * | * | * | * | | BRPNF (N=92) | 5.4% (5/92) | * | 0.0% (0/92) | 0.0% (0/92) | * | 7.6% (7/92) | 0.0% (0/92) | * | * | * | | CEWT (N=94) | 5.3% (5/94) | * | * | * | 6.4% (6/94) | 0.0% (0/94) | * | * | * | * | | EPEN (N=75) | 6.7% (5/75) | 0.0% (0/75) | 0.0% (0/75) | * | 0.0% (0/75) | * | 0.0% (0/75) | 0.0% (0/75) | * | * | | EPIC (N=112) | 4.5% (5/112) | * | * | * | * | * | * | * | 4.5% (5/112) | 8.9% (10/112) | | NTPEN (N=99) | 15.2% (15/99) | 5.1% (5/99) | 0.0% (0/99) | * | * | 8.1% (8/99) | 0.0% (0/99) | 0.0% (0/99) | * | * | | NWEIG (N=67) | * | * | 0.0% (0/67) | 0.0% (0/67) | * | 14.9% (10/67) | 0.0% (0/67) | 0.0% (0/67) | * | 0.0% (0/67) | | ORENG (N=91) | * | * | * | 0.0% (0/91) | * | 5.5% (5/91) | 0.0% (0/91) | 0.0% (0/91) | * | * | | PENNEC (N=65) | 10.8% (7/65) | 7.7% (5/65) | 0.0% (0/65) | * | 0.0% (0/65) | * | 0.0% (0/65) | 0.0% (0/65) | * | * | | SETPEG (N=23) | * | 0.0% (0/23) | 0.0% (0/23) | 0.0% (0/23) | 0.0% (0/23) | * | 0.0% (0/23) | 0.0% (0/23) | 0.0% (0/23) | 0.0% (0/23) | | SWEP (N=51) | * | * | 0.0% (0/51) | 0.0% (0/51) | 0.0% (0/51) | 9.8% (5/51) | * | * | 0.0% (0/51) | * | | SWIPE (N=72) | 6.9% (5/72) | 6.9% (5/72) | 0.0% (0/72) | 6.9% (5/72) | * | * | * | 0.0% (0/72) | * | * | | SWTPEG (N=64) | 10.9% (7/64) | 9.4% (6/64) | * | * | * | 10.9% (7/64) | 0.0% (0/64) | * | * | * | | TEN (N=54) | * | * | 0.0% (0/54) | 0.0% (0/54) | * | 0.0% (0/54) | 0.0% (0/54) | 0.0% (0/54) | 0.0% (0/54) | * | | WPNN (N=42) | * | 0.0% (0/42) | 0.0% (0/42) | 0.0% (0/42) | 0.0% (0/42) | * | 0.0% (0/42) | * | * | * | | YPEN (N=111) | 4.5% (5/111) | * | * | * | 0.0% (0/111) | * | 0.0% (0/111) | 0.0% (0/111) | * | * |
- In accordance with information governance rules, data based on a number less than five has been masked. Figure 57: Neurodisability/neurodevelopmental problems among children diagnosed with epilepsy in cohort 1.
Table 74 shows, out of 70 children and young people diagnosed with epilepsy with intellectual disability/global development delay/learning disability, 54.3% (38/70) had moderate severity in England and Wales.
Table 74: Percentage of severity of neurodevelopmental problems among the children and young people with intellectual disability, global development delay, or learning disability in England and Wales.
| Severity of neurodevelopmental problems | % of children and young people with intellectual disability | |----------------------------------------|----------------------------------------------------------| | Mild | 22.9% (16/70) | | Moderate | 54.3% (38/70) | | Severe or Profound | 22.8% (16/70) | Mental health conditions
4.6% (51/1112) of children and young people diagnosed with epilepsy in cohort 1 had an identified mental health condition(s) by one year in England and Wales. 0.5% (6/112) had a mood disorder, 0.7% (8/112) had an anxiety disorder and 2.3% (26/1112) had other mental health concerns.
6.1% (43/701) of children and young people between the age of 5-15 years and diagnosed with epilepsy in cohort 1, had an identified mental health condition(s) by one year in England and Wales. 23.3% (10/43) of these had formal development assessment, 20.9% (9/43) had formal cognitive assessment by one year, (Table 76).
There were 11 children and young people with emotional/behavioural problems, which included conduct disorders and Oppositional Defiant Disorder (ODD).
Table 75: Percentage of children and young people diagnosed with mental health conditions in England and Wales.
| Mental health condition | % of children and young people with mental health conditions | % of children and young people ages 5–15 with mental health conditions | |-------------------------|-------------------------------------------------------------|---------------------------------------------------------------------| | Mood disorder | 0.5% (6/1112) | 0.7% (5/701) | | Anxiety disorder | 0.7% (8/1112) | 1.1% (8/701) | | Emotional/behavioural | 1.0% (11/1112) | 1.4% (10/701) | | Other\* | 2.3% (26/1112) | 2.8% (20/701) |
\*Includes self-harm as there were fewer than 5 children and young people Figure 58: Number of children diagnosed with epilepsy by mental health condition in England and Wales.
Table 76: Percentage of children and young people between the age of 5-15 years and diagnosed with a mental health condition that had ongoing investigations in England and Wales.
| Mental health condition that requires ongoing investigations | % of children and young people with mental health conditions | |-------------------------------------------------------------|-------------------------------------------------------------| | Formal developmental assessment | 23.3% (10/43) | | Formal cognitive assessment | 20.9% (9/43) | Investigations
Time since first request for EEG
- 0.4% (4/1112) of the children and young people diagnosed with epilepsy did not have an EEG.
- 3.1% (35/1112) had an invalid EEG request date/EEG obtained date (date of EEG request is after the date EEG was obtained).
- 96.5% (1073/1112) children and young people diagnosed with epilepsy had a valid EEG request date.
- 94.2% (1047/1112) children and young people diagnosed with epilepsy obtained an EEG and had a valid EEG request date.
NICE guidelines (Quality Statement 2) state that children and young people having initial investigations for epilepsy undergo the tests within 4 weeks of being requested.
In Round 3, cohort 1, 56.2% (625/1112) of children and young people diagnosed with epilepsy, obtained their EEG within four weeks of request in England and Wales, (Table 77).
Table 77: Time in weeks to when EEG was obtained since EEG request date by country
| Country | 0 - 4 weeks | 4 - 8 weeks | 8 - 12 weeks | 12 - 16 weeks | >16 weeks | |------------------|-------------|-------------|--------------|---------------|-----------| | England & Wales (N=1112) | 56.2% (625/1112) | 26.6% (296/1112) | 5.2% (58/1112) | 2.3% (26/1112) | 3.8% (42/1112) | | England (N=1051) | 57% (599/1051) | 26.1% (274/1051) | 4.7% (49/1051) | 2.3% (24/1051) | 4.0% (42/1051) | | Wales (N=61) | 42.6% (26/61) | 36.1% (22/61) | 14.8% (9/61) | 3.3% (2/61) | 0.0% (0/61) |
The four children and young people who did not have an EEG and those with invalid dates are not included in the analysis on this table, hence the percentages do not add up to 100%.
Table 78 shows 97.5% (1084/1112) of children and young people diagnosed with epilepsy obtained the first EEG in year one. 59.1% (657/1112) obtained MRI brain, 56.4% (627/1112) obtained 12 lead ECG and 13.1% (146/1112) obtained a CT head scan in year one, in England and Wales. Figure 59 shows the percentages of children and young people who obtained each investigation in England and Wales. These are displayed as descriptions, rather than performance-related percentages because not all children with epilepsy require each investigation.
Table 78: Number and percentage of children and young people diagnosed with epilepsy that obtained First EEG, 12 lead ECG, CT head scan and MRI brain investigations by country and OPEN UK network.
| Country/ Network | % First EEG | % 12 lead ECG | % CT head scan | % MRI brain | |------------------|-------------|---------------|----------------|-------------| | England & Wales (N=1112) | 97.5% (1084/1112) | 56.4% (627/1112) | 13.1% (146/1112) | 59.1% (657/1112) | | England (N=1051) | 97.3% (1023/1051) | 57.8% (607/1051) | 13.6% (143/1051) | 59.7% (627/1051) | | Wales (N=61) | 100% (61/61) | 32.8% (20/61) | 4.9% (3/61) | 49.2% (30/61) | | BRPNF (N=92) | 97.8% (90/92) | 62% (57/92) | 9.8% (9/92) | 56.5% (52/92) | | CEWT (N=94) | 100% (94/94) | 68.1% (64/94) | 8.5% (8/94) | 61.7% (58/94) | | EPEN (N=75) | 94.7% (71/75) | 45.3% (34/75) | 10.7% (8/75) | 53.3% (40/75) | | EPIC (N=112) | 100% (112/112) | 46.4% (52/112) | 11.6% (13/112) | 59.8% (67/112) | | NTPEN (N=99) | 97.0% (96/99) | 58.6% (58/99) | 9.1% (9/99) | 64.6% (64/99) | | NWEIG (N=67) | 100% (67/67) | 55.2% (37/67) | 19.4% (13/67) | 55.2% (37/67) | | ORENG (N=91) | 93.4% (85/91) | 51.6% (47/91) | 20.9% (19/91) | 53.8% (49/91) | | PENNEC (N=65) | 95.4% (62/65) | 52.3% (34/65) | 15.4% (10/65) | 55.4% (36/65) | | SETPEG (N=23) | 100% (23/23) | 82.6% (19/23) | 17.4% (4/23) | 73.9% (17/23) | | SWEP (N=51) | 100% (51/51) | 33.3% (17/51) | 5.9% (3/51) | 49.0% (25/51) | | SWIPE (N=72) | 98.6% (71/72) | 48.6% (35/72) | 8.3% (6/72) | 61.1% (44/72) | | SWTPEG (N=64) | 96.9% (62/64) | 81.3% (52/64) | 17.2% (11/64) | 67.2% (43/64) | | TEN (N=54) | 98.1% (53/54) | 59.3% (32/54) | 11.1% (6/54) | 38.9% (21/54) | | WPNN (N=42) | 97.6% (41/42) | 42.9% (18/42) | 14.3% (6/42) | 69.0% (29/42) | | YPEN (N=111) | 95.5% (106/111) | 64% (71/111) | 18.9% (21/111) | 67.6% (75/111) | Figure 59: Percentage of children and young people diagnosed with epilepsy that obtained First EEG, 12 lead ECG, CT head scan and MRI brain investigations in England and Wales. Performance Indicator 6: ECG
In Round 3 cohort 1, 67.6% (474/701) of children and young people diagnosed with epilepsy and had convulsive seizures, obtained a 12 lead ECG by the first year in England and Wales, (Table 79). This indicator ranged from 0% to 100% and the inter-quartile range was 46.0% to 100% at a Health Board or Trust level. In Round 3, this performance indicator was just applied to children with epilepsy and convulsive seizures, rather than all children with convulsive seizures. This means that longitudinal comparison is not meaningful and therefore has not been reported.
Table 79: Percentage of children and young people with convulsive seizures and epilepsy, with an ECG by the first year, Round 3, cohort 1.
| Performance Indicator: 6 | England and Wales | England | Wales | |--------------------------|-------------------|---------|-------| | ECG | % of children and young people with convulsive seizures and epilepsy, with an ECG by the first year | 67.6% (474/701) | 69.5% (460/662) | 35.9% (14/39) | Figure 60: Percentage of children and young people with convulsive seizures and epilepsy, with an ECG at first year by Health Board and Trust, Round 3, cohort 1.
Each Health Board or Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Performance Indicator 7: MRI
NICE guidelines (Quality Statement 3) states that children and young people who meet the criteria for neuroimaging for epilepsy to have magnetic resonance imaging (MRI).
In Round 3, cohort 1, 68.6% (317/462) children and young people diagnosed with epilepsy and with defined indications for an MRI, who had MRI by their first year of care in England and Wales, (Table 80). At a Health Board or Trust level in Round 3, this indicator ranged from 0% to 100%, the inter-quartile range was 50% to 100%.
Table 80: Percentage of children and young people with defined indications for an MRI, who had MRI by their first year of care.
| Performance Indicator: 7 | Audit Round | England and Wales | England | Wales | |--------------------------|-------------|-------------------|---------|-------| | MRI | % of children and young people with defined indications for an MRI, who had MRI by first year | Round 1 | 63.5% (602/948) | 64.3% (578/899) | 49.0% (24/49) | | | | Round 2 | 72.2% (481/666) | 72.7% (458/630) | 63.9% (23/36) | | | | Round 3 | 68.6% (317/462) | 70.4% (307/436) | 38.5% (10/26) | Figure 61: Percentage of children and young people with defined indications for an MRI, who had MRI by first year by Health Board and Trust, Round 3, cohort 1.
Each Health Board or Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Treatment
Anti-epileptic drug (AED)
In Round 3, cohort 1, 879 children and young people were prescribed one or more anti-epileptic drugs (AEDs) during their first 12 months of care. 72 children and young people had begun three or more AEDs during their first 12 months of care.
Table 81 below shows the diagnosis of children and young people together with the number of different AEDs prescribed over their first year of care.
Table 81: Diagnosis and AEDs.
| Diagnoses | Round 1 | Round 2 | Round 3 | |----------------------------------|--------------------------|--------------------------|--------------------------| | | 1 or more AED N=1538 | 3 or more AEDs N=135 | 1 or more AED N=1059 | 3 or more AEDs N=84 | 1 or more AED N=879 | 3 or more AEDs N=72 | | Epilepsy | 1406 (91.0%) | 129 (96.0%) | 976 (92.0%) | 82 (98.0%) | 856 (97.4%) | 71 (98.6%) | | Single epileptic seizure (or cluster) | 68 (4.0%) | 6 (4.0%) | 9 (1.0%) | 0 (0.0%) | 10 (1.1%) | 0 (0.0%) | | Non-epileptic episode (s) | 44 (3.0%) | 0 (0.0%) | 20 (2.0%) | 1 (1.0%) | 7 (0.8%) | 1 (1.4%) | | Uncertain episodes | 20 (1.0%) | 0 (0.0%) | 55 (5.0%) | 1 (1.0%) | 6 (0.7%) | 0 (0.0%) |
Figure 62 shows the frequency of AEDs use among children diagnosed with epilepsy. Carbamazepine, sodium valproate and levetiracetam were the most commonly used AEDs for children diagnosed with epilepsy in Round 3, cohort 1. Figure 62: Frequency by AED type in England and Wales, Round 3, cohort 1.
**Sodium valproate use**
Figure 63 below shows the number of children and young people diagnosed with epilepsy on sodium valproate by gender in England and Wales, Round 3 cohort 1. There were more boys on sodium valproate than girls across all ages. Figure 63: Number of children and young people diagnosed with epilepsy on sodium valproate by gender in England and Wales, Round 3 cohort 1.
\*Age groups with fewer than five children and young people are not shown. Performance indicator 9 and 9b: Sodium Valproate
In Round 3, cohort 1, 39.7% (25/63) of all females diagnosed with epilepsy and on sodium valproate treatment, had evidence of previous discussion of risk regarding birth defects and/or neurodevelopmental outcomes, (Table 82). This indicator ranged from 0% to 100% and had an interquartile range of 0% to 100% at a Health Board and Trust level.
There were fewer than five females aged nine years and above, who were diagnosed with epilepsy and receiving treatment with sodium valproate. All (100%) of them had evidence of previous discussion of risk regarding birth defects and/or neurodevelopmental outcomes.
Table 82: Sodium Valproate in females
| Performance indicator: Sodium valproate | Audit Round | England and Wales | |----------------------------------------|-------------|-------------------| | 9 | Round 3 | 100% (>5) | | % of all females >9 years currently on valproate treatment with evidence of discussion of foetal risk | | 9b | Round 3 | 39.7% (25/63) | | % of all females currently on valproate treatment with evidence of discussion of foetal risk | Figure 64: Percentage of females currently on sodium valproate treatment with evidence of discussion of foetal risk by Health Board and Trust, Round 3, cohort 1.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph.
**Rescue medication prescribed**
19.6% (218/1112) of the children and young people diagnosed with epilepsy had rescue medication prescription in England and Wales, (Figure 65). 80.4% (894/1112) of children and young people did not have rescue medication prescribed.
Figure 66 shows the percentage of children and young people diagnosed with epilepsy that had rescue medication prescribed by country and network. Figure 65: Percentage of children and young people diagnosed with epilepsy that had/did not have rescue medication prescribed in England and Wales.
Figure 66: Percentage of children and young people diagnosed with epilepsy that had rescue medication prescribed by country and network. Children’s Epilepsy Surgery Service (CESS) referral criteria
8.0% (89/1112) of the children and young people diagnosed with epilepsy, met one or more of the CESS referral criteria in England and Wales, (Figure 66). 92.0% (1023/1112) of children and young people did not meet any CESS referral criteria.
Figure 67: Percentage of children and young people diagnosed with epilepsy that met/did not meet any CESS referral criteria in England and Wales. Figure 68 shows the percentage of children and young people diagnosed with epilepsy that met any CESS referral criteria by country and network. In the paediatric network areas, this varied between 0% and 16.0% of children and young people meeting any CESS referral criteria.
Figure 68: Percentage of children and young people diagnosed with epilepsy that met any CESS referral criteria by country and network. Performance indicator 3b: Epilepsy surgery referral
In Round 3, cohort 1, **30.0% (27/89)** of the children and young people who met CESS referral criteria had epilepsy surgery referral by one year, (Table 83). Table 84 shows the breakdown of this performance indicator by network. This is a new indicator for Round 3 and therefore longitudinal comparison will not be possible.
Table 83: Epilepsy surgery referral.
| Performance Indicator: 3b | Audit Round | England and Wales | England | Wales | |---------------------------|-------------|-------------------|---------|-------| | Epilepsy Surgery Referral | Round 3 | 30.0% (27/89) | 33.0% (26/78) | 9.1% (1/11) |
Table 84: Percentage of ongoing children and young people meeting defined epilepsy surgery referral criteria with evidence of epilepsy surgery referral by country and network.
| Country/network | Epilepsy surgery referral | |-----------------|---------------------------| | England and Wales | 30% (27/89) | | England | 33% (26/78) | | Wales | 9.1% (1/11) | | BRPNF | 83.3% (5/6) | | CEWT | 12.5% (1/8) | | EPEN | 33.3% (2/6) | | EPIC | 25.0% (4/16) | | NTPEN | 36.4% (4/11) | | NWEIG | 25.0% (1/4) | | ORENG | 0.0% (0/3) | | PENNEC | 0.0% (0/5) | | SETPEG | (0/0) | | SWEP | 12.5% (1/8) | | SWIPE | 50.0% (2/4) | | SWTPEG | 33.3% (1/3) | | TEN | 75.0% (3/4) | | WPNN | 33.3% (1/3) | | YPEN | 25.0% (2/8) | 4.0% (6/150) of children and young people meeting the defined criteria for paediatric neurology referral, did not have a paediatric neurologist input date.
*NICE guidelines (Quality statement 7) state that children and young people who meet the criteria for referral to a neurologist are seen within 4 weeks of referral.*
52.8% (76/144) of children and young people who met the criteria for referral to a neurologist, were seen within four weeks of referral in England and Wales, *(Table 85).*
**Table 85: Time in weeks since referral to neurologist by country.**
| Country | 0 - 4 weeks | 4 - 8 weeks | 8 - 12 weeks | 12 - 16 weeks | >16 weeks | |------------------|-------------|-------------|--------------|---------------|-----------| | England and Wales| 52.8% (76/144) | 14.6% (21/144) | 12.5% (18/144) | 6.9% (10/144) | 11.8% (17/144) | | England | 52.9% (72/136) | 14.7% (20/136) | 12.5% (17/136) | 6.6% (9/136) | 11.8% (16/136) | | Wales | 50.0% (4/8) | 12.5% (1/8) | 12.5% (1/8) | 12.5% (1/8) | 12.5% (1/8) |
*Only the children with a paediatric neurologist input date were included in this analysis, hence the percentages on the table may not add up to 100%.* Care planning
Appropriate care planning
Performance indicator 10: Comprehensive Care Planning agreement
In Round 3, cohort 1, 62.4% (694/1112) of children and young people diagnosed with epilepsy had evidence of a comprehensive care plan that had been updated where necessary and was agreed between the patient, their family and/or carers and primary and secondary care providers, for the first year of care (Table 86). This indicator ranged from 0% to 100% and had an interquartile range of 43% to 81% at a Health Board or Trust level.
Table 86: Comprehensive Care Planning agreement
| Performance indicator: Comprehensive Care Planning agreement | Audit Round | England and Wales | England | Wales | |-------------------------------------------------------------|-------------|-------------------|---------|-------| | 10 % of children and young people with epilepsy after 12 months where there is evidence of a comprehensive care plan that is agreed between the person, their family and/or carers and primary and secondary care providers, and the care plan has been updated where necessary | Round 3 | 62.4% (694/1112) | 63.5% (667/1051) | 44.3% (27/61) | | 10a % of children and young people with epilepsy after 12 months that had an individualised epilepsy document with individualised epilepsy document or a copy clinic letter that includes care planning information | Round 3 | 88.3% (982/1112) | 88.8% (933/1051) | 80.3% (49/61) | | 10b % of children and young people with epilepsy after 12 months where there was evidence of agreement between the person, their family and/or carers as appropriate | Round 3 | 74.2% (825/1112) | 74.8% (786/1051) | 63.9% (39/61) | | 10c % of children and young people with epilepsy after 12 months where there is evidence that the care plan has been updated where necessary | Round 3 | 69.6% (774/1112) | 71.0% (746/1051) | 45.9% (28/61) | Figure 69: Comprehensive Care Planning agreement, Round 3
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Performance indicator 11: Comprehensive Care Planning content
NICE guidelines (Quality statement 4) state that children and young people with epilepsy have an agreed and comprehensive care plan.
In Round 3, cohort 1, 70.1% (779/1112) of children and young people diagnosed with epilepsy had documented evidence of communication regarding relevant core elements of care planning, (Table 87). This indicator ranged from 0% to 100% and had an interquartile range of 50% to 100% at a Health Board and Trust level.
NICE guidelines (Quality statement 6) state that children and young people with a history of prolonged or repeated seizures have an agreed written emergency care plan.
88.5% (193/218) of children and young people diagnosed with epilepsy and on rescue medication, had a parental prolonged seizure care plan in England and Wales, (Table 87).
Table 87: Comprehensive Care Planning content.
| Performance indicator: Comprehensive Care Planning content | Audit Round | England and Wales | England | Wales | |------------------------------------------------------------|-------------|-------------------|---------|-------| | 11 % of children diagnosed with epilepsy with documented evidence of communication regarding relevant core elements of care planning | Round 3 | 70.1% (779/1112) | 71.7% (754/1051) | 41.0% (25/61) | | 11a % of children diagnosed with epilepsy with parental prolonged seizures care plan | Round 3 | 88.5% (193/218) | 89.2% (182/204) | 78.6% (11/14) | | 11b % of children diagnosed with epilepsy with evidence of discussion regarding water safety | Round 3 | 79.7% (886/1112) | 81.4% (856/1051) | 49.2% (30/61) | | 11c % of children diagnosed with epilepsy with evidence of discussion regarding first aid | Round 3 | 84.8% (943/1112) | 86.2% (906/1051) | 60.7% (37/61) | | 11d % of children diagnosed with epilepsy with evidence of discussion regarding general participation and risk | Round 3 | 80% (890/1112) | 81.1% (852/1051) | 62.3% (38/61) | | 11e % of children diagnosed with epilepsy evidence of discussion of been given service contact details | Round 3 | 90.7% (1009/1112) | 91.3% (960/1051) | 80.3% (49/61) | Figure 70: Comprehensive Care Planning content by Health Board and Trust, Round 3.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Performance indicator 12: School Individual Healthcare Plan
In Round 3 cohort 1, 32.2% (231/717) of children and young people diagnosed with epilepsy and aged five years and above had evidence of a school individual healthcare plan by one year (Table 88). This indicator ranged from 0% to 100% and had an interquartile range of 0% to 63% at Health Board or Trust level.
Table 88: School Individual Healthcare Plan
| Performance indicator 12: | Audit Round | England and Wales | England | Wales | |---------------------------|-------------|-------------------|---------|-------| | School Individual Healthcare Plan | % of children and young people with epilepsy aged 5 years and above with evidence of a school individual healthcare plan by 1 year after first paediatric assessment. | Round 3 | 32.2% (231/717) | 32.4% (219/676) | 29.3% (12/41) |
Figure 71: School Individual Healthcare Plan, by Health Board or Trust, Round 3, cohort 1
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Sudden Unexpected Death in Epilepsy (SUDEP)
42.6% (474/1112) of children and young people diagnosed with epilepsy had evidence of information on SUDEP in England and Wales (Figure 72). 57.4% (638/1112) of children and young people did not have SUDEP information provided. Figure 73 shows the percentage of children and young people with evidence of SUDEP information by country and network.
Figure 72: Percentage of children and young people diagnosed with Epilepsy with/without evidence of SUDEP information in England and Wales.
Figure 73: Percentage of children and young people diagnosed with evidence of SUDEP information by country and network. Professionals and services involved in care
Professionals
Table 89 shows that 82.3% (915/1112) of the children and young people diagnosed with epilepsy had input from a paediatrician with expertise in epilepsies in England and Wales in their first year of care. 71.8% (798/1112) of children and young people diagnosed with epilepsy had an input from an epilepsy specialist nurse (ESN).
Figure 74 shows the percentage of children and young people diagnosed with epilepsy with an input from various professionals in England and Wales.
Table 89: Percentage of children and young people diagnosed with epilepsy with an input from various professionals by Country.
| Professionals and services involved in care | England and Wales | England | Wales | |--------------------------------------------|-------------------|---------|-------| | % Consultant Paediatrician with expertise in epilepsies | 82.3% (915/1112) | 81.9% (861/1051) | 88.5% (54/61) | | % ESN | 71.8% (798/1112) | 73.2% (769/1051) | 47.5% (29/61) | | % Paediatric neurologist | 22.4% (249/1112) | 22.1% (232/1051) | 27.9% (17/61) | | % CESS | 1.6% (18/1112) | 1.7% (18/1051) | 0.0% (0/61) | | % Ketogenic dietician | 0.6% (7/1112) | 0.7% (7/1051) | 0.0% (0/61) | | % VNS service | 0.0% (0/1112) | 0.0% (0/1051) | 0.0% (0/61) | | % Genetic service | 4.8% (53/1112) | 4.9% (52/1051) | 1.6% (1/61) | | % Clinical psychologist | 1.2% (13/1112) | 1.2% (13/1051) | 0.0% (0/61) | | % Educational psychologist | 0.6% (7/1112) | 0.7% (7/1051) | 0.0% (0/61) | | % Psychiatrist | 0.6% (7/1112) | 0.7% (7/1051) | 0.0% (0/61) | | % Neuropsychologist | 0.5% (6/1112) | 0.6% (6/1051) | 0.0% (0/61) | | % Counselling service | 0.4% (4/1112) | 0.4% (4/1051) | 0.0% (0/61) | | % Other mental health professional | 0.7% (8/1112) | 0.8% (8/1051) | 0.0% (0/61) | | % Youth worker | 0.0% (0/1112) | 0.0% (0/1051) | 0.0% (0/61) | | % Other | 1.5% (17/1112) | 1.5% (16/1051) | 1.6% (1/61) | Figure 74: Percentage of children and young people diagnosed with epilepsy with input from various professionals in England and Wales. Performance indicator 1: Paediatrician with expertise in epilepsies
In Round 3 cohort 1, 87.9% (977/1112) of children and young people diagnosed with epilepsy, had input from a paediatrician with expertise in epilepsies in their first year of care, (Table 90). This is slightly higher than in Round 2, 86.1% (938/1090).
This indicator ranged from 20% to 100% and had an interquartile range of 84% to 100% at a Health Board and Trust level.
Table 90: Paediatrician with expertise in epilepsies.
| Performance indicator: 1 | Audit Round | England and Wales | England | Wales | |--------------------------|-------------|-------------------|---------|-------| | Paediatrician with expertise in epilepsies | % of children and young people with epilepsy, with input by a 'consultant paediatrician with expertise in epilepsies' within the first year of care | Round 1 | 78.0% (1183/1516) | 77.7% (1106/1423) | 82.8% (77/93) | | | | Round 2 | 86.1% (938/1090) | 86.1% (877/1019) | 85.9% (61/71) | | | | Round 3 | 87.9% (977/1112) | 87.9% (924/1051) | 86.9% (53/61) | Figure 75: Paediatrician with expertise in epilepsies by Health Board and Trust, Round 3, cohort 1.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Performance indicator 2: Epilepsy specialist nurse
NICE guidelines (Quality statement 5) state that children and young people with epilepsy are seen by an epilepsy specialist nurse who they can contact between scheduled reviews.
In Round 3, cohort 1, 69.0% (767/1112) of children and young people diagnosed with epilepsy, had input from an epilepsy specialist nurse (ESN) by one year, (Table 91). This is proportion is higher than Round 2. This indicator ranged from 0% to 100% and had an interquartile range of 58.0% to 100% at a Health Board or Trust level.
Table 91: Epilepsy specialist nurse
| Performance indicator: 2 | Audit Round | England and Wales | England | Wales | |--------------------------|-------------|-------------------|---------|-------| | Epilepsy specialist nurse | % of children and young people with epilepsy, with input by an epilepsy specialist nurse within the first year of care | Round 1 | 43.4% (658/1516) | 41.6% (592/1423) | 71.0% (66/93) | | | | Round 2 | 55.5% (605/1090) | 54.5% (555/1019) | 70.4% (50/71) | | | | Round 3 | 69.0% (767/1112) | 70.2% (738/1051) | 47.5% (29/61) |
Figure 76: Input from an ESN by Health Board and Trust, Round 3, cohort 1.
Each Health Board or Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Performance indicator 3: Tertiary input
In Round 3 cohort 1, 59.3% (150/253) of children and young people who met paediatric neurology referral criteria had paediatric neurologist input or Children’s Epilepsy Surgical service (CESS) referral by one year (Table 92). This is slightly higher than Round 2. This indicator ranged from 0% to 100% and had an interquartile range of 33% to 100% at Health Board or Trust level.
Table 92: Tertiary input.
| Performance indicator: 3 | Audit Round | England and Wales | England | Wales | |--------------------------|-------------|-------------------|---------|-------| | Tertiary input | | | | | | % of children and young people meeting defined criteria for paediatric neurology referral, with input of tertiary care and/or CESS referral within the first year of care | Round 1 | 59.1% (205/347) | 59.2% (200/338) | 55.6% (5/9) | | | Round 2 | 54.1% (119/220) | 53.7% (115/214) | 66.7% (4/6) | | | Round 3 | 59.3% (150/253) | 59.2% (142/240) | 61.5% (8/13) |
Figure 77: Tertiary input by Health Board and Trust, Round 3, cohort 1.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Ongoing investigations
Table 93 shows that in the first year of care for children and young people who were diagnosed with epilepsy in England and Wales:
- 20.2% (225/1112) had a formal development assessment,
- 7.0% (78/1112) had formal cognitive assessment.
Figure 78 shows the percentage of children and young people that had relevant ongoing assessment in England and Wales.
Table 93: Number of children and young people diagnosed with epilepsy with relevant ongoing investigation by country.
| Country | % with formal developmental assessment | % with formal cognitive assessment | |--------------------|----------------------------------------|----------------------------------| | England & Wales (N=1112) | 20.2% (225/1112) | 7.0% (78/1112) | | England (N=1051) | 21.1% (222/1051) | 7.4% (78/1051) | | Wales (N=61) | 4.9% (3/61) | 0.0% (0/61) |
Figure 78: Percentage of children and young people diagnosed with epilepsy with relevant ongoing investigation in England and Wales. Performance indicator 8: Accuracy of diagnosis
In Round 3, cohort 1, 97.2% (1093/1124) of children and young people had the same diagnosis by their first year of care, (Table 94). This proportion is higher than Round 2. This indicator ranged from 71.0% to 100% and had an interquartile range of 100% to 100% at a Health Board or Trust level.
Table 94: Accuracy of diagnosis
| Performance indicator 8 | Audit Round | England and Wales | England | Wales | |-------------------------|-------------|-------------------|---------|-------| | Accuracy of diagnosis | % of children diagnosed with epilepsy, who still had that diagnosis at one year | Round 1 | 88.1% (1516/1721) | 87.6% (1423/1624) | 95.9% (93/97) | | | | Round 2 | 93.2% (1077/1156) | 93.2% (1007/1080) | 92.1% (70/76) | | | | Round 3 | 97.2% (1093/1124) | 97.1% (1032/1063) | 100% (61/61) |
Figure 79: Accuracy of diagnosis by Health Board and Trust, Round 3, cohort 1.
Each Health Board and Trust is represented by a vertical bar in the order of the percentage score, including those scoring 0% in this graph. Overview of performance indicators
Rounds 1, 2 and 3, cohort 1
Table 95: Performance indicators by country across Rounds 1, 2 and 3, cohort 1
| Performance Indicators | Audit Round | England and Wales | England | Wales | |------------------------|-------------|-------------------|---------|-------| | 1 Paediatrician with expertise in epilepsies | Round 1 | 78.0% (1183/1516) | 77.7% (1106/1423) | 82.8% (77/93) | | | Round 2 | 86.1% (938/1090) | 86.1% (877/1019) | 85.9% (61/71) | | | Round 3 | 87.9% (977/1112) | 87.9% (924/1051) | 86.9% (53/61) | | 2 Epilepsy Specialist Nurse | Round 1 | 43.4% (658/1516) | 41.6% (592/1423) | 71.0% (66/93) | | | Round 2 | 55.5% (605/1090) | 54.5% (555/1019) | 70.4% (50/71) | | | Round 3 | 69.0% (767/1112) | 70.2% (738/1051) | 47.5% (29/61) | | 3 Tertiary input | Round 1 | 59.1% (205/347) | 59.2% (200/338) | 55.6% (5/9) | | | Round 2 | 54.1% (119/220) | 53.7% (115/214) | 66.7% (4/6) | | | Round 3 | 59.3% (150/253) | 59.2% (142/240) | 61.5% (8/13) | | 5 Seizure formulation | Round 1 | 86.9% (1318/1516) | 86.8% (1235/1423) | 89.2% (83/93) | | | Round 2 | 94.9% (1040/1096) | 95.5% (973/1019) | 94.4% (67/71) | | | Round 3 | 88.0% (979/1112) | 87.4% (919/1051) | 98.4% (60/61) | | 7 MRI | Round 1 | 63.5% (602/948) | 64.3% (578/899) | 49.0% (24/49) | | | Round 2 | 72.2% (481/666) | 72.7% (458/630) | 63.9% (23/36) | | | Round 3 | 68.6% (317/462) | 70.4% (307/436) | 38.5% (10/26) | | 8 Accuracy of diagnosis | Round 1 | 88.1% (1516/1721) | 87.6% (1423/1624) | 95.9% (93/97) | | | Round 2 | 93.2% (1077/1156) | 93.2% (1007/1080) | 92.1% (70/76) | | | Round 3 | 97.2% (1093/1124) | 97.1% (1032/1063) | 100% (61/61) | Figure 80: Epilepsy12 Performance indicators for England and Wales
The ‘whiskers’ on the chart above represent 95% confidence intervals. If these whiskers overlap, the difference in the achievement of the indicator is not statistically significant.
Figure 81: Epilepsy12 Performance indicators for England.
The ‘whiskers’ on the chart above represent 95% confidence intervals. If these whiskers overlap the difference in the achievement of the indicator is not statistically significant. Figure 82: Epilepsy12 Performance indicators for Wales
The ‘whiskers’ on the chart above represent 95% confidence intervals. If these whiskers overlap, the difference in the achievement of the indicator is not statistically significant.
Figure 83: Epilepsy12 Performance indicators by country, Round 3 cohort 1
The ‘whiskers’ on the chart above represent 95% confidence intervals. If these whiskers overlap the difference in the achievement of the indicator is not statistically significant. Figure 84: Epilepsy12 Performance indicators in England and Wales, Round 3, cohort 1 only Figure 85 below compares the organisational audit results of the epilepsy specialist nurses in the workforce with the clinical performance indicators. It sets out the performance indicators for Health Boards and Trusts which employed at least some level of whole time equivalent (WTE) epilepsy specialist nurse, versus Health Boards and Trusts with no whole time equivalent (WTE) epilepsy specialist nurse employed.
In Health Boards and Trusts with ESN provision, children and young people diagnosed with epilepsy were more likely to:
- be seen by an epilepsy specialist nurse,
- have individual healthcare plan,
- have an MRI.
Figure 85: Performance indicators for England and Wales by ESN provision
The ‘whiskers’ on the chart above represents 95% confidence intervals. If these whiskers do not overlap, the difference is statistically significant. Only three Health Boards and Trusts had females 9 years old and greater on sodium valproate hence performance indicator 9a was not included in this analysis. Appendix H: List of clinical data figures & tables
List of figures (clinical audit)
Figure 30: Percentage of children and young people verified by Health Boards and Trusts in Round 3 – page 8
Figure 31: The percentage of children and young people within cohort 1 with their first year of care form submitted and locked – page 9
Figure 32: Numbers of children and young people included in cohort 1 by age in years at first paediatric assessment and gender. – page 10
Figure 33: Numbers of children and young people included in cohort 1 by age in months at first paediatric assessment and gender. – page 11
Figure 34: Comparison of the proportion of children and young people by age group in Round 1, Round 2 and Round 3 – page 13
Figure 35: Percentage of children and young people in cohort 1 by deprivation in England and Wales combined – page 15
Figure 36: Percentage of children and young people in cohort 1 by deprivation by country/network – page 16
Figure 37: Percentage of children and young with/without prior experience of seizures – page 18
Figure 38: Percentage of children and young people in Cohort 1 by diagnostic status at first year of care, in England and Wales – page 20
Figure 39: Percentage of children and young people by diagnostic status in first paediatric assessment and first year of care in England and Wales – page 22
Figure 40: Diagnosis at first assessment and one year after first assessment in Round 1, Round 2, Round 3 – page 23
Figure 41: Percentage of children and young people by description of non-epileptic episode – page 24
Figure 42: Referring service to first paediatric assessment in England and Wales – page 25
Figure 43: Numbers of children and young people diagnosed with epilepsy by age in years at first paediatric assessment and gender in England and Wales – page 27
Figure 44: Setting of first paediatric assessment in Round 1, Round 2 and Round 3 in England and Wales – page 28
Figure 45: Appropriate first paediatric assessment by unit, Round 3 cohort 1 – page 30
Figure 46: Percentage of children and young people diagnosed with epilepsy who had focal onset seizures in England and Wales – page 32
Figure 47: Percentage of children and young people diagnosed with epilepsy who had generalised onset seizures in England and Wales – page 34
Figure 48: Percentage of children and young people diagnosed with epilepsy who had generalised onset seizures in England and Wales – page 36
Figure 49: Percentage of children and young people diagnosed with epilepsy that had unknown onset seizures in England and Wales. – page 37 Figure 50: Number of children and young people diagnosed with epilepsy by electroclinical syndrome in England and Wales. - page 38
Figure 51: Seizure formulation, by Health Board or Trust, Round 3. - page 40
Figure 52: Percentage of children and young people diagnosed with epilepsy who had structural seizure cause. - page 41
Figure 53: Percentage of children and young people diagnosed with epilepsy with/without no convulsive epileptic seizures in England and Wales. - page 42
Figure 54: Percentage of children and young people diagnosed with epilepsy by prolonged generalised convulsive epileptic seizures in England and Wales. - page 43
Figure 55: Percentage of children and young people diagnosed with epilepsy by prolonged focal convulsive epileptic seizures in England and Wales - page 44
Figure 56: Percentage of children and young people diagnosed with epilepsy with/without no family history of epilepsy in England and Wales. - page 45
Figure 57: Neurodisability/neurodevelopmental problems among children diagnosed with epilepsy in cohort 1. - page 48
Figure 58: Number of children diagnosed with epilepsy by mental health problem in England and Wales. - page 50
Figure 59: Percentage of children and young people diagnosed with epilepsy that obtained First EEG, 12 lead ECG, CT head scan and MRI brain investigations in England and Wales – page 53
Figure 60: Percentage of children and young people with convulsive seizures and epilepsy, with an ECG at first year by Health Board or Trust, Round 3. - page 55
Figure 61: Percentage of children and young people with defined indications for an MRI, who had MRI by first year by Health Board or Trust, Round 3 - page 57
Figure 62: Frequency by AED type in England and Wales (Round 3). - page 59
Figure 63: Number of children and young people diagnosed with epilepsy on sodium valproate by gender in England and Wales, Round 3 cohort 1. - page 60
Figure 64: Percentage females currently on sodium valproate treatment with evidence of discussion of foetal risk by Health Board or Trust, Round 3. - page 62
Figure 65: Percentage of children and young people diagnosed with epilepsy that had/did not have rescue medication prescribed in England and Wales. - page 63
Figure 66: Percentage of children and young people diagnosed with epilepsy that had rescue medication prescribed by country and network – page 63
Figure 67: Percentage of children and young people diagnosed with epilepsy that met/did not meet any CESS referral criteria in England and Wales. - page 64
Figure 68: Percentage of children and young people diagnosed with epilepsy that met any CESS referral criteria by country and network. - page 65
Figure 69: Comprehensive Care Planning agreement, Round 3. - page 69
Figure 70: Comprehensive Care Planning content by Health Board or Trust, Round 3. - page 71
Figure 71: School Individual Healthcare Plan, by Health Board or Trust, Round 3 – page 72
Figure 72: Percentage of children and young people diagnosed with Epilepsy with/without evidence of SUDEP information in England and Wales. - page 73
Figure 73: Percentage of children and young people diagnosed with evidence of SUDEP information by country and network. - page 73 Figure 74: Percentage of children and young people diagnosed with epilepsy with input from various professionals in England and Wales. – page 75
Figure 75: Paediatrician with expertise in epilepsies by Health Board or Trust, Round 3. – page 77
Figure 76: Epilepsy Specialist Nurse by Health Board or Trust, Round 3. – page 78
Figure 77: Tertiary input by Health Board or Trust, Round 3. – page 79
Figure 78: Percentage of children and young people diagnosed with epilepsy with relevant ongoing investigation in England and Wales. – page 80
Figure 79: Accuracy of diagnosis by Health Board or Trust, Round 3. – page 81
Figure 80: Epilepsy12 Performance indicators for England and Wales – page 83
Figure 81: Epilepsy12 Performance indicators for England – page 83
Figure 82: Epilepsy12 Performance indicators for Wales. – page 84
Figure 83: Epilepsy12 Performance indicators by country, Round 3 cohort 1 – page 84
Figure 84: Epilepsy12 Performance indicators in England and Wales, Round 3 cohort 1 only – page 85
Figure 85: Performance indicators for England and Wales by ESN provision – page 86
List of tables (clinical audit)
Table 47: Participation in Round 3 of Epilepsy12 – page 5
Table 48: Shows the flow of children and young people through the data capture system – page 6
Table 49: Number of children and young people registered as eligible for the audit. – page 7
Table 50: Number of children and young people in cohort 1 by country, network and age-group. – page 12
Table 51: Demographic characteristics of children included in Round 1, 2 and 3 of Epilepsy12. – page 13
Table 52: Percentage and number of children and young people in cohort 1 by deprivation by country and Open UK network. – page 14
Table 53: Prior experience of seizures in children and young people in cohort 1 in England and Wales. – page 17
Table 54: Diagnostic status at first year of care by country and Open UK network. – page 19
Table 55: Diagnostic status at first paediatric assessment by country and Open UK network. – page 21
Table 56: Description of non-epileptic episodes in children in cohort 1 at one year after first assessment in England and Wales – page 24
Table 57: Referring service to first paediatric assessment by country. – page 25
Table 58: Time in weeks to achieving input from paediatrician with expertise in epilepsy since the first referral to paediatrics by country. – page 26
Table 59: Setting of the first paediatric assessment by country. – page 28
Table 60: Appropriate first paediatric assessment. – page 29 Table 61: Number of seizures in children diagnosed with epilepsy by country. - page 31 Table 62: Seizure type. - page 31 Table 63: Epileptic seizure type. - page 32 Table 64: Percentage of children and young people diagnosed with epilepsy who had focal onset seizures in England and Wales. - page 33 Table 65: Percentage of children and young people diagnosed with epilepsy who had generalised onset seizures in England and Wales. - page 35 Table 66: Percentage of children and young people diagnosed with epilepsy who had unknown onset seizures in England and Wales. - page 36 Table 67: Seizure formulation. - page 39 Table 68: Percentage of children and young people diagnosed with epilepsy by seizure cause in England and Wales. - page 41 Table 69: Convulsive epileptic seizures in children and young people diagnosed with epilepsy by country - page 42 Table 70: Prolonged generalised convulsive epileptic seizures in children and young people diagnosed with epilepsy. - page 43 Table 71: Prolonged focal convulsive epileptic seizures in children and young people diagnosed with epilepsy by country. - page 44 Table 72: Family history of epilepsy in children and young people diagnosed with epilepsy by country. - page 45 Table 73: Neurodisability / neurodevelopmental problems among children diagnosed with epilepsy in Round 3. - page 47 Table 74: Percentage of severity of neurodevelopmental problems among the children and young people with intellectual disability, global development delay, or learning disability in England and Wales. - page 48 Table 75: Percentage of children and young people diagnosed with mental health problems in England and Wales. - page 49 Table 76: Percentage of children and young people between age 5-15 years and diagnosed with mental health condition that had ongoing investigations in England and Wales. - page 50 Table 77: Time in weeks to when EEG was obtained since EEG request date by country - page 51 Table 78: Number and percentage of children and young people diagnosed with epilepsy that obtained First EEG, 12 lead ECG, CT head scan and MRI brain investigations by country and OPEN UK network. - page 52 Table 79: Percentage of children and young people with convulsive seizures and epilepsy, with an ECG at first year. - 54 Table 80: Percentage of children and young people with defined indications for an MRI, who had MRI by first year - page 56 Table 81: Diagnosis and AEDs. - page 58 Table 82: Sodium Valproate in females. - page 61 Table 83: Epilepsy surgery referral. - page 66 Table 84: Time in weeks since referral to neurologist by country. - page 66 Table 85: Time in weeks since referral to neurologist by country. - page 67 Table 86: Comprehensive Care Planning agreement. - page 68 Table 87: Comprehensive Care Planning content. - page 70 Table 88: School Individual Healthcare Plan. - page 72 Table 89: Percentage of children and young people diagnosed with epilepsy with input from various professionals by Country. - page 74 Table 90: Paediatrician with expertise in epilepsies. - page 76 Table 91: Epilepsy Specialist Nurse. - page 78 Table 92: Tertiary input. - page 79 Table 93: Number of children and young people diagnosed with epilepsy with relevant ongoing investigation by country - page 80 Table 94: Accuracy of diagnosis - page 81 Table 95: Performance indicators by country across Rounds 1, 2 and 3 cohort 1 - page 82 Appendix I: Data completeness
Outlier identification and management
Epilepsy12 manages outlier status in line with the RCPCH policy Detection and Management of Outlier Status for Clinical Indicators in National Clinical Audits. The approach and timelines associated with Epilepsy12 are set out in a document entitled RCPCH management of outlier management policy for national clinical audits.
Preliminary outlier analysis against cohort 1 data was undertaken for three audit measures: children verified on the data platform, children with a locked first year of care record, children with epilepsy who saw a paediatrician with expertise in the first year of care. The data for children verified on the system and those seen by a specialist measures did not form a ‘normal’ distribution. This meant the planned analytical approach was unsuitable and we were unable to reliably identify outliers based on these measures. On the third measure, children with a complete year of care record, the relatively small dataset was a risk to identifying outliers with statistical validity.
Cohort 1 was based on a patient group who underwent a first paediatric assessment within a five-month period between July and November 2018. After piloting this outlier analysis with cohort 1, the outlier analysis for cohorts 2 and 3 will both be based on 12-month periods. Therefore we expect future datasets to be sufficiently robust to allow us to complete the full outlier analysis for these data.
Health Boards and Trusts in the results
Organisational audit
The Epilepsy12 project team originally identified 163 Health Boards and Trusts (acute, community and tertiary) with paediatric services across England and Wales in August 2017 as potentially eligible to participate in Round 3 of Epilepsy12. This was based on information from the 2017 British Association for Community Child Health (BACCH) and Royal College of Paediatrics and Child Health (RCPCH) publication “Covering all bases - Community Child Health: A paediatric workforce guide”.
Of the 163, one Health Board in Wales did not register and five acute Trusts in England were no longer eligible due to mergers. Nine of the remaining 157 were community Trusts which were excluded because they either had no paediatric services, or they defined their paediatric service as not assessing or managing children with seizures or epilepsies.
This left 148 registered Health Boards and Trusts, all of whom provided a submitted a full 2018 organisational audit submission for Round 3 of Epilepsy12 (including 100% of acute Trusts in England).
The 2019 Organisational audit saw the inclusion of Birmingham Community Healthcare NHS Foundation Trust which made 149 registered Health Boards and Trusts. There were eight separate Trusts mergers which meant a total of 141 of Health Boards and Trusts.
The following Health Boards and Trusts were not included within the 2019 organisational audit results:
| Health Board or Trust | Regional Network | |-----------------------------------------------------------|------------------| | 1 Brighton and Sussex University Hospitals NHS Trust\* | SETPEG | | 2 Cardiff & Vale University LHB\* | SWEP | | 3 Coventry and Warwickshire Partnership NHS Trust\* | BRPNF | | 4 Gloucestershire Hospitals NHS Foundation Trust | SWIPE | | 5 Leicestershire Partnership NHS Trust | CEWT | | 6 Maidstone and Tunbridge Wells NHS Trust\* | SETPEG | | 7 North East London NHS Foundation Trust\* | NTPEN | | 8 Plymouth Hospitals NHS Trust\* | SWIPE | | 9 Surrey and Sussex Healthcare NHS Trust\* | SWTPEG |
\*Trusts that were not included within the 2019 organisational results due to data that was either not submitted in time, or not ‘locked’ (a form of verification). Clinical audit
The following Trusts and Health Boards were not included within the 2018-2019 national clinical audit results:
| Health Board or Trust | Regional Network | |--------------------------------------------------------------------------------------|------------------| | 1 Aneurin Bevan LHB | SWEP | | 2 Barking, Havering and Redbridge University Hospitals NHS Trust | NTPEN | | 3 Barts Health NHS Trust | NTPEN | | 4 Basildon and Thurrock University Hospitals NHS Foundation Trust | NTPEN | | 5 Blackpool Teaching Hospitals NHS Foundation Trust | NWEIG | | 6 Brighton and Sussex University Hospitals NHS Trust\* | SETPEG | | 7 Burton Hospitals NHS Foundation Trust | BRPNF | | 8 Cambridge University Hospitals NHS Foundation Trust | EPEN | | 9 Cardiff & Vale University LHB\* | SWEP | | 10 Coventry and Warwickshire Partnership NHS Trust\* | BRPNF | | 11 Croydon Health Services NHS Trust | SWTPEG | | 12 East Cheshire NHS Trust | NWEIG | | 13 Epsom and St Helier University Hospitals NHS Trust | SWTPEG | | 14 George Eliot Hospital NHS Trust | BRPNF | | 15 *Great Ormond Street Hospital for Children NHS Foundation Trust | NTPEN | | 16 Guy's and St Thomas' NHS Foundation Trust | SETPEG | | 17 James Paget University Hospitals NHS Foundation Trust | EPEN | | 18 Leeds Community Healthcare NHS Trust | YPEN | | 19 Luton and Dunstable University Hospital NHS Foundation Trust | EPEN | | 20 Maidstone and Tunbridge Wells NHS Trust* | SETPEG | | 21 Medway NHS Foundation Trust | SETPEG | | 22 North East London NHS Foundation Trust\* | NTPEN | | 23 North Tees and Hartlepool NHS Foundation Trust | PENNEC | | 24 Northern Devon Healthcare NHS Trust | SWIPE | | 25 Plymouth Hospitals NHS Trust\* | SWIPE | | 26 Portsmouth Hospitals NHS Trust | WPNN | | 27 Sandwell and West Birmingham Hospitals NHS Trust | BRPNF | | 28 South Tyneside NHS Foundation Trust | PENNEC | | 29 Surrey and Sussex Healthcare NHS Trust\* | SWTPEG | | 30 Sussex Community NHS Foundation Trust | SETPEG | | 31 The Princess Alexandra Hospital NHS Trust | EPEN | | 32 The Queen Elizabeth Hospital, King’s Lynn, NHS Foundation Trust | EPEN | | 33 University Hospital Southampton NHS Foundation Trust | WPNN | | 34 University Hospitals Bristol NHS Foundation Trust | SWIPE | | 35 Weston Area Health NHS Trust | SWIPE | | 36 Yeovil District Hospital NHS Foundation Trust | SWIPE |
\*Tertiary Trust that does not conduct first assessments for children with epilepsy or seizures
\*Trusts that were not included within the 2019 organisational results due to data that was not submitted to the audit. Appendix J: Participating Health Boards and Trusts by OPEN UK region
The following list shows the NHS Health Boards and Trusts across England and Wales that submitted data to the Epilepsy12 Round 3 clinical and organisational audit in 2018-19.
| Birmingham Regional Paediatric Neurology Forum (BRPNF) | |--------------------------------------------------------| | Birmingham Community Healthcare NHS Foundation Trust | | Birmingham Women's and Children's NHS Foundation Trust | | Burton Hospitals NHS Foundation Trust\* | | Coventry and Warwickshire Partnership NHS Trust | | George Eliot Hospital NHS Trust | | Sandwell and West Birmingham Hospitals NHS Trust | | South Warwickshire NHS Foundation Trust | | The Dudley Group NHS Foundation Trust | | The Royal Wolverhampton NHS Trust | | University Hospitals Birmingham NHS Foundation Trust | | University Hospitals Coventry and Warwickshire NHS Trust | | Walsall Healthcare NHS Trust | | Worcestershire Acute Hospitals NHS Trust | | Worcestershire Health and Care NHS Trust | | Wye Valley NHS Trust |
| Children's Epilepsy Workstream in Trent (CEWT) | |-----------------------------------------------| | Derby Teaching Hospitals NHS Foundation Trust\* | | Leicestershire Partnership NHS Trust | | Nottingham University Hospitals NHS Trust | | Sherwood Forest Hospitals NHS Foundation Trust | | United Lincolnshire Hospitals NHS Trust | | University Hospitals of Leicester NHS Trust |
| Eastern Paediatric Epilepsy Network (EPEN) | |------------------------------------------| | Bedford Hospital NHS Trust | | Cambridge University Hospitals NHS Foundation Trust | | Cambridgeshire Community Services NHS Trust | | Colchester Hospital University NHS Foundation Trust\* | | East and North Hertfordshire NHS Trust | | Ipswich Hospital NHS Trust | |---------------------------| | James Paget University Hospitals NHS Foundation Trust | | Luton and Dunstable University Hospital NHS Foundation Trust | | Mid Essex Hospital Services NHS Trust | | Norfolk and Norwich University Hospitals NHS Foundation Trust | | Norfolk Community Health and Care NHS Trust | | North West Anglia NHS Foundation Trust | | The Princess Alexandra Hospital NHS Trust | | The Queen Elizabeth Hospital, King's Lynn, NHS Foundation Trust | | West Suffolk NHS Foundation Trust | | **Mersey and North Wales network 'Epilepsy In Childhood' interest group (EPIC)** | | Alder Hey Children's NHS Foundation Trust | | Betsi Cadwaladr University LHB | | Countess of Chester Hospital NHS Foundation Trust | | Mid Cheshire Hospitals NHS Foundation Trust | | Shrewsbury and Telford Hospital NHS Trust | | Southport and Ormskirk Hospital NHS Trust | | St Helens and Knowsley Hospitals NHS Trust | | Warrington and Halton Hospitals NHS Foundation Trust | | Wirral University Teaching Hospital NHS Foundation Trust | | **North Thames Paediatric Epilepsy Network (NTPEN)** | | Barking, Havering and Redbridge University Hospitals NHS Trust | | Barts Health NHS Trust | | Basildon and Thurrock University Hospitals NHS Foundation Trust | | Central and North West London NHS Foundation Trust | | Chelsea and Westminster Hospital NHS Foundation Trust | | Great Ormond Street Hospital For Children NHS Foundation Trust | | Homerton University Hospital NHS Foundation Trust | | Imperial College Healthcare NHS Trust | | London North West Healthcare NHS Trust | | North East London NHS Foundation Trust | | North Middlesex University Hospital NHS Trust | | Royal Free London NHS Foundation Trust | | Southend University Hospital NHS Foundation Trust | | The Hillingdon Hospitals NHS Foundation Trust | | The Whittington Hospital NHS Trust | | University College London Hospitals NHS Foundation Trust | | West Hertfordshire Hospitals NHS Trust | |----------------------------------------| | **North West Children and Young People’s Epilepsy Interest Group (NWEIG)** | | Blackpool Teaching Hospitals NHS Foundation Trust | | Bolton NHS Foundation Trust | | East Cheshire NHS Trust | | East Lancashire Hospitals NHS Trust | | Lancashire Teaching Hospitals NHS Foundation Trust | | Manchester University NHS Foundation Trust | | Northern Care Alliance NHS Group | | Salford Royal NHS Foundation Trust\* | | Stockport NHS Foundation Trust | | Tameside and Glossop Integrated Care NHS Foundation Trust | | University Hospitals of Morecambe Bay NHS Foundation Trust | | University Hospitals of North Midlands NHS Trust | | Wrightington, Wigan and Leigh NHS Foundation Trust | | **Oxford region epilepsy interest group (ORENG)** | | Buckinghamshire Healthcare NHS Trust | | Great Western Hospitals NHS Foundation Trust | | Kettering General Hospital NHS Foundation Trust | | Milton Keynes University Hospital NHS Foundation Trust | | Northampton General Hospital NHS Trust | | Oxford University Hospitals NHS Foundation Trust | | Royal Berkshire NHS Foundation Trust | | **Paediatric Epilepsy Network for the North East and Cumbria (PENNEC)** | | City Hospitals Sunderland NHS Foundation Trust\* | | County Durham and Darlington NHS Foundation Trust | | Gateshead Health NHS Foundation Trust | | North Cumbria University Hospitals NHS Trust | | North Tees and Hartlepool NHS Foundation Trust | | Northumbria Healthcare NHS Foundation Trust | | South Tees Hospitals NHS Foundation Trust | | South Tyneside NHS Foundation Trust\* | | The Newcastle Upon Tyne Hospitals NHS Foundation Trust | | **South East Thames Paediatric Epilepsy Group (SETPEG)** | | Brighton and Sussex University Hospitals NHS Trust | | Dartford and Gravesham NHS Trust | | East Kent : QEQM, Margate and WHM, Ashford, Kent | | East Sussex Healthcare NHS Trust | |----------------------------------| | Guy’s and St Thomas’ NHS Foundation Trust | | King’s College Hospital NHS Foundation Trust | | Lewisham and Greenwich NHS Trust | | Maidstone and Tunbridge Wells NHS Trust | | Medway NHS Foundation Trust | | Sussex Community NHS Foundation Trust | | **South Wales Epilepsy Forum (SWEP)** | | Abertawe Bro Morgannwg University LHB | | Aneurin Bevan LHB | | \*Cardiff & Vale University LHB | | Cwm Taf LHB | | Hywel Dda LHB | | **South West Interest Group Paediatric Epilepsy (SWIPE)** | | Gloucestershire Hospitals NHS Foundation Trust | | Northern Devon Healthcare NHS Trust | | Plymouth Hospitals NHS Trust | | Royal Cornwall Hospitals NHS Trust | | Royal Devon and Exeter NHS Foundation Trust | | Royal United Hospitals Bath NHS Foundation Trust | | Taunton and Somerset NHS Foundation Trust | | Torbay and South Devon NHS Foundation Trust | | University Hospitals Bristol NHS Foundation Trust | | Weston Area Health NHS Trust | | Yeovil District Hospital NHS Foundation Trust | | **South West Thames Paediatric Epilepsy Group (SWTPEG)** | | Ashford and St Peter's Hospitals NHS Foundation Trust | | Croydon Health Services NHS Trust | | Epsom and St Helier University Hospitals NHS Trust | | Frimley Health NHS Foundation Trust | | Kingston Hospital NHS Foundation Trust | | Royal Surrey County Hospital NHS Foundation Trust | | St George's University Hospitals NHS Foundation Trust | | Surrey and Sussex Healthcare NHS Trust | | **Trent Epilepsy Network (TEN)** | | Barnsley Hospital NHS Foundation Trust | | Chesterfield Royal Hospital NHS Foundation Trust | | Trusts | |----------------------------------------------------------------------| | Doncaster and Bassetlaw Teaching Hospitals Foundation Trust | | Northern Lincolnshire and Goole NHS Foundation Trust | | Sheffield Children's NHS Foundation Trust | | The Rotherham NHS Foundation Trust | | **Wessex Paediatric Neurosciences Network (WPNN)** | | Dorset County Hospital NHS Foundation Trust | | Hampshire Hospitals NHS Foundation Trust | | Isle of Wight NHS Trust | | Poole Hospital NHS Foundation Trust | | Portsmouth Hospitals NHS Trust | | Salisbury NHS Foundation Trust | | Solent NHS Trust | | University Hospital Southampton NHS Foundation Trust | | Western Sussex Hospitals NHS Foundation Trust | | **Yorkshire Paediatric Neurology Network (YPEN)** | | Airedale NHS Foundation Trust | | Bradford Teaching Hospitals NHS Foundation Trust | | Calderdale and Huddersfield NHS Foundation Trust | | Harrogate and District NHS Foundation Trust | | Hull and East Yorkshire Hospitals NHS Trust | | Leeds Community Healthcare NHS Trust | | Leeds Teaching Hospitals NHS Trust | | Mid Yorkshire Hospitals NHS Trust | | York Teaching Hospital NHS Foundation Trust |
The following Trusts merged prior to the November 2019 organisational audit.
| Trust mergers | |-------------------------------------------------------------------------------| | **East Suffolk and North Essex NHS Foundation Trust** (formerly Colchester Hospital University NHS Foundation Trust & Ipswich Hospital NHS Trust, merged July 2018) | | **Northern care Alliance** (Merged with Salford Royal NHS Foundation Trust, April 2017) | | **University Hospitals of Derby and Burton NHS Foundation Trust** (formerly Burton Hospitals NHS Foundation Trust & Derby Hospitals NHS Foundation Trust, merged July 2018) | | **South Tyneside and Sunderland NHS Foundation Trust** (formerly South Tyneside NHS Foundation Trust & City Hospitals Sunderland NHS Foundation Trust, merged April 2019) |
## Appendix K: Glossary of terms and abbreviations
| Term | Definition | |-------------------------------------------|-----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Absence seizure | A type of generalised seizure where the person briefly loses awareness and becomes blank or unresponsive. Absences often last a few seconds and the person is unconscious. If they are walking they might carry on walking. | | Acute | Inpatient review, or paediatric review in emergency department, or other clinical assessment in an acute paediatric setting | | Adherence | When someone takes their medication as they have agreed with their doctor. This is a more modern term than ‘compliance’ (doing what your doctor tells you to), and implies that there has been some discussion between the individual and their doctor to agree upon a plan of treatment. Whether someone is adherent or not is a measure of how closely they adhere (or ‘stick to’) taking their medication or treatment as agreed. | | Adverse events | Another term for ‘side effects’. These are effects of medication that happen alongside the effects you are expecting (the reason you are taking it). Side effects are usually, but not always, unwanted. | | AED (Anti-epileptic drug) | Anti-epileptic drugs (AEDs) are the main type of treatment for most people with epilepsy. AEDs are a type of medication that aims to stop seizures. There are many different AEDs and they work in different ways and stop different types of seizures. Up to 70% of people with epilepsy could have their seizures stopped with the right AEDs. | | Atonic or atonic seizure | A type of generalised seizure where the person’s muscles suddenly lose tone, go floppy, and they fall down (usually forwards) if they are standing up. Although the seizures themselves don’t hurt, the person might hurt themselves, especially their head and face, when they fall. These seizures are usually very brief and the person becomes conscious again very quickly. This is sometimes called a ‘drop attack’. | | BPT/BPC | Best Practice Tariff/Best Practice Criteria | | Children’s Epilepsy Specialist Nurse | A children’s nurse with a defined role and specific qualification and/or training in children’s epilepsies | Childhood epilepsy syndrome
Clonic seizures
Clusters
Complex focal seizures (CFS), Complex partial seizures (CPS)
Consultant General Paediatrician
Convulsive seizure Diazepam
ECG
ED Electroencephalogram (EEG)
Emergency medication
A type of epilepsy that happens in children and young people, and follows a particular, typical pattern: the age that the seizures start, the type of seizures, the EEG recording and the progression or outcome. Some syndromes are benign and either go away or have little impact on the child. Others are severe and can affect the child’s behaviour, learning and life expectancy. This is sometimes just referred to as a ‘syndrome’. These are seizures where the person convulses (jerks or shakes). Unlike tonic clonic seizures, the person does not go stiff at the start of the seizure. When a series or group of seizures happen close together in time, with gaps between each cluster. For example, in catamenial epilepsy, a woman might have a cluster of seizures around ovulation and no seizures at other times. Seizures that involve just part (not the whole) of the brain. These seizures used to be called 'complex partial seizures' or 'CPS'. The person will not be fully conscious and they are often very confused and may not remember what happens during the seizure. During CFS the person may behave strangely or make repetitive movements called automatisms. A paediatric consultant (or associate specialist) with a role that includes seeing children or young people in a general outpatient or community clinic setting. They may or may not have other specialty or acute roles. They are likely to receive referrals directly from primary care. Neonatologists would not be included in this definition unless they also fulfil general paediatric roles. A seizure where the person’s body jerks or shakes. It is another name for tonic clonic or clonic seizures. A type of sedative medication that is given to someone in status epilepticus to stop the seizures. Diazepam is given rectally (up the bottom). This is sometimes referred to as a type of 'emergency medication'. An electrocardiogram (ECG) is a simple test that can be used to check your heart's rhythm and electrical activity. Sensors attached to the skin are used to detect the electrical signals produced by your heart each time it beats. Emergency Department An electroencephalogram (EEG) is a recording of brain activity. During the test, small sensors are attached to the scalp to pick up the electrical signals produced when brain cells send messages to each other. These signals are recorded by a machine and are looked at by a doctor later to see if they're unusual. Medication that is given to stop prolonged or repeated seizures (to stop status epilepticus from happening). 101
| **Epilepsy** | A chronic neurological condition characterised by two or more epileptic seizures (International League Against Epilepsy, ILAE). A pragmatic definition for epilepsy in this audit is 2 or more epileptic seizures more than 24 hours apart that are not acute symptomatic seizures or febrile seizures. | | **Epilepsy surgery** | Different types of surgery on the brain to try to reduce or stop seizures. Some people with epilepsy, whose seizures are not controlled or significantly reduced with medication, are able to have epilepsy surgery. Also called neurosurgery. | | **Epilepsy syndrome** | A complex of clinical features, signs and symptoms that together define a distinctive, recognizable clinical disorder (ILAE) | | **‘Epilepsy syndrome category’** | A group of epilepsies described using the terms idiopathic primary, symptomatic, probably symptomatic and cryptogenic and focal, partial, multifocal or generalized | | **Epileptic seizure** | Seizures that start due to interrupted electrical activity in the brain but can affect the body in many different ways. Clinical manifestation(s) of epileptic (excessive and/or hypersynchronous), usually self-limited activity of neurons in the brain. (ILAE) | | **Febrile convulsions** | Convulsive seizures that can happen in young children (from about six months to six years of age) when they have a high temperature or fever. Febrile convulsions happen because very young children cannot control their body temperature very well. Although they can look like epileptic seizures they are not: they are caused by high temperatures not interrupted brain activity. | | **First paediatric assessment** | A ‘face to face’ assessment by a secondary level/tier doctor in a paediatric service occurring in any non-acute or acute setting. Assessment within emergency department counts if performed by paediatric team rather than an emergency department team. Some paediatric neurologists see referrals direct from GP or ED and these would count as both a first paediatric assessment and tertiary input | | **Focal seizures** | These are seizures that happen in, and affect, only part or one side of the brain (not both sides of the brain) and start from a ‘focal point’ in the brain. What happens in focal seizures varies depending on which part of the brain is affected and what that part of the brain normally does. Also known as ‘partial seizures’. | | **Frontal lobe seizures** | Focal seizures that start in the frontal lobe. Simple focal seizures from the frontal lobe include making strange movements or stiffness or jerking in part of the body such as the arm. Complex focal seizures from this area include making strange postures with the arms or legs or making juddering movements. | | **General examination** | Any evidence of a multisystem examination of the child other than neurological examination | |-------------------------|----------------------------------------------------------------------------------------------------------------------------------| | **General practitioners (GP)** | A doctor based in the community who treats patients with all common medical conditions with minor or chronic illnesses and refers those with serious conditions to a hospital for urgent and specialist treatment. They focus on the health of the whole person combining physical, psychological and social aspects of care. | | **Generalised seizures** | Seizures that happen in, and affect, the both sides of the brain from the start. There are many different types of generalised seizures, but they all involve the person becoming unconscious, even just for a few seconds, and they won't remember the seizure itself. The most well-known generalised seizure is the tonic clonic (convulsive) seizure. | | **Genetic** | The information in the DNA in our cells that controls our characteristics, for example hair colour, sex and height. | | **Handover clinic** | A clinic where a young people 'leaves the paediatric service and joins an adult service' and comprises both adult and paediatric health professionals | | **Infantile spasms (also called West Syndrome)** | A rare childhood epilepsy syndrome that starts in the first year of life. The child has brief jerks or spasms of the arms, legs or whole body, often in clusters. Some children have problems with learning or behaviour. | | **Input** | Any form of documented clinical contact including face to face clinical, written, electronic or telephone contact | | **Juvenile myoclonic epilepsy (JME)** | A type of childhood epilepsy syndrome that starts between the ages of 11 and 18 years. The person usually has myoclonic seizures when they are waking up and might also have absences and tonic clonic seizures. This syndrome usually responds well to medication. | | **Ketogenic diet** | A high fat, controlled protein, low carbohydrate diet that helps control seizures in some children with epilepsy. The diet works by encouraging the body to get energy from fat (rather than from carbohydrates). When this happens, the body produces chemicals called ketones which, for some children, help prevent seizures from happening. | | **Ketones** | Chemicals produced in the body when the body uses fat for energy. This happens in high-fat diets such as the ketogenic diet. Ketones can help prevent seizures from happening for some people. | | **Ketosis** | The process of producing ketones in the body, when the body uses fat for energy. | | **Magnetic resonance imaging (MRI)** | A type of scan that uses strong magnetic fields and radio waves to produce detailed images of the inside of the body. An MRI scanner is a large tube that contains powerful magnets | | **Midazolam** | A type of medication that is given to someone who is having prolonged or repeated seizures, to stop status | epilepticus from happening. Buccal means it is given into the mouth between the teeth and the cheek. Midazolam is a type of emergency medication.
| Myoclonic seizure | A type of generalised seizure where just part of the body (for example, a leg or arm) suddenly jerks. Myoclonic jerks often happen in clusters (several happening in a row) and often early in the morning. | |-------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | Neurodisability | Documented diagnosis including any of the following phrases indicating the diagnosis made by the assessing team:
- Autistic spectrum disorder
- Moderate, severe (or profound) learning difficulty or global development delay
- Cerebral palsy
- Neurodegenerative disease or condition
- An identified chromosomal disorder with a neurological or developmental component
- Attention deficit hyperactivity disorder (ADHD)
- Exclusions e.g. hypermobility, dyspraxia, specific learning difficulties e.g. (dyslexia, dyscalculia) | | Neurological examination | Any evidence of a neurological examination of the child | | Paediatrician with expertise | A paediatric consultant (or associate specialist) defined by themselves, their employer and tertiary service/network as having:
- training and continuing education in epilepsies
- AND peer review of practice
- AND regular audit of diagnosis (e.g. participation in Epilepsy12)\
(Consensus Conference on Better care for children and adults with epilepsy- Final Statement, Royal College of Physicians of Edinburgh,2002) A paediatric neurologist is also defined as a ‘paediatrician with expertise’. | | Parietal lobe seizures | Focal seizures that start in the parietal lobe. Simple focal seizures from the parietal lobe include feeling numb or tingling in part of the body, a burning sensation or feeling of heat, or feeling that parts of the body are bigger or smaller than they really are. Complex focal seizures from this area are rare. | | Partial seizures | Another name for ‘focal seizures’. There are seizures that happen in, and affect, only part of the brain (not both sides of the brain) and start from a ‘focal point’ in the brain. What happens in these seizures varies depending on which part of the brain is affected and what that part of the brain normally does. | | **Paroxysmal episodes** | This is the term chosen in this audit to represent the events causing concern. It includes all epileptic and non-epileptic seizures and also seizures of uncertain in origin. | |------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------| | **Psychiatrist** | A medically trained doctor who specialises in mental health problems. Psychiatrists are medically qualified and can prescribe medications. | | **Psychologist** | Someone who studies the way the mind works and how people behave. Clinical psychologists are trained to help people manage mental health and social problems and they cannot prescribe medications. | | **Refractory epilepsy**| Epilepsy that does not respond to AEDs (AEDs do not stop the seizures). This is also called intractable, drug-resistant or difficult to control epilepsy. | | **Rescue medication** | Medication that is given to a person when they are having prolonged or repeated seizures to stop status epilepticus from happening. It is usually either rectal diazepam or buccal midazolam. These are only given in an emergency: they are not the same as AEDs, which are taken every day to prevent seizures. | | **Risk assessment** | An assessment of someone's safety and possible risks. This might be at work, at home or any other area. Assessments look at risks to health and safety as well as ways to reduce risk, such as making reasonable adjustments or taking safety measures. | | **Secondarily generalised seizures** | Seizures that start as a focal seizure (in part of the brain) but the seizure activity spreads and affects the whole of the brain. In simple terms these are 'small seizures' that become 'big seizures'. The focal seizure start is sometimes called an 'aura' or 'seizure warning', and the seizure usually spreads to become a tonic clonic seizure. | | **Seizure** | A sudden, short-lived event that causes a change in the person's behaviour, awareness or consciousness. There are lots of different causes and types of seizures including epileptic seizures, hypoglycaemic (diabetic) seizures, non-epileptic seizures, syncope (fainting), and seizures caused by a heart problem. | | **Seizure control** | When seizures are completely stopped, and the person experiences no seizures anymore. This is usually achieved by taking AEDs. | | **Seizure-free** | When a person's seizures are fully controlled and stop happening (they don't have seizures anymore). | | **Severe Myoclonic Epilepsy in Infancy (SMEI) (also called Dravet Syndrome)** | A rare childhood epilepsy syndrome that starts in a child's first few years of life. The child has jerking seizures, usually on one side of the body. They may also be photosensitive. Learning, speech and general development may be affected. | | **SUDEP (Sudden Unexpected Death in Epilepsy)** | When a person with epilepsy suddenly dies and no reason for their death can be seen. | Symptomatic epilepsy
Syncope
'School age' Temporal lobe seizures
Tonic clonic seizure
Transition
Treatment plan
Vagus nerve
Vagus Nerve Stimulation (VNS)
Video telemetry
Epilepsy where there is a known physical cause of the person’s seizures. This could be due to a scar on the brain, an accident or head injury, or a stroke or brain tumour. Structural causes can often be seen on an MRI. When someone loses consciousness and collapses because the oxygen getting to their brain temporarily stops. This can be because of a drop-in blood pressure, a change in the heartbeat (and not enough blood is pumped through the heart), or because of a reduced amount of oxygen in the blood. Syncope is also another word for ‘faint’. Child 5 years and older (past their 5th birthday) Focal seizures that start in the temporal lobe. Simple focal seizures from the temporal lobe include an epigastric rising sensation, a sudden feeling of fear or joy or a funny taste or smell. A type of generalised seizure where the person stiffens (the ‘tonic’ part), falls down if they are standing, and then shakes, jerks or convulses (the ‘clonic’ part). When the management of someone's epilepsy moves ('transfers') from a paediatrician to an adult neurologist. Transition usually happens at around 16 - 18 years of age. A record of the number and types of AED taken, when to take them and what to do if they do not work or need adjusting or changing. This is also called a drug plan. The Vagus nerves connect to many different parts of the body and passes messages between the brain and various organs, including the throat, the heart, organs in the chest and abdomen. A type of treatment for epilepsy. It involves having a generator implanted in the chest wall attached to electrical wires around the Vagus nerve in the neck. The generator sends regular electrical signals through the Vagus nerve into the brain. For some people, this prevents or reduces the brain activity that causes seizures, and can reduce the number, length or severity of seizures they have. A test which involves having an EEG and being videotaped at the same time. This means that the EEG recording of a seizure can be compared to what is seen happening to the person. This can help to diagnose epilepsy and nonepileptic seizures.
106
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4d9b7f8e4d3c0ad891fc0d319d8e0c59220f6a6c | Appendix A: Epilepsy12 organisational audit results Epilepsy12
National Clinical Audit of Seizures and Epilepsies for Children and Young People
Combined organisational and clinical audits: Report for England and Wales, Round 3 Cohort 1 (2018-19)
The Healthcare Quality Improvement Partnership (HQIP) is led by a consortium of the Academy of Medical Royal Colleges, the Royal College of Nursing and National Voices. Its aim is to promote quality improvement in patient outcomes, and in particular, to increase the impact that clinical audit, outcome review programmes and registries have on healthcare quality in England and Wales. HQIP holds the contract to commission, manage and develop the National Clinical Audit and Patient Outcomes Programme (NCAPOP), comprising around 40 projects covering care provided to people with a wide range of medical, surgical and mental health conditions. The programme is funded by NHS England, the Welsh Government and, with some individual projects, other devolved administrations and crown dependencies. www.hqip.org.uk/national-programmes
© 2020 Healthcare Quality Improvement Partnership (HQIP)
Published by RCPCH September 2020.
The Royal College of Paediatrics and Child Health is a registered charity in England and Wales (1057744) and in Scotland (SCO38299). Appendices
The Epilepsy12 combined report for 2020 includes a description of key findings, recommendations, quality improvement activities, and patient involvement in Epilepsy12. It is available to download from Epilepsy12.
Appendix: Full Epilepsy12 clinical audit results for Round 3, Cohort 1 includes the publication of the clinical performance results and outcomes captured from Health Boards and Trusts with England and Wales. It is available to download from Epilepsy12.
Appendix A: Full Epilepsy12 Round 3 2019 organisational audit results Appendix B: Organisational findings by OPEN UK regional networks Appendix C: List of organisational data figures & tables Appendix D: Participating Health Boards and Trusts by OPEN UK region Appendix E: Data completeness Appendix F: Useful resources The 16 OPEN UK Regional Paediatric Epilepsy Networks are named in the following table. The abbreviated regional network names appear in the regional network results of both the clinical and organisational audits in this report.
| OPEN UK Regional Paediatric Epilepsy Network | Regional Network full name | |---------------------------------------------|-----------------------------| | BRPNF | Birmingham Regional Paediatric Neurology Forum | | CEWT | Children's Epilepsy Workstream in Trent | | EPEN | Eastern Paediatric Epilepsy Network | | EPIC | Mersey and North Wales network 'Epilepsy in Childhood' interest group | | NTPEN | North Thames Paediatric Epilepsy Network | | NWEIG | North West Children and Young People's Epilepsy Interest Group | | NI | Northern Ireland epilepsy services | | ORENG | Oxford Region Epilepsy Interest Group | | PENNEC | Paediatric Epilepsy Network for the North East and Cumbria | | SETPEG | South East Thames Paediatric Epilepsy Group | | SPEN | Scottish Paediatric Epilepsy Network | | SWEP | South Wales Epilepsy Forum | | SWIPE | South West Interest Group Paediatric Epilepsy | | SWTPEG | South West Thames Paediatric Epilepsy Group | | TEN | Trent Epilepsy Network | | WPNN | Wessex Paediatric Neurosciences Network | | YPEN | Yorkshire Paediatric Neurology Network | Appendix A: Full Epilepsy12 Round 3 2019 Organisational audit results
In this section, we present the full tables of results and figures, attributed by England and Wales combined, England, Wales and by each OPEN UK regional network, for each of the Epilepsy12 Round 3 Organisational audit measures.
For individual Health Board or Trust level results, please go to the Epilepsy12 website (www.rcpch.ac.uk/epilepsy12).
Paediatric epilepsy network names are abbreviated in the following tables of results and figures. The full names of the networks can be found on page 4 of this report.
Participation
Table 1 provides a breakdown of Epilepsy12 Round 3, 2019 Organisational audit participation by Paediatric Epilepsy Networks and by country.
- During the 2019 organisational audit, there were merges in eight Trusts in England, which resulted in four combined Trusts.
- There are 145 registered Health Boards and Trusts in Round 3 of Epilepsy12 (149 prior to the Trust merges).
- 136 out of 145 (93.8%) registered Health Boards and Trusts submitted and locked 2019 Organisational audit data. Table 1: Epilepsy12 Round 3 2019 Organisational Audit participation by Paediatric Epilepsy Networks and by country.
| Country/network | Number of registered T/HBs | Number of T/HBs that have submitted and locked 2019 organisational audit data | |-----------------|---------------------------|--------------------------------------------------------------------------------| | England & Wales | 145 | 93.8% (136/145) | | England | 139 | 94.2% (131/139) | | Wales | 6 | 83.3% (5/6) | | BRPNF | 14 | 92.9% (13/14) | | CEWT | 6 | 83.3% (5/6) | | EPEN | 14 | 100% (14/14) | | EPIC | 9 | 100% (9/9) | | NTPEN | 17 | 94.1% (16/17) | | NWEIG | 12 | 100% (12/12) | | ORENG | 7 | 100% (7/7) | | PENNEC | 8 | 100% (8/8) | | SETPEG | 11 | 72.7% (8/11) | | SWEP | 5 | 80.0% (4/5) | | SWIPE | 11 | 81.8% (9/11) | | SWTPEG | 7 | 100% (7/7) | | TEN | 6 | 100% (6/6) | | WPNN | 9 | 100% (9/9) | | YPEN | 9 | 100% (9/9) |
Workforce
Consultant paediatrician
The total whole time equivalent (WTE) for general paediatric consultants employed across England and Wales was 2146, (Table 2). There was a total of 308.7 whole time equivalent (WTE) paediatric consultants with 'expertise in epilepsy' employed across England and Wales; this represented 14.4% (308.7/2146) of the total WTE general paediatric (consultant or associate specialist) reported workforce, (Table 3). 93.4% (127/136) of Health Boards and Trusts did employ a consultant paediatrician with 'expertise in epilepsy', this ranged from 0.6 WTE to 12 WTE, (Table 4). 11.8% (16/136) of Health Boards and Trusts did not have a defined paediatric epilepsy clinical lead, (Table 5).
Figure 1 shows a comparison of the total whole time equivalent consultant paediatrician with expertise in epilepsy employed across England and Wales in Round 1, Round 2, Round 3 April 2018 and Round 3 November 2019. Figure 1: Total whole time equivalent consultant paediatrician with ‘expertise in epilepsy’ employed in England and Wales in Round 1, Round 2, Round 3 April 2018 and Round 3 November 2019.
### Table 2: Whole time equivalent (WTE) general paediatric consultants, community or hospital based, employed within Health Boards and Trusts.
| Country/network | Total WTE | Mean WTE | |-----------------|-----------|----------| | England and Wales (N=136) | 2146.0 | 15.8 | | England (N=131) | 2016.1 | 15.4 | | Wales (N=5) | 129.9 | 26.0 | | BRPNF (N=13) | 186.1 | 14.3 | | CEWT (N=5) | 114.7 | 22.9 | | EPEN (N=14) | 182.9 | 13.1 | | EPIC (N=9) | 116.1 | 12.9 | | NTPEN (N=16) | 266.8 | 16.7 | | NWEIG (N=12) | 227.0 | 18.9 | | ORENG (N=7) | 113.3 | 16.2 | | PENNEC (N=8) | 141.0 | 17.6 | | SETPEG (N=8) | 130.8 | 16.3 | | SWEP (N=4) | 98.9 | 24.7 | | SWIPE (N=9) | 107.3 | 11.9 | | SWTPEG (N=7) | 131.9 | 18.8 | | TEN (N=6) | 75.4 | 12.6 | | WPNN (N=9) | 113.9 | 12.7 | | YPEN (N=9) | 140.0 | 15.6 |
### Table 3: Whole time equivalent (WTE) general paediatric consultants with ‘expertise in epilepsy’, excluding paediatric neurologists, employed within Health Boards and Trusts.
| Country/network | Total WTE | Mean WTE | Min WTE | Max WTE | % of general paediatric workforce with ‘expertise in epilepsy’ | |-----------------|-----------|----------|---------|---------|---------------------------------------------------------------| | England and Wales (N=136) | 308.7 | 2.3 | 0.0 | 12.0 | 14.4% (308.7/2146.0) | | England (N=131) | 290.7 | 2.2 | 0.0 | 12.0 | 14.4% (290.7/2016.0) | | Wales (N=5) | 18.0 | 3.6 | 2.0 | 9.0 | 13.9% (18/129.9) | | BRPNF (N=13) | 23.6 | 1.8 | 0.0 | 4.5 | 12.7% (23.6/186.1) | | CEWT (N=5) | 13.5 | 2.7 | 0.0 | 7.0 | 11.8% (13.5/114.7) | | EPEN (N=14) | 23.8 | 1.7 | 0.0 | 4.0 | 13.0% (23.8/182.9) | | EPIC (N=9) | 24.5 | 2.7 | 0.0 | 9.0 | 21.1% (24.5/116.1) | | NTPEN (N=16) | 48.4 | 3.0 | 0.0 | 12.0 | 18.1% (48.4/266.8) | | NWEIG (N=12) | 23.5 | 2.0 | 1.0 | 5.0 | 10.3% (23.5/227.0) | | ORENG (N=7) | 13.5 | 1.9 | 1.0 | 5.0 | 11.9% (13.5/113.3) | | PENNEC (N=8) | 28.5 | 3.6 | 1.0 | 9.0 | 20.2% (28.5/141.0) | | SETPEG (N=8) | 17.4 | 2.2 | 1.0 | 3.9 | 13.3% (17.4/130.8) | | SWEP (N=4) | 9.0 | 2.3 | 2.0 | 3.0 | 9.1% (9.0/98.9) | | SWIPE (N=9) | 16.5 | 1.8 | 0.8 | 4.0 | 15.3% (16.5/107.3) | | SWTPEG (N=7) | 12.1 | 1.7 | 0.0 | 2.8 | 9.2% (12.1/131.9) | | TEN (N=6) | 12.8 | 2.1 | 1.8 | 3.0 | 17.0% (12.8/75.4) | | WPNN (N=9) | 17.0 | 1.9 | 0.0 | 3.8 | 14.9% (17.0/113.9) | | YPEN (N=9) | 24.8 | 2.8 | 1.0 | 11.2 | 17.7% (24.8/140.0) |
### Table 4: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) consultant paediatrician with ‘expertise in epilepsy’.
| Country/network | % with some WTE | % with no WTE | WTE range in T/HBs with some WTE | |-----------------|-----------------|---------------|---------------------------------| | England and Wales (N=136) | 93.4% (127/136) | 6.6% (9/136) | 0.6 - 12.0 | | England (N=131) | 93.1% (122/131) | 6.9% (9/131) | 0.6 - 12.0 | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | 2.0 - 9.0 | | BRPNF (N=13) | 92.3% (12/13) | 7.7% (1/13) | 1.0 - 4.5 | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | 2.0 - 7.0 | | EPEN (N=14) | 92.9% (13/14) | 7.1% (1/14) | 0.6 - 4.0 | | EPIC (N=9) | 88.9% (8/9) | 11.1% (1/9) | 1.0 - 9.0 | | NTPEN (N=16) | 87.5% (14/16) | 12.5% (2/16) | 1.0 - 12.0 | | NWEIG (N=12) | 100% (12/12) | 0.0% (0/12) | 1.0 - 5.0 | | ORENG (N=7) | 100% (7/7) | 0.0% (0/7) | 1.0 - 5.0 | | PENNEC (N=8) | 100% (8/8) | 0.0% (0/8) | 1.0 - 9.0 | | SETPEG (N=8) | 100% (8/8) | 0.0% (0/8) | 1.0 - 3.9 | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | 2.0 - 3.0 | | SWIPE (N=9) | 100% (9/9) | 0.0% (0/9) | 0.8 - 4.0 | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | 1.0 - 2.8 | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | 1.8 - 3.0 | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | 1.0 - 3.8 | | YPEN (N=9) | 100% (9/9) | 0.0% (0/9) | 1.0 - 11.2 |
### Table 5: Health Boards and Trusts that had a defined paediatric epilepsy clinical lead.
| Country/network | % with a defined lead | % with no defined lead | |-----------------|-----------------------|-----------------------| | England and Wales (N=136) | 88.2% (120/136) | 11.8% (16/136) | | England (N=131) | 88.5% (116/131) | 11.5% (15/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | | BRPNF (N=13) | 84.6% (11/13) | 15.4% (2/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | | EPEN (N=14) | 92.9% (13/14) | 7.1% (1/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | | NTPEN (N=16) | 87.5% (14/16) | 12.5% (2/16) | | NWEIG (N=12) | 100% (12/12) | 0.0% (0/12) | | ORENG (N=7) | 100% (7/7) | 0.0% (0/7) | | PENNEC (N=8) | 100% (8/8) | 0.0% (0/8) | | SETPEG (N=8) | 50.0% (4/8) | 50.0% (4/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 88.9% (8/9) | 11.1% (1/9) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | | WPNN (N=9) | 77.8% (7/9) | 22.2% (2/9) | | YPEN (N=9) | 88.9% (8/9) | 11.1% (1/9) | Epilepsy specialist nurse
There was a total of **158.4 WTE** epilepsy specialist nurses (ESN) employed across England and Wales. The ESNs were employed across **81.6% (111/136)** of Health Boards and Trusts. Of those with an ESN, the number employed ranged from **0.2 WTE** to **5.0 WTE**, (Table 7).
**Figure 2** shows a comparison of the total WTE for epilepsy specialist nurses (ESN) employed in England and Wales in Round 1, Round 2, Round 3 April 2018 and November 2019.
 Functions supported by epilepsy specialist nurses (all Health Boards or Trusts)
Figure 3 shows the percentage of Health Boards and Trusts supporting key ESN functions. 80.1% (109/136) of Health Boards and Trusts indicated that they could offer ESN support for rescue medication training for parents, 77.9% (106/136) could offer support in school meetings, 76.5% (104/136) provided individual healthcare plan facilitation and 67.6% (92/136) supported rescue medication training for schools. 55.9% (76/136) supported nurse led clinics, 46.3% (63/136) supported emergency department visits and 33.8% (46/136) were able to support nurse prescribing. 68.4% (93/136) were able to support home visits. 16.9% (23/136) were able to support all nine functions.
Figure 4 shows a comparison of the percentage of Health Boards and Trusts that supported various epilepsy specialist nurse functions in Round 3 April 2018 and November 2019.
Figure 3: Percentage of Health Boards and Trusts that could support epilepsy specialist nurse functions (n=136). Figure 4: Percentage of Health Boards and Trusts that could support epilepsy specialist nurse functions in Round 3 April 2018 and November 2019.
### Table 6: Whole time equivalent (WTE) epilepsy specialist nurses employed within Health Boards and Trusts.
| Country/network | Total WTE | Mean WTE | Min WTE | Max WTE | |-----------------|-----------|----------|---------|---------| | England and Wales (N=136) | 158.4 | 1.2 | 0.0 | 5.0 | | England (N=131) | 148.0 | 1.1 | 0.0 | 5.0 | | Wales (N=5) | 10.4 | 2.1 | 0.0 | 3.0 | | BRPNF (N=13) | 7.1 | 0.5 | 0.0 | 1.0 | | CEWT (N=5) | 6.8 | 1.4 | 0.0 | 2.0 | | EPEN (N=14) | 15.2 | 1.1 | 0.0 | 2.9 | | EPIC (N=9) | 13.1 | 1.5 | 0.3 | 3.6 | | NTPEN (N=16) | 18.8 | 1.2 | 0.0 | 3.7 | | NWEIG (N=12) | 18.1 | 1.5 | 0.0 | 5.0 | | ORENG (N=7) | 4.2 | 0.6 | 0.0 | 1.0 | | PENNEC (N=8) | 8.6 | 1.1 | 0.0 | 2.1 | | SETPEG (N=8) | 8.8 | 1.1 | 0.0 | 2.5 | | SWEP (N=4) | 8.0 | 2.0 | 0.0 | 3.0 | | SWIPE (N=9) | 6.5 | 0.7 | 0.0 | 2.0 | | SWTPEG (N=7) | 5.6 | 0.8 | 0.0 | 1.6 | | TEN (N=6) | 12.0 | 2.0 | 1.0 | 4.0 | | WPNN (N=9) | 10.4 | 1.2 | 0.0 | 2.1 | | YPEN (N=9) | 15.1 | 1.7 | 0.5 | 4.8 |
### Table 7: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) epilepsy specialist nurse.
| Country/network | % with some WTE | % with no WTE | WTE range in T/HBs with some WTE | |-----------------|-----------------|---------------|---------------------------------| | England and Wales (N=136) | 81.6% (111/136) | 18.4% (25/136) | 0.2 - 5.0 | | England (N=131) | 81.7% (107/131) | 18.3% (24/131) | 0.2 - 5.0 | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | 2.0 - 3.0 | | BRPNF (N=13) | 61.5% (8/13) | 38.5% (5/13) | 0.5 - 1.0 | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | 1.0 - 2.0 | | EPEN (N=14) | 85.7% (12/14) | 14.3% (2/14) | 0.2 - 2.9 | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | 0.3 - 3.6 | | NTPEN (N=16) | 81.3% (13/16) | 18.8% (3/16) | 0.4 - 3.7 | | NWEIG (N=12) | 91.7% (11/12) | 8.3% (1/12) | 0.6 - 5.0 | | ORENG (N=7) | 71.4% (5/7) | 28.6% (2/7) | 0.6 - 1.0 | | PENNEC (N=8) | 75.0% (6/8) | 25.0% (2/8) | 1.0 - 2.1 | | SETPEG (N=8) | 75.0% (6/8) | 25.0% (2/8) | 0.3 - 2.5 | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | 2.0 - 3.0 | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.3 - 2.0 | | SWTPEG (N=7) | 71.4% (5/7) | 28.6% (2/7) | 0.8 - 1.6 | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | 1.0 - 4.0 | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | 0.2 - 2.1 | | YPEN (N=9) | 100% (9/9) | 0.0% (0/9) | 0.5 - 4.8 | Table 8: Health Boards and Trusts that could support epilepsy nurse functions (n=136).
| Country/network | Home visits | Nurse led clinics | Emergency department visits | Ward visits | Nurse prescribing | School meetings | |-----------------|-------------|-------------------|-----------------------------|-------------|-------------------|-----------------| | England and Wales (N=136) | 68.4% (93/136) | 55.9% (76/136) | 46.3% (63/136) | 76.5% (104/136) | 33.8% (46/136) | 77.9% (106/136) | | England (N=131) | 68.7% (90/131) | 55.7% (73/131) | 48.1% (63/131) | 77.1% (101/131) | 34.4% (45/131) | 77.9% (102/131) | | Wales (N=5) | 60.0% (3/5) | 60.0% (3/5) | 0.0% (0/5) | 60.0% (3/5) | 20.0% (1/5) | 80.0% (4/5) | | BRPNF (N=13) | 38.5% (5/13) | 38.5% (5/13) | 30.8% (4/13) | 61.5% (8/13) | 30.8% (4/13) | 53.8% (7/13) | | CEWT (N=5) | 40.0% (2/5) | 80.0% (4/5) | 80.0% (4/5) | 80.0% (4/5) | 40.0% (2/5) | 80.0% (4/5) | | EPEN (N=14) | 57.1% (8/14) | 57.1% (8/14) | 71.4% (10/14) | 85.7% (12/14) | 21.4% (3/14) | 78.6% (11/14) | | EPIC (N=9) | 100% (9/9) | 55.6% (5/9) | 44.4% (4/9) | 100% (9/9) | 66.7% (6/9) | 100% (9/9) | | NWEIG (N=16) | 68.8% (11/16) | 56.3% (9/16) | 56.3% (9/16) | 81.3% (13/16) | 18.8% (3/16) | 68.8% (11/16) | | NWEIG (N=16) | 91.7% (11/12) | 58.3% (7/12) | 25.0% (3/12) | 91.7% (11/12) | 50.0% (6/12) | 91.7% (11/12) | | ORENG (N=7) | 71.4% (5/7) | 42.9% (3/7) | 57.1% (4/7) | 71.4% (5/7) | 14.3% (1/7) | 71.4% (5/7) | | PENNEC (N=8) | 62.5% (5/8) | 62.5% (5/8) | 50.0% (4/8) | 62.5% (5/8) | 50.0% (4/8) | 75.0% (6/8) | | SETPEG (N=8) | 75% (6/8) | 75.0% (6/8) | 50.0% (4/8) | 50.0% (4/8) | 12.5% (1/8) | 75.0% (6/8) | | SWEP (N=4) | 50.0% (2/4) | 50.0% (2/4) | 0.0% (0/4) | 50.0% (2/4) | 0.0% (0/4) | 75.0% (3/4) | | SWIPE (N=9) | 44.4% (4/9) | 33.3% (3/9) | 55.6% (5/9) | 66.7% (6/9) | 44.4% (4/9) | 55.6% (5/9) | | SWTPEG (N=7) | 71.4% (5/7) | 57.1% (4/7) | 28.6% (2/7) | 71.4% (5/7) | 28.6% (2/7) | 71.4% (5/7) | | TEN (N=6) | 100% (6/6) | 83.3% (5/6) | 66.7% (4/6) | 100% (6/6) | 50.0% (3/6) | 100% (6/6) | | WPNN (N=9) | 77.8% (7/9) | 44.4% (4/9) | 33.3% (3/9) | 77.8% (7/9) | 33.3% (3/9) | 88.9% (8/9) | | YPEN (N=9) | 77.8% (7/9) | 66.7% (6/9) | 33.3% (3/9) | 77.8% (7/9) | 44.4% (4/9) | 100% (9/9) | Table 8 (continued): Health Boards and Trusts that could support epilepsy nurse functions (n=136).
| Country/network | Individual HCP facilitation | Rescue medication training parents | Rescue medication training schools | Supporting all 9 functions | |-----------------|-----------------------------|-----------------------------------|-----------------------------------|---------------------------| | England and Wales (N=136) | 76.5% (104/136) | 80.1% (109/136) | 67.6% (92/136) | 16.9% (23/136) | | England (N=131) | 76.3% (100/131) | 80.2% (105/131) | 67.2% (88/131) | 17.6% (23/131) | | Wales (N=5) | 80.0% (4/5) | 80.0% (4/5) | 80.0% (4/5) | 0.0% (0/5) | | BRPNF (N=13) | 53.8% (7/13) | 61.5% (8/13) | 46.2% (6/13) | 15.4% (2/13) | | CEWT (N=5) | 80.0% (4/5) | 80.0% (4/5) | 60.0% (3/5) | 20.0% (1/5) | | EPEN (N=14) | 85.7% (12/14) | 85.7% (12/14) | 50.0% (7/14) | 14.3% (2/14) | | EPIC (N=9) | 100% (9/9) | 100% (9/9) | 100% (9/9) | 33.3% (3/9) | | NTPEN (N=16) | 75.0% (12/16) | 81.3% (13/16) | 56.3% (9/16) | 0.0% (0/16) | | NWEIG (N=12) | 91.7% (11/12) | 83.3% (10/12) | 83.3% (10/12) | 8.3% (1/12) | | ORENG (N=7) | 71.4% (5/7) | 71.4% (5/7) | 57.1% (4/7) | 0.0% (0/7) | | PENNEC (N=8) | 75.0% (6/8) | 75.0% (6/8) | 75.0% (6/8) | 37.5% (3/8) | | SETPEG (N=8) | 75.0% (6/8) | 75.0% (6/8) | 75.0% (6/8) | 12.5% (1/8) | | SWEP (N=4) | 75.0% (3/4) | 75.0% (3/4) | 75.0% (3/4) | 0.0% (0/4) | | SWIPE (N=9) | 55.6% (5/9) | 66.7% (6/9) | 66.7% (6/9) | 22.2% (2/9) | | SWTPEG (N=7) | 71.4% (5/7) | 71.4% (5/7) | 57.1% (4/7) | 28.6% (2/7) | | TEN (N=6) | 83.3% (5/6) | 100% (6/6) | 100% (6/6) | 33.3% (2/6) | | WPNN (N=9) | 77.8% (7/9) | 77.8% (7/9) | 44.4% (4/9) | 11.1% (1/9) | | YPEN (N=9) | 77.8% (7/9) | 100% (9/9) | 100% (9/9) | 33.3% (3/9) | Table 9: Health Boards and Trusts that could support epilepsy nurse functions (n=111). These are Health Boards and Trusts that had employed some level of ESN.
| Country/network | Home visits | Nurse led clinics | Emergency department visits | Ward visits | Nurse prescribing | School meetings | |-----------------|-------------|-------------------|-----------------------------|-------------|-------------------|-----------------| | England and Wales (N=111) | 83.8% (93/111) | 68.5% (76/111) | 56.8% (63/111) | 93.7% (104/111) | 41.4% (46/111) | 95.5% (106/111) | | England (N=107) | 84.1% (90/107) | 68.2% (73/107) | 58.9% (63/107) | 94.4% (101/107) | 42.1% (45/107) | 95.3% (102/107) | | Wales (N=4) | 75.0% (3/4) | 75.0% (3/4) | 0.0% (0/4) | 75.0% (3/4) | 25.0% (1/4) | 100% (4/4) | | BRPNF (N=8) | 62.5% (5/8) | 62.5% (5/8) | 50.0% (4/8) | 100% (8/8) | 50.0% (4/8) | 87.5% (7/8) | | CEWT (N=4) | 50.0% (2/4) | 100% (4/4) | 100% (4/4) | 100% (4/4) | 50.0% (2/4) | 100% (4/4) | | EPEN (N=12) | 66.7% (8/12) | 66.7% (8/12) | 83.3% (10/12) | 100% (12/12) | 25.0% (3/12) | 91.7% (11/12) | | EPIC (N=9) | 100% (9/9) | 55.6% (5/9) | 44.4% (4/9) | 100% (9/9) | 66.7% (6/9) | 100% (9/9) | | NTPEN (N=13) | 84.6% (11/13) | 69.2% (9/13) | 69.2% (9/13) | 100% (13/13) | 23.1% (3/13) | 84.6% (11/13) | | NWEIG (N=11) | 100% (11/11) | 63.6% (7/11) | 27.3% (3/11) | 100% (11/11) | 54.5% (6/11) | 100% (11/11) | | ORENG (N=5) | 100% (5/5) | 60.0% (3/5) | 80.0% (4/5) | 100% (5/5) | 20.0% (1/5) | 100% (5/5) | | PENNEC (N=6) | 83.3% (5/6) | 83.3% (5/6) | 66.7% (4/6) | 83.3% (5/6) | 66.7% (4/6) | 100% (6/6) | | SETPEG (N=6) | 100% (6/6) | 100% (6/6) | 66.7% (4/6) | 66.7% (4/6) | 16.7% (1/6) | 100% (6/6) | | SWEP (N=3) | 66.7% (2/3) | 66.7% (2/3) | 0.0% (0/3) | 66.7% (2/3) | 0.0% (0/3) | 100% (3/3) | | SWIPE (N=6) | 66.7% (4/6) | 50.0% (3/6) | 83.3% (5/6) | 100% (6/6) | 66.7% (4/6) | 83.3% (5/6) | | SWTPEG (N=5) | 100% (5/5) | 80.0% (4/5) | 40.0% (2/5) | 100% (5/5) | 40.0% (2/5) | 100% (5/5) | | TEN (N=6) | 100% (6/6) | 83.3% (5/6) | 66.7% (4/6) | 100% (6/6) | 50.0% (3/6) | 100% (6/6) | | WPNN (N=8) | 87.5% (7/8) | 50.0% (4/8) | 37.5% (3/8) | 87.5% (7/8) | 37.5% (3/8) | 100% (8/8) | | YPEN (N=9) | 77.8% (7/9) | 66.7% (6/9) | 33.3% (3/9) | 77.8% (7/9) | 44.4% (4/9) | 100% (9/9) | Table 9 (continued): Health Boards and Trusts that could support epilepsy nurse functions (n=111). These are Health Boards and Trusts that had employed some level of ESN
| Country/network | Individual HCP facilitation | Rescue medication training with parents | Rescue medication training in schools | Supporting all 9 functions | |-----------------|-----------------------------|----------------------------------------|--------------------------------------|---------------------------| | England and Wales (N=111) | 93.7% (104/111) | 98.2% (109/111) | 82.9% (92/111) | 20.7% (23/111) | | England (N=107) | 93.5% (100/107) | 98.1% (105/107) | 82.2% (88/107) | 21.5% (23/107) | | Wales (N=4) | 100% (4/4) | 100% (4/4) | 100% (4/4) | 0.0% (0/4) | | BRPNF (N=8) | 87.5% (7/8) | 100% (8/8) | 75.0% (6/8) | 25.0% (2/8) | | CEWT (N=4) | 100% (4/4) | 100% (4/4) | 75.0% (3/4) | 25.0% (1/4) | | EPEN (N=12) | 100% (12/12) | 100% (12/12) | 58.3% (7/12) | 16.7% (2/12) | | EPIC (N=9) | 100% (9/9) | 100% (9/9) | 100% (9/9) | 33.3% (3/9) | | NTPEN (N=13) | 92.3% (12/13) | 100% (13/13) | 69.2% (9/13) | 0.0% (0/13) | | NWEIG (N=11) | 100% (11/11) | 90.9% (10/11) | 90.9% (10/11) | 9.1% (1/11) | | ORENG (N=5) | 100% (5/5) | 100% (5/5) | 80.0% (4/5) | 0.0% (0/5) | | PENNEC (N=6) | 100% (6/6) | 100% (6/6) | 100% (6/6) | 50.0% (3/6) | | SETPEG (N=6) | 100% (6/6) | 100% (6/6) | 100% (6/6) | 16.7% (1/6) | | SWEP (N=3) | 100% (3/3) | 100% (3/3) | 100% (3/3) | 0.0% (0/3) | | SWIPE (N=6) | 83.3% (5/6) | 100% (6/6) | 100% (6/6) | 33.3% (2/6) | | SWTPEG (N=5) | 100% (5/5) | 100% (5/5) | 80.0% (4/5) | 40.0% (2/5) | | TEN (N=6) | 83.3% (5/6) | 100% (6/6) | 100% (6/6) | 33.3% (2/6) | | WPNN (N=8) | 87.5% (7/8) | 87.5% (7/8) | 50.0% (4/8) | 12.5% (1/8) | | YPEN (N=9) | 77.8% (7/9) | 100% (9/9) | 100% (9/9) | 33.3% (3/9) | Clinic configuration
Defined epilepsy clinic
89.7% (122/136) of Health Boards and Trusts had a defined epilepsy clinic seeing patients at secondary level, (Table 10). 87.7% (107/122) of Health Boards and Trusts holding defined epilepsy clinics allowed at least 20 minutes with a consultant with expertise in epilepsy and an ESN, either simultaneously or in succession, (Table 12). A total of 252.9 consultant or associate specialist led secondary level ‘epilepsy clinics’ took place each week across England and Wales. The mean number of consultant or associate specialist clinics taking place per week was 2.1 (range 0–6), (Table 11).
Figure 5 shows a comparison of the total number of consultant or associate specialist led secondary level epilepsy clinics in Round 1, Round 2, Round 3 April 2018 and November 2019.
Figure 5: Total number of consultant or associate specialist led secondary level epilepsy clinics in Round 1, Round 2, Round 3 April 2018 and November 2019. Table 10: Health Boards and Trusts that had a defined epilepsy clinic.
| Country/network | % with a defined epilepsy clinic | % with no defined epilepsy clinic | |-----------------|----------------------------------|----------------------------------| | England and Wales (N=136) | 89.7% (122/136) | 10.3% (14/136) | | England (N=131) | 89.3% (117/131) | 10.7% (14/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 69.2% (9/13) | 30.8% (4/13) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | | EPEN (N=14) | 85.7% (12/14) | 14.3% (2/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | | NTPEN (N=16) | 87.5% (14/16) | 12.5% (2/16) | | NWEIG (N=12) | 100% (12/12) | 0.0% (0/12) | | ORENG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | PENNEC (N=8) | 100% (8/8) | 0.0% (0/8) | | SETPEG (N=8) | 87.5% (7/8) | 12.5% (1/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 77.8% (7/9) | 22.2% (2/9) | | SWTPEG (N=7) | 100% (7/7) | 0.0% (0/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | | YPEN (N=9) | 88.9% (8/9) | 11.1% (1/9) | Table 11: Number of consultant or associate specialist led secondary level 'epilepsy clinics' taking place within Health Boards and Trusts per week.
| Country/network | Total no. clinics per week | Mean no. clinics per week | Min no. clinics per week | Max no. clinics per week | |-----------------|---------------------------|---------------------------|--------------------------|--------------------------| | England and Wales (N=122) | 252.9 | 2.1 | 0.0 | 6.0 | | England (N=117) | 237.7 | 2.0 | 0.0 | 6.0 | | Wales (N=5) | 15.2 | 3.0 | 1.5 | 4.7 | | BRPNF (N=9) | 13.9 | 1.5 | 1.0 | 3.0 | | CEWT (N=5) | 12.0 | 2.4 | 1.0 | 4.5 | | EPEN (N=12) | 23.9 | 2.0 | 0.6 | 4.5 | | EPIC (N=9) | 19.1 | 2.1 | 0.5 | 4.7 | | NTPEN (N=14) | 29.9 | 2.1 | 0.8 | 4.0 | | NWEIG (N=12) | 26.3 | 2.2 | 1.0 | 4.5 | | ORENG (N=6) | 9.2 | 1.5 | 0.8 | 3.0 | | PENNEC (N=8) | 15.3 | 1.9 | 0.5 | 4.0 | | SETPEG (N=7) | 20.0 | 2.9 | 1.3 | 6.0 | | SWEP (N=4) | 10.5 | 2.6 | 1.5 | 4.0 | | SWIPE (N=7) | 9.2 | 1.3 | 0.0 | 2.3 | | SWTPEG (N=7) | 17.5 | 2.5 | 1.0 | 4.5 | | TEN (N=6) | 9.5 | 1.6 | 0.5 | 2.0 | | WPNN (N=8) | 19.3 | 2.4 | 0.5 | 4.8 | | YPEN (N=8) | 17.6 | 2.2 | 0.5 | 3.0 | Table 12: Defined epilepsy clinics that allowed at least 20 minutes with a consultant with ‘expertise in epilepsy’ and/or an epilepsy specialist nurse.
| Country/network | % with a defined epilepsy clinic | % with no defined epilepsy clinic | |-----------------|----------------------------------|----------------------------------| | England and Wales (N=122) | 87.7% (107/122) | 12.3% (15/122) | | England (N=117) | 87.2% (102/117) | 12.8% (15/117) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=9) | 88.9% (8/9) | 11.1% (1/9) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | | EPEN (N=12) | 91.7% (11/12) | 8.3% (1/12) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | | NTPEN (N=14) | 71.4% (10/14) | 28.6% (4/14) | | NWEiG (N=12) | 100% (12/12) | 0.0% (0/12) | | ORENG (N=6) | 83.3% (5/6) | 16.7% (1/6) | | PENNEC (N=8) | 62.5% (5/8) | 37.5% (3/8) | | SETPEG (N=7) | 100% (7/7) | 0.0% (0/7) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=7) | 85.7% (6/7) | 14.3% (1/7) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | | WPNN (N=8) | 87.5% (7/8) | 12.5% (1/8) | | YPEN (N=8) | 75.0% (6/8) | 25.0% (2/8) | Epilepsy Best Practice Tariff (BPC) – England only
Figure 6 shows 46.6% (61/131) of Trusts in England were running an Epilepsy Best Practice Tariff (BPC) service. 26.0% (34/131) Trusts were working toward BPT, 20.6% (27/131) were not running a BPT service whilst 6.9% (9/131) reported that this was not applicable, (Table 13).
Figure 7 shows a comparison of the percentage of Trusts running a BPT epilepsy service in Round 3 April 2018 and November 2019.
Figure 6: Percentage of Trusts receiving TFC 223 Epilepsy Best Practice Criteria (England only) (n=131)
Figure 7: Percentage of Trusts receiving TFC 223 Epilepsy Best Practice Criteria (England only) in Round 3 April 2018 and November 2019. Table 13: Trusts that were running TFC 223 Epilepsy Best Practice Criteria (BPC) clinics.
| Country/network | Yes | In development | No | N/A | |-----------------|-----------|----------------|-----------|-----------| | England (N=131) | 46.6% (61/131) | 26.0% (34/131) | 20.6% (27/131) | 6.9% (9/131) | | BRPNF (N=13) | 30.8% (4/13) | 30.8% (4/13) | 38.5% (5/13) | 0.0% (0/13) | | CEWT (N=5) | 60.0% (3/5) | 0.0% (0/5) | 20.0% (1/5) | 20.0% (1/5) | | EPEN (N=14) | 50.0% (7/14) | 21.4% (3/14) | 14.3% (2/14) | 14.3% (2/14) | | EPIC (N=8) | 37.5% (3/8) | 50.0% (4/8) | 12.5% (1/8) | 0.0% (0/8) | | NTPEN (N=16) | 31.3% (5/16) | 31.3% (5/16) | 25.0% (4/16) | 12.5% (2/16) | | NWEIG (N=12) | 41.7% (5/12) | 33.3% (4/12) | 25.0% (3/12) | 0.0% (0/12) | | ORENG (N=7) | 57.1% (4/7) | 0.0% (0/7) | 42.9% (3/7) | 0.0% (0/7) | | PENNEC (N=8) | 50.0% (4/8) | 37.5% (3/8) | 12.5% (1/8) | 0.0% (0/8) | | SETPEG (N=8) | 37.5% (3/8) | 12.5% (1/8) | 37.5% (3/8) | 12.5% (1/8) | | SWIPE (N=9) | 44.4% (4/9) | 22.2% (2/9) | 33.3% (3/9) | 0.0% (0/9) | | SWTPEG (N=7) | 57.1% (4/7) | 28.6% (2/7) | 14.3% (1/7) | 0.0% (0/7) | | TEN (N=6) | 66.7% (4/6) | 33.3% (2/6) | 0.0% (0/6) | 0.0% (0/6) | | WPNN (N=9) | 66.7% (6/9) | 11.1% (1/9) | 0.0% (0/9) | 22.2% (2/9) | | YPEN (N=9) | 55.6% (5/9) | 33.3% (3/9) | 0.0% (0/9) | 11.1% (1/9) |
Tertiary provision
Paediatric neurology services
A total of 109.4 WTE consultant paediatric neurologists responsible for managing the care of children and young people with epilepsy, both acutely and non-acutely, were employed across England and Wales, (Table 14). 16.9% (23/136) of Health Boards and Trusts had some level of whole time equivalent (WTE) paediatric neurologists who manage children with epilepsy (acutely and/or non-acutely) employed (this ranged from 0.6 WTE to 10.6 WTE, (Table 15). Table 16 shows, 92.6% (126/136) of Health Boards and Trusts had agreed referral pathway to tertiary paediatric neurology services. 23.5% (32/136) of Health Boards and Trusts reported that paediatric neurologists could receive direct referrals from general practice or emergency services to assess children with possible epilepsy, (Table 17a). 73.5% (100/136) of Health Boards and Trusts reported that they host satellite paediatric neurology clinics, (Table 18).
### Table 14: Whole time equivalent (WTE) paediatric neurologists, acutely and/or non-acutely, employed within Health Boards or Trusts.
| Country/network | Total WTE | Min WTE | Max WTE | |-----------------|-----------|---------|---------| | England and Wales (N=136) | 109.4 | 0.0 | 10.6 | | England (N=131) | 108.8 | 0.0 | 10.6 | | Wales (N=5) | 0.6 | 0.0 | 0.6 | | BRPNF (N=13) | 7.0 | 0.0 | 7.0 | | CEWT (N=5) | 5.5 | 0.0 | 3.0 | | EPEN (N=14) | 4.4 | 0.0 | 4.4 | | EPIC (N=9) | 5.2 | 0.0 | 5.2 | | NTPEN (N=16) | 26.6 | 0.0 | 10.6 | | NWEIG (N=12) | 9.2 | 0.0 | 7.2 | | ORENG (N=7) | 5.7 | 0.0 | 5.7 | | PENNEC (N=8) | 5.7 | 0.0 | 4.7 | | SETPEG (N=8) | 6.6 | 0.0 | 3.6 | | SWEP (N=4) | 0.6 | 0.0 | 0.6 | | SWIPE (N=9) | 7.0 | 0.0 | 7.0 | | SWTPEG (N=7) | 3.0 | 0.0 | 3.0 | | TEN (N=6) | 10.0 | 0.0 | 5.0 | | WPNN (N=9) | 6.5 | 0.0 | 6.5 | | YPEN (N=9) | 6.4 | 0.0 | 6.4 |
### Table 15: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) paediatric neurologists, acutely and/or non-acutely.
| Country/network | % with some WTE | % with no WTE | WTE range in T/HBs with some WTE | |-----------------|-----------------|---------------|---------------------------------| | England and Wales (N=136) | 16.9% (23/136) | 83.1% (113/136) | 0.6 - 10.6 | | England (N=131) | 16.8% (22/131) | 83.2% (109/131) | 1.0 - 10.6 | | Wales (N=5) | 20.0% (1/5) | 80.0% (4/5) | 0.6 - 0.6 | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | 7.0 - 7.0 | | CEWT (N=5) | 40.0% (2/5) | 60.0% (3/5) | 2.5 - 3.0 | | EPEN (N=14) | 7.1% (1/14) | 92.9% (13/14) | 4.4 - 4.4 | | EPIC (N=9) | 11.1% (1/9) | 88.9% (8/9) | 5.2 - 5.2 | | NTPEN (N=16) | 25.0% (4/16) | 75.0% (12/16) | 3.0 - 10.6 | | NWEIG (N=12) | 16.7% (2/12) | 83.3% (10/12) | 2.0 - 7.2 | | ORENG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 5.7 - 5.7 | | PENNEC (N=8) | 25.0% (2/8) | 75.0% (6/8) | 1.0 - 4.7 | | SETPEG (N=8) | 25.0% (2/8) | 75.0% (6/8) | 3.0 - 3.6 | | SWEP (N=4) | 25.0% (1/4) | 75.0% (3/4) | 0.6 - 0.6 | | SWIPE (N=9) | 11.1% (1/9) | 88.9% (8/9) | 7.0 - 7.0 | | SWTPEG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 3.0 - 3.0 | | TEN (N=6) | 33.3% (2/6) | 66.7% (4/6) | 5.0 - 5.0 | | WPNN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 6.5 - 6.5 | | YPEN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 6.4 - 6.4 |
### Table 16: Health Boards and Trusts with agreed referral pathways to tertiary paediatric neurology services.
| Country/network | Yes | No | |-----------------|--------------|-------------| | England and Wales (N=136) | 92.6% (126/136) | 7.4% (10/136) | | England (N=131) | 93.1% (122/131) | 6.9% (9/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | | BRPNF (N=13) | 76.9% (10/13) | 23.1% (3/13) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | | EPEN (N=14) | 100% (14/14) | 0.0% (0/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | | NTPEN (N=16) | 100% (16/16) | 0.0% (0/16) | | NWEIG (N=12) | 91.7% (11/12) | 8.3% (1/12) | | ORENG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | PENNEC (N=8) | 87.5% (7/8) | 12.5% (1/8) | | SETPEG (N=8) | 100% (8/8) | 0.0% (0/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 88.9% (8/9) | 11.1% (1/9) | | SWTPEG (N=7) | 100% (7/7) | 0.0% (0/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | | YPEN (N=9) | 88.9% (8/9) | 11.1% (1/9) |
### Table 17a: Health Boards and Trusts that could receive paediatric neurological direct referrals from general practice and emergency departments.
| Country/network | Yes | No | N/A | |-----------------|--------------|-------------|--------------| | England and Wales (N=136) | 23.5% (32/136) | 50.0% (68/136) | 26.5% (36/136) | | England (N=131) | 22.9% (30/131) | 50.4% (66/131) | 26.7% (35/131) | | Wales (N=5) | 40.0% (2/5) | 40.0% (2/5) | 20.0% (1/5) | | BRPNF (N=13) | 7.7% (1/13) | 23.1% (3/13) | 69.2% (9/13) | | CEWT (N=5) | 20.0% (1/5) | 20.0% (1/5) | 60.0% (3/5) | | EPEN (N=14) | 0.0% (0/14) | 100% (14/14) | 0.0% (0/14) | | EPIC (N=9) | 22.2% (2/9) | 33.3% (3/9) | 44.4% (4/9) | | NTPEN (N=16) | 18.8% (3/16) | 56.3% (9/16) | 25.0% (4/16) | | NWEIG (N=12) | 33.3% (4/12) | 66.7% (8/12) | 0.0% (0/12) | | ORENG (N=7) | 42.9% (3/7) | 57.1% (4/7) | 0.0% (0/7) | | PENNEC (N=8) | 25.0% (2/8) | 62.5% (5/8) | 12.5% (1/8) | | SETPEG (N=8) | 37.5% (3/8) | 25.0% (2/8) | 37.5% (3/8) | | SWEP (N=4) | 25.0% (1/4) | 50.0% (2/4) | 25.0% (1/4) | | SWIPE (N=9) | 22.2% (2/9) | 44.4% (4/9) | 33.3% (3/9) | | SWTPEG (N=7) | 14.3% (1/7) | 71.4% (5/7) | 14.3% (1/7) | | TEN (N=6) | 66.7% (4/6) | 16.7% (1/6) | 16.7% (1/6) | | WPNN (N=9) | 11.1% (1/9) | 44.4% (4/9) | 44.4% (4/9) | | YPEN (N=9) | 44.4% (4/9) | 33.3% (3/9) | 22.2% (2/9) |
### Table 17b: Health Boards and Trusts that could receive paediatric neurological direct referrals from general practice and emergency departments (excl. N/A).
| Country/network | Yes | No | |-----------------|--------------|-------------| | England and Wales (N=100) | 32.0% (32/100) | 68.0% (68/100) | | England (N=96) | 31.3% (30/96) | 68.8% (66/96) | | Wales (N=4) | 50.0% (2/4) | 50.0% (2/4) | | BRPNF (N=4) | 25.0% (1/4) | 75.0% (3/4) | | CEWT (N=2) | 50.0% (1/2) | 50.0% (1/2) | | EPEN (N=14) | 0.0% (0/14) | 100% (14/14) | | EPIC (N=5) | 40.0% (2/5) | 60.0% (3/5) | | NTPEN (N=12) | 25.0% (3/12) | 75.0% (9/12) | | NWEIG (N=12) | 33.3% (4/12) | 66.7% (8/12) | | ORENG (N=7) | 42.9% (3/7) | 57.1% (4/7) | | PENNEC (N=7) | 28.6% (2/7) | 71.4% (5/7) | | SETPEG (N=5) | 60.0% (3/5) | 40.0% (2/5) | | SWEP (N=3) | 33.3% (1/3) | 66.7% (2/3) | | SWIPE (N=6) | 33.3% (2/6) | 66.7% (4/6) | | SWTPEG (N=6) | 16.7% (1/6) | 83.3% (5/6) | | TEN (N=5) | 80.0% (4/5) | 20.0% (1/5) | | WPNN (N=5) | 20.0% (1/5) | 80.0% (4/5) | | YPEN (N=7) | 57.1% (4/7) | 42.9% (3/7) |
### Table 18: Health Boards and Trusts that were hosting satellite paediatric neurology clinics.
| Country/network | Yes | No | N/A | |-----------------|--------------|-------------|--------------| | England and Wales (N=136) | 73.5% (100/136) | 22.8% (31/136) | 3.7% (5/136) | | England (N=131) | 72.5% (95/131) | 23.7% (31/131) | 3.8% (5/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 23.1% (3/13) | 53.8% (7/13) | 23.1% (3/13) | | CEWT (N=5) | 80.0% (4/5) | 0.0% (0/5) | 20.0% (1/5) | | EPEN (N=14) | 78.6% (11/14) | 21.4% (3/14) | 0.0% (0/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | | NTPEN (N=16) | 31.3% (5/16) | 68.8% (11/16) | 0.0% (0/16) | | NWEIG (N=12) | 83.3% (10/12) | 8.3% (1/12) | 8.3% (1/12) | | ORENG (N=7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | | PENNEC (N=8) | 75.0% (6/8) | 25.0% (2/8) | 0.0% (0/8) | | SETPEG (N=8) | 75.0% (6/8) | 25.0% (2/8) | 0.0% (0/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 88.9% (8/9) | 11.1% (1/9) | 0.0% (0/9) | | SWTPEG (N=7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | 0.0% (0/6) | | WPNN (N=9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | | YPEN (N=9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | Other services
14.7% (20/136) of Health Boards and Trusts provided commencement of a ketogenic diet service, whilst 19.1% (26/136) provided the ongoing review of ketogenic diet services, (Table 19 and Table 20 respectively).
Figure 8 shows, 9.6% (13/136) of Health Boards and Trusts provided insertion of a vagal nerve stimulator (VNS) within their locations, whilst 21.3% (29/136) provided Vagal Nerve Stimulator (VNS) review services. A comparison of Health Boards and Trusts that provided ketogenetic diet and vagal nerve stimulator (VNS) services within their locations in Round 3 April 2018 and Round 3 November 2019 is shown in Figure 9.
Figure 8: Percentage of Health Boards and Trusts that could provide ketogenetic diet and vagal nerve stimulator. Figure 9: Percentage of Health Boards and Trusts that could provide ketogenic diet and vagal nerve stimulator services in Round 3 April 2018 and November 2019.
### Table 19: Health Boards and Trusts that could facilitate the commencement of a ketogenic diet.
| Country/network | Yes | No | Uncertain | |-----------------|-----------|-----------|-----------| | England and Wales (N=136) | 14.7% (20/136) | 85.3% (116/136) | 0.0% (0/136) | | England (N=131) | 15.3% (20/131) | 84.7% (111/131) | 0.0% (0/131) | | Wales (N=5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | 0.0% (0/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | 0.0% (0/5) | | EPEN (N=14) | 7.1% (1/14) | 92.9% (13/14) | 0.0% (0/14) | | EPIC (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | NTPEN (N=16) | 6.3% (1/16) | 93.8% (15/16) | 0.0% (0/16) | | NWEIG (N=12) | 16.7% (2/12) | 83.3% (10/12) | 0.0% (0/12) | | ORENG (N=7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SETPEG (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SWEP (N=4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | | SWTPEG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | | WPNN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | YPEN (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) |
### Table 20: Health Boards and Trusts that could undertake ongoing review of a ketogenic diet.
| Country/network | Yes | No | Uncertain | |-----------------|-----------|-----------|-----------| | England and Wales (N=136) | 19.1% (26/136) | 80.9% (110/136) | 0.0% (0/136) | | England (N=131) | 19.8% (26/131) | 80.2% (105/131) | 0.0% (0/131) | | Wales (N=5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | 0.0% (0/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | 0.0% (0/5) | | EPEN (N=14) | 7.1% (1/14) | 92.9% (13/14) | 0.0% (0/14) | | EPIC (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | NTPEN (N=16) | 6.3% (1/16) | 93.8% (15/16) | 0.0% (0/16) | | NWEIG (N=12) | 16.7% (2/12) | 83.3% (10/12) | 0.0% (0/12) | | ORENG (N=7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SETPEG (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SWEP (N=4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | | SWTPEG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | | WPNN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | YPEN (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) |
### Table 21: Health Boards and Trusts that were able to insert vagal nerve stimulator.
| Country/network | Yes | No | Uncertain | |-----------------|-----------|-----------|-----------| | England and Wales (N=136) | 9.6% (13/136) | 90.4% (123/136) | 0.0% (0/136) | | England (N=131) | 9.9% (13/131) | 90.1% (118/131) | 0.0% (0/131) | | Wales (N=5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | 0.0% (0/13) | | CEWT (N=5) | 20.0% (1/5) | 80.0% (4/5) | 0.0% (0/5) | | EPEN (N=14) | 7.1% (1/14) | 92.9% (13/14) | 0.0% (0/14) | | EPIC (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | NTPEN (N=16) | 6.3% (1/16) | 93.8% (15/16) | 0.0% (0/16) | | NWEIG (N=12) | 8.3% (1/12) | 91.7% (11/12) | 0.0% (0/12) | | ORENG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SETPEG (N=8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SWEP (N=4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | SWTPEG (N=7) | 0.0% (0/7) | 100% (7/7) | 0.0% (0/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | | WPNN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | YPEN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) |
### Table 22: Health Boards and Trusts that were able to review vagal nerve stimulator
| Country/network | Yes | No | Uncertain | |-----------------|-----------|-----------|-----------| | England and Wales (N=136) | 21.3% (29/136) | 78.7% (107/136) | 0.0% (0/136) | | England (N=131) | 19.8% (26/131) | 80.2% (105/131) | 0.0% (0/131) | | Wales (N=5) | 60.0% (3/5) | 40.0% (2/5) | 0.0% (0/5) | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | 0.0% (0/13) | | CEWT (N=5) | 40.0% (2/5) | 60.0% (3/5) | 0.0% (0/5) | | EPEN (N=14) | 14.3% (2/14) | 85.7% (12/14) | 0.0% (0/14) | | EPIC (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | NTPEN (N=16) | 6.3% (1/16) | 93.8% (15/16) | 0.0% (0/16) | | NWEIG (N=12) | 25.0% (3/12) | 75.0% (9/12) | 0.0% (0/12) | | ORENG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | | PENNEC (N=8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | | SETPEG (N=8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | 0.0% (0/4) | | SWIPE (N=9) | 44.4% (4/9) | 55.6% (5/9) | 0.0% (0/9) | | SWTPEG (N=7) | 0.0% (0/7) | 100% (7/7) | 0.0% (0/7) | | TEN (N=6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | WPNN (N=9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | YPEN (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | Investigations
Figure 10 shows the percentage of Health Boards and Trusts offering epilepsy investigation services. 3.7% (5/136) Health Boards and Trusts were not able to offer 12 lead ECG service. In 40.4% (55/136) of Health Boards and Trusts, it was not possible to obtain a standard EEG at a location within their Trust, (Table 23).
Figure 11 shows a comparison of availability of epilepsy investigation services across England and Wales in Round 3 April 2018 and November 2019.
 Figure 11: Percentage of Health Boards and Trusts that could provide investigation services in Round 3 April 2018 and November 2019.
### Table 23: Health Boards and Trusts that could provide epilepsy investigation services.
| Country/network | 12-lead ECG | ‘Awake’ MRI | MRI with sedation | |-----------------|-------------|-------------|-------------------| | | Yes | No | Uncertain | Yes | No | Uncertain | Yes | No | Uncertain | | England and Wales (N=136) | 96.3% (131/136) | 3.7% (5/136) | 0.0% (0/136) | 95.6% (130/136) | 4.4% (6/136) | 0.0% (0/136) | 65.4% (89/136) | 34.6% (47/136) | 0.0% (0/136) | | England (N=131) | 96.2% (126/131) | 3.8% (5/131) | 0.0% (0/131) | 95.4% (125/131) | 4.6% (6/131) | 0.0% (0/131) | 64.9% (85/131) | 35.1% (46/131) | 0.0% (0/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | | BRPNF (N=13) | 92.3% (12/13) | 7.7% (1/13) | 0.0% (0/13) | 84.6% (11/13) | 15.4% (2/13) | 0.0% (0/13) | 61.5% (8/13) | 38.5% (5/13) | 0.0% (0/13) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 92.9% (13/14) | 7.1% (1/14) | 0.0% (0/14) | 92.9% (13/14) | 7.1% (1/14) | 0.0% (0/14) | 85.7% (12/14) | 14.3% (2/14) | 0.0% (0/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | | NTPE (N=16) | 100% (16/16) | 0.0% (0/16) | 0.0% (0/16) | 100% (16/16) | 0.0% (0/16) | 0.0% (0/16) | 93.8% (15/16) | 6.3% (1/16) | 0.0% (0/16) | | NWEIG (N=12) | 100% (12/12) | 0.0% (0/12) | 0.0% (0/12) | 100% (12/12) | 0.0% (0/12) | 0.0% (0/12) | 58.3% (7/12) | 41.7% (5/12) | 0.0% (0/12) | | ORENG (N=7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | 57.1% (4/7) | 42.9% (3/7) | 0.0% (0/7) | | PENNEC (N=8) | 100% (8/8) | 0.0% (0/8) | 0.0% (0/8) | 100% (8/8) | 0.0% (0/8) | 0.0% (0/8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | | SETPEG (N=8) | 87.5% (7/8) | 12.5% (1/8) | 0.0% (0/8) | 87.5% (7/8) | 12.5% (1/8) | 0.0% (0/8) | 75.0% (6/8) | 25.0% (2/8) | 0.0% (0/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | 75.0% (3/4) | 25.0% (1/4) | 0.0% (0/4) | | SWIPE (N=9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | | SWTPEG (N=7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | | TEN (N=6) | 83.3% (5/6) | 16.7% (1/6) | 0.0% (0/6) | 100% (6/6) | 0.0% (0/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | 0.0% (0/9) | 88.9% (8/9) | 11.1% (1/9) | 0.0% (0/9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | | YPEN (N=9) | 100% (9/9) | 0.0% (0/9) | 0.0% (0/9) | 88.9% (8/9) | 11.1% (1/9) | 0.0% (0/9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services.
| Country/network | MRI with general anaesthetic | Standard EEG | Sleep deprived EEG | |-----------------|-----------------------------|--------------|-------------------| | | Yes | No | Uncertain | Yes | No | Uncertain | Yes | No | Uncertain | | England and Wales (N=136) | 55.9% (76/136) | 44.1% (60/136) | 0.0% (0/136) | 59.6% (81/136) | 40.4% (55/136) | 0.0% (0/136) | 57.4% (78/136) | 42.6% (58/136) | 0.0% (0/136) | | England (N=131) | 54.2% (71/131) | 45.8% (60/131) | 0.0% (0/131) | 58% (76/131) | 42.0% (55/131) | 0.0% (0/131) | 55.7% (73/131) | 44.3% (58/131) | 0.0% (0/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 30.8% (4/13) | 69.2% (9/13) | 0.0% (0/13) | 53.8% (7/13) | 46.2% (6/13) | 0.0% (0/13) | 53.8% (7/13) | 46.2% (6/13) | 0.0% (0/13) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | | EPEN (N=14) | 71.4% (10/14) | 28.6% (4/14) | 0.0% (0/14) | 50.0% (7/14) | 50.0% (7/14) | 0.0% (0/14) | 50.0% (7/14) | 50.0% (7/14) | 0.0% (0/14) | | EPIC (N=9) | 44.4% (4/9) | 55.6% (5/9) | 0.0% (0/9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | | NWEIG (N=16) | 43.8% (7/16) | 56.3% (9/16) | 0.0% (0/16) | 62.5% (10/16) | 37.5% (6/16) | 0.0% (0/16) | 62.5% (10/16) | 37.5% (6/16) | 0.0% (0/16) | | ORENG (N=7) | 33.3% (4/12) | 66.7% (8/12) | 0.0% (0/12) | 66.7% (8/12) | 33.3% (4/12) | 0.0% (0/12) | 66.7% (8/12) | 33.3% (4/12) | 0.0% (0/12) | | PENNEC (N=8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | | SETPEG (N=8) | 62.5% (5/8) | 37.5% (3/8) | 0.0% (0/8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | | SWTPEG (N=7) | 57.1% (4/7) | 42.9% (3/7) | 0.0% (0/7) | 85.7% (6/7) | 14.3% (1/7) | 0.0% (0/7) | 71.4% (5/7) | 28.6% (2/7) | 0.0% (0/7) | | TEN (N=6) | 50.0% (3/6) | 50.0% (3/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | WPNN (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | | YPEN (N=9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) |
### Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services.
| Country/network | Melatonin EEG | Sedated EEG | 24–48h ambulatory EEG | |-----------------|---------------|-------------|-----------------------| | | Yes | No | Uncertain | Yes | No | Uncertain | Yes | No | Uncertain | | England and Wales (N=136) | 56.6% (77/136) | 43.4% (59/136) | 0.0% (0/136) | 39.7% (54/136) | 58.8% (80/136) | 1.5% (2/136) | 40.4% (55/136) | 58.8% (80/136) | 0.7% (1/136) | | England (N=131) | 55.7% (73/131) | 44.3% (58/131) | 0.0% (0/131) | 38.2% (50/131) | 60.3% (79/131) | 1.5% (2/131) | 38.2% (50/131) | 61.1% (80/131) | 0.8% (1/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 53.8% (7/13) | 46.2% (6/13) | 0.0% (0/13) | 38.5% (5/13) | 61.5% (8/13) | 0.0% (0/13) | 38.5% (5/13) | 61.5% (8/13) | 0.0% (0/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | | EPEN (N=14) | 42.9% (6/14) | 57.1% (8/14) | 0.0% (0/14) | 7.1% (1/14) | 85.7% (12/14) | 7.1% (1/14) | 28.6% (4/14) | 71.4% (10/14) | 0.0% (0/14) | | EPIC (N=9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | | NTPEN (N=16) | 56.3% (9/16) | 43.8% (7/16) | 0.0% (0/16) | 43.8% (7/16) | 56.3% (9/16) | 0.0% (0/16) | 12.5% (2/16) | 87.5% (14/16) | 0.0% (0/16) | | NWEIG (N=12) | 66.7% (8/12) | 33.3% (4/12) | 0.0% (0/12) | 58.3% (7/12) | 41.7% (5/12) | 0.0% (0/12) | 33.3% (3/12) | 66.7% (8/12) | 0.0% (0/12) | | ORENG (N=7) | 42.9% (3/7) | 57.1% (4/7) | 0.0% (0/7) | 42.9% (3/7) | 57.1% (4/7) | 0.0% (0/7) | 42.9% (3/7) | 57.1% (4/7) | 0.0% (0/7) | | PENNEC (N=8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | 37.5% (3/8) | 50% (4/8) | 12.5% (1/8) | | SETPEG (N=8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | 0.0% (0/4) | 75.0% (3/4) | 25.0% (1/4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | 44.4% (4/9) | 55.6% (5/9) | 0.0% (0/9) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | 0.0% (0/7) | 14.3% (1/7) | 71.4% (5/7) | 14.3% (1/7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | | TEN (N=6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | WPNN (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 44.4% (4/9) | 55.6% (5/9) | 0.0% (0/9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | | YPEN (N=9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | 44.4% (4/9) | 55.6% (5/9) | 0.0% (0/9) | 77.8% (7/9) | 22.2% (2/9) | 0.0% (0/9) | Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services.
| Country/ network | Inpatient Video Telemetry | Outpatient Video Telemetry | Home Video Telemetry | |------------------|---------------------------|----------------------------|----------------------| | | Yes | No | Uncertain | Yes | No | Uncertain | Yes | No | Uncertain | | England and Wales (N=136) | 21.3% (29/136) | 78.7% (107/136) | 0.0% (0/136) | 14.7% (20/136) | 83.8% (114/136) | 1.5% (2/136) | 16.2% (22/136) | 82.4% (112/136) | 1.5% (2/136) | | England (N=131) | 20.6% (27/131) | 79.4% (104/131) | 0.0% (0/131) | 14.5% (19/131) | 84.7% (111/131) | 0.8% (1/131) | 15.3% (20/131) | 83.2% (109/131) | 1.5% (2/131) | | Wales (N=5) | 40.0% (2/5) | 60.0% (3/5) | 0.0% (0/5) | 20.0% (1/5) | 60.0% (3/5) | 20.0% (1/5) | 40.0% (2/5) | 60.0% (3/5) | 0.0% (0/5) | | BRPNF (N=13) | 23.1% (3/13) | 76.9% (10/13) | 0.0% (0/13) | 23.1% (3/13) | 76.9% (10/13) | 0.0% (0/13) | 30.8% (4/13) | 69.2% (9/13) | 0.0% (0/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | 0.0% (0/5) | 20.0% (1/5) | 80.0% (4/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | | EPEN (N=14) | 14.3% (2/14) | 85.7% (12/14) | 0.0% (0/14) | 0.0% (0/14) | 92.9% (13/14) | 7.1% (1/14) | 7.1% (1/14) | 92.9% (13/14) | 0.0% (0/14) | | EPIC (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | | NTPEN (N=16) | 12.5% (2/16) | 87.5% (14/16) | 0.0% (0/16) | 6.3% (1/16) | 93.8% (15/16) | 0.0% (0/16) | 12.5% (2/16) | 87.5% (14/16) | 0.0% (0/16) | | NWEIG (N=12) | 8.3% (1/12) | 91.7% (11/12) | 0.0% (0/12) | 16.7% (2/12) | 83.3% (10/12) | 0.0% (0/12) | 8.3% (1/12) | 91.7% (11/12) | 0.0% (0/12) | | ORENG (N=7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | 28.6% (2/7) | 71.4% (5/7) | 0.0% (0/7) | | PENNEC (N=8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | 12.5% (1/8) | 87.5% (7/8) | 0.0% (0/8) | | SETPEG (N=8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | | SWEP (N=4) | 25.0% (1/4) | 75.0% (3/4) | 0.0% (0/4) | 0.0% (0/4) | 75.0% (3/4) | 25.0% (1/4) | 25.0% (1/4) | 75.0% (3/4) | 0.0% (0/4) | | SWIPE (N=9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | 11.1% (1/9) | 77.8% (7/9) | 11.1% (1/9) | | SWTPEG (N=7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | 14.3% (1/7) | 85.7% (6/7) | 0.0% (0/7) | 14.3% (1/7) | 71.4% (5/7) | 14.3% (1/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | 16.7% (1/6) | 83.3% (5/6) | 0.0% (0/6) | | WPNN (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | | YPEN (N=9) | 22.2% (2/9) | 77.8% (7/9) | 0.0% (0/9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | 11.1% (1/9) | 88.9% (8/9) | 0.0% (0/9) | Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services.
| Country/network | Portable EEG on ward area | |-----------------|---------------------------| | | Yes | No | Uncertain | | England and Wales (N=136) | 58.1% (79/136) | 40.4% (55/136) | 1.5% (2/136) | | England (N=131) | 56.5% (74/131) | 42.0% (55/131) | 1.5% (2/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 61.5% (8/13) | 30.8% (4/13) | 7.7% (1/13) | | CEWT (N=5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 42.9% (6/14) | 57.1% (8/14) | 0.0% (0/14) | | EPIC (N=9) | 33.3% (3/9) | 66.7% (6/9) | 0.0% (0/9) | | NTPEN (N=16) | 50.0% (8/16) | 50.0% (8/16) | 0.0% (0/16) | | NWEIG (N=12) | 58.3% (7/12) | 33.3% (4/12) | 8.3% (1/12) | | ORENG (N=7) | 71.4% (5/7) | 28.6% (2/7) | 0.0% (0/7) | | PENNEC (N=8) | 50.0% (4/8) | 50.0% (4/8) | 0.0% (0/8) | | SETPEG (N=8) | 37.5% (3/8) | 62.5% (5/8) | 0.0% (0/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | 0.0% (0/7) | | TEN (N=6) | 50.0% (3/6) | 50.0% (3/6) | 0.0% (0/6) | | WPNN (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | | YPEN (N=9) | 55.6% (5/9) | 44.4% (4/9) | 0.0% (0/9) | Service contact
95.6% (130/136) of Health Boards and Trusts were able to provide specialist advice between scheduled reviews across England and Wales, (Table 24). Table 25/Figure 12 shows 48.5% (66/136) of the Health Boards and Trusts that provided specialist advice during reviews reported that the service was available all weekdays for all 52 weeks of the year.
In 7.4% 10/136 of Health Boards and Trusts this service was available all weekdays and out of hours for 52 weeks of the year. 28.7% (39/136) Health Boards and Trusts reported to provide this service on every weekday but for a part of the year.
Figure 13 shows a comparison of availability of specialist advice between scheduled reviews in Round 3 April 2018 and November 2019.
Figure 12: Availability of specialist advice between scheduled reviews (n=136). 52.3% (68/130) of Health Boards and Trusts that reported to provide specialist advice between scheduled reviews described a typical response time of same or next weekday, (Table 26/Figure 14).
Figure 15 shows a comparison of the typical response time for specialist advice in Round 3 April 2018 and November 2019. Table 27/ Figure 16 shows that 46.2% (60/130) of initial specialist advice was ‘typically’ provided by an epilepsy specialist nurse and 40.8% (53/130) were by a consultant paediatrician with expertise in epilepsy.
In the 11.5% (15/136) of Health Boards and Trusts that selected other, advice is typically provided by: both a consultant paediatrician with expertise in epilepsy and an epilepsy specialist nurse (8/130); a combination of all three (5/130); a community paediatrician (1/130); a named or on call paediatrician (1/130).
Figure 17 shows a comparison of professionals who ‘typically’ provided initial specialist advice in Round 3 April 2018 and November 2019.
76.5% (104/136) of Trusts and Health Boards reported to have a clear point of contact for non-paediatric professionals seeking paediatric epilepsy support across England and Wales (Table 28). Figure 14: Typical response time for specialist advice (n=130)
Figure 15: Typical response time for specialist advice in Round 3 April 2018 and November 2019 Figure 16: Professional who ‘typically’ provides initial specialist advice (n=130).
Figure 17: Professional who ‘typically’ provides initial specialist advice in Round 3 April 2018 and November 2019. Table 24: Health Boards and Trusts providing specialist advice between scheduled reviews.
| Country/network | Yes | No | |-----------------|----------------------|---------------------| | England and Wales (N=136) | 95.6% (130/136) | 4.4% (6/136) | | England (N=131) | 95.4% (125/131) | 4.6% (6/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 84.6% (11/13) | 15.4% (2/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | | EPEN (N=14) | 100% (14/14) | 0.0% (0/14) | | EPIC (N=9) | 100% (9/9) | 0.0% (0/9) | | NTPEN (N=16) | 100% (16/16) | 0.0% (0/16) | | NWEIG (N=12) | 100% (12/12) | 0.0% (0/12) | | ORENG (N=7) | 100% (7/7) | 0.0% (0/7) | | PENNEC (N=8) | 100% (8/8) | 0.0% (0/8) | | SETPEG (N=8) | 87.5% (7/8) | 12.5% (1/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 100% (9/9) | 0.0% (0/9) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | TEN (N=6) | 100% (6/6) | 0.0% (0/6) | | WPNN (N=9) | 88.9% (8/9) | 11.1% (1/9) | | YPEN (N=9) | 100% (9/9) | 0.0% (0/9) | Table 25: Availability of Health Boards and Trusts between scheduled reviews.
| Country/network | Available 52 weeks of the year | Not available 52 weeks of the year | |-----------------|--------------------------------|-----------------------------------| | | Some weekdays | Every weekday | Every weekday and out of hours | Some weekdays | Every weekday | Every weekday and out of hours | | England and Wales (N=136) | 0.7% (1/136) | 48.5% (66/136) | 7.4% (10/136) | 9.6% (13/136) | 28.7% (39/136) | 0.7% (1/136) | | England (N=131) | 0.8% (1/131) | 47.3% (62/131) | 7.6% (10/131) | 9.2% (12/131) | 29.8% (39/131) | 0.8% (1/131) | | Wales (N=5) | 0.0% (0/5) | 80.0% (4/5) | 0.0% (0/5) | 20.0% (1/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 0.0% (0/13) | 38.5% (5/13) | 0.0% (0/13) | 0.0% (0/13) | 46.2% (6/13) | 0.0% (0/13) | | CEWT (N=5) | 0.0% (0/5) | 80.0% (4/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 0.0% (0/14) | 42.9% (6/14) | 0.0% (0/14) | 0.0% (0/14) | 57.1% (8/14) | 0.0% (0/14) | | EPIC (N=9) | 0.0% (0/9) | 77.8% (7/9) | 0.0% (0/9) | 11.1% (1/9) | 11.1% (1/9) | 0.0% (0/9) | | NTPEN (N=16) | 0.0% (0/16) | 43.8% (7/16) | 12.5% (2/16) | 12.5% (2/16) | 31.3% (5/16) | 0.0% (0/16) | | NWEIG (N=12) | 0.0% (0/12) | 75.0% (9/12) | 8.3% (1/12) | 8.3% (1/12) | 8.3% (1/12) | 0.0% (0/12) | | ORENG (N=7) | 0.0% (0/7) | 57.1% (4/7) | 14.3% (1/7) | 0.0% (0/7) | 28.6% (2/7) | 0.0% (0/7) | | PENNEC (N=8) | 12.5% (1/8) | 25.0% (2/8) | 25.0% (2/8) | 12.5% (1/8) | 25.0% (2/8) | 0.0% (0/8) | | SETPEG (N=8) | 0.0% (0/8) | 25.0% (2/8) | 0.0% (0/8) | 0.0% (0/8) | 62.5% (5/8) | 0.0% (0/8) | | SWEP (N=4) | 0.0% (0/4) | 75.0% (3/4) | 0.0% (0/4) | 25.0% (1/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 0.0% (0/9) | 22.2% (2/9) | 11.1% (1/9) | 66.7% (6/9) | 0.0% (0/9) | 0.0% (0/9) | | SWTPEG (N=7) | 0.0% (0/7) | 14.3% (1/7) | 14.3% (1/7) | 14.3% (1/7) | 28.6% (2/7) | 14.3% (1/7) | | TEN (N=6) | 0.0% (0/6) | 33.3% (2/6) | 33.3% (2/6) | 0.0% (0/6) | 33.3% (2/6) | 0.0% (0/6) | | WPNN (N=9) | 0.0% (0/9) | 55.6% (5/9) | 0.0% (0/9) | 0.0% (0/9) | 33.3% (3/9) | 0.0% (0/9) | | YPEN (N=9) | 0.0% (0/9) | 77.8% (7/9) | 0.0% (0/9) | 0.0% (0/9) | 22.2% (2/9) | 0.0% (0/9) | Table 26: Typical response time to specialist advice.
| Country/network | Same weekday | Next weekday | 3-4 weekdays | Within the working week | |-----------------|--------------|--------------|--------------|-------------------------| | England and Wales (N=130) | 7.7% (10/130) | 44.6% (58/130) | 36.9% (48/130) | 10.8% (14/130) | | England (N=125) | 8.0% (10/125) | 45.6% (57/125) | 36.0% (45/125) | 10.4% (13/125) | | Wales (N=5) | 0.0% (0/5) | 20.0% (1/5) | 60.0% (3/5) | 20.0% (1/5) | | BRPNF (N=11) | 0.0% (0/11) | 36.4% (4/11) | 45.5% (5/11) | 18.2% (2/11) | | CEWT (N=4) | 25.0% (1/4) | 50.0% (2/4) | 25.0% (1/4) | 0.0% (0/4) | | EPEN (N=14) | 0.0% (0/14) | 42.9% (6/14) | 50.0% (7/14) | 7.1% (1/14) | | EPIC (N=9) | 0.0% (0/9) | 66.7% (6/9) | 22.2% (2/9) | 11.1% (1/9) | | NTPEN (N=16) | 18.8% (3/16) | 31.3% (5/16) | 25.0% (4/16) | 25.0% (4/16) | | NWEIG (N=12) | 8.3% (1/12) | 66.7% (8/12) | 25.0% (3/12) | 0.0% (0/12) | | ORENG (N=7) | 28.6% (2/7) | 42.9% (3/7) | 14.3% (1/7) | 14.3% (1/7) | | PENNEC (N=8) | 0.0% (0/8) | 50.0% (4/8) | 25.0% (2/8) | 25.0% (2/8) | | SETPEG (N=7) | 0.0% (0/7) | 42.9% (3/7) | 42.9% (3/7) | 14.3% (1/7) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 11.1% (1/9) | 33.3% (3/9) | 44.4% (4/9) | 11.1% (1/9) | | SWTPEG (N=6) | 0.0% (0/6) | 83.3% (5/6) | 16.7% (1/6) | 0.0% (0/6) | | TEN (N=6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | WPNN (N=8) | 12.5% (1/8) | 25.0% (2/8) | 62.5% (5/8) | 0.0% (0/8) | | YPEN (N=9) | 11.1% (1/9) | 55.6% (5/9) | 33.3% (3/9) | 0.0% (0/9) | Table 27: Professional who ‘typically’ provides initial specialist advice.
| Country/network | ESN | Consultant with ‘expertise in epilepsy’ | Paediatric neurologist | Other | |-----------------|-----|----------------------------------------|------------------------|-------| | England and Wales (N=130) | 46.2% (60/130) | 40.8% (53/130) | 1.5% (2/130) | 11.5% (15/130) | | England (N=125) | 46.4% (58/125) | 40.0% (50/125) | 1.6% (2/125) | 12.0% (15/125) | | Wales (N=5) | 40.0% (2/5) | 60.0% (3/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=11) | 27.3% (3/11) | 45.5% (5/11) | 0.0% (0/11) | 27.3% (3/11) | | CEWT (N=4) | 50.0% (2/4) | 0.0% (0/4) | 25.0% (1/4) | 25.0% (1/4) | | EPEN (N=14) | 50.0% (7/14) | 50.0% (7/14) | 0.0% (0/14) | 0.0% (0/14) | | EPIC (N=9) | 66.7% (6/9) | 33.3% (3/9) | 0.0% (0/9) | 0.0% (0/9) | | NTPEN (N=16) | 50.0% (8/16) | 43.8% (7/16) | 6.3% (1/16) | 0.0% (0/16) | | NWEIG (N=12) | 41.7% (5/12) | 50.0% (6/12) | 0.0% (0/12) | 8.3% (1/12) | | ORENG (N=7) | 57.1% (4/7) | 28.6% (2/7) | 0.0% (0/7) | 14.3% (1/7) | | PENNEC (N=8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 0.0% (0/8) | | SETPEG (N=7) | 57.1% (4/7) | 14.3% (1/7) | 0.0% (0/7) | 28.6% (2/7) | | SWEP (N=4) | 50.0% (2/4) | 50.0% (2/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 33.3% (3/9) | 44.4% (4/9) | 0.0% (0/9) | 22.2% (2/9) | | SWTPEG (N=6) | 50.0% (3/6) | 33.3% (2/6) | 0.0% (0/6) | 16.7% (1/6) | | TEN (N=6) | 33.3% (2/6) | 50.0% (3/6) | 0.0% (0/6) | 16.7% (1/6) | | WPNN (N=8) | 62.5% (5/8) | 25.0% (2/8) | 0.0% (0/8) | 12.5% (1/8) | | YPEN (N=9) | 44.4% (4/9) | 33.3% (3/9) | 0.0% (0/9) | 22.2% (2/9) | Table 28: Health Boards and Trusts with evidence of a clear point of contact for non-paediatric professionals seeking paediatric epilepsy support.
| Country/network | Yes | No | |-----------------|----------------------|---------------------| | England and Wales (N=136) | 76.5% (104/136) | 23.5% (32/136) | | England (N=131) | 75.6% (99/131) | 24.4% (32/131) | | Wales (N=5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 61.5% (8/13) | 38.5% (5/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | | EPEN (N=14) | 85.7% (12/14) | 14.3% (2/14) | | EPIC (N=9) | 88.9% (8/9) | 11.1% (1/9) | | NTPEN (N=16) | 81.3% (13/16) | 18.8% (3/16) | | NWEIG (N=12) | 91.7% (11/12) | 8.3% (1/12) | | ORENG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | PENNEC (N=8) | 50.0% (4/8) | 50.0% (4/8) | | SETPEG (N=8) | 75.0% (6/8) | 25.0% (2/8) | | SWEP (N=4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 77.8% (7/9) | 22.2% (2/9) | | SWTPEG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | TEN (N=6) | 83.3% (5/6) | 16.7% (1/6) | | WPNN (N=9) | 66.7% (6/9) | 33.3% (3/9) | | YPEN (N=9) | 77.8% (7/9) | 22.2% (2/9) | Transition
Table 29 shows 20.6% (28/136) of Health Boards and Trusts did not have agreed referral pathway for young people to adult services. 36.8% (50/136) of Health Boards and Trusts had an outpatient clinic specifically for young people with epilepsies, (Table 30). The median age of acceptance of young people into adult clinics was 15 years with a minimum acceptance age of 11 years and a maximum acceptance age of 18 as shown on Table 31.
Figure 18 shows the proportion of Health Boards and Trusts with specific outpatient clinic for 'young people' with epilepsies in Rounds 1, Round 2, Round 3 April 2018 and November 2019.
Figure 18: Clinics for young people across Rounds 1, Round 2, Round 3 April 2018 and Round 3 November 2019.
55.9% (76/136) Health Boards and Trusts reported to have outpatient service for epilepsy where there is a presence of both adult and paediatric professionals. Figure 19/Table 33 shows 53.9% (41/76) had single joint appointments, 9.2% (7/76) have a series of several joint appointments, 27.6% (21/76) have a flexible approach that included a mixture of joint or individual reviews. In the seven Health Boards and Trusts that responded other, the responses included:
- Adult and Paediatric nurse led clinic,
- Adult epilepsy nurse attends teenage clinics,
- Single joint appointment with paediatric and adult neurologist based at the adult centre,
- Some single joint appointments and some a series,
- Single joint appointment and Transition Clinic for one consultant only, • Joint transition appointment /Sees Neurologist/back to paediatrics for final appointment.
Figure 20 shows a comparison of composition of joint transition in Round 3 April 2018 and November 2019. The mean of the percentage of young people transferred to adult services who transitioned through the joint professional process was 72.1%. This ranged from 1% to 100% as shown in Table 34.
Table 35/ Figure 23 shows 58.1% (79/136) of Health Boards and Trusts, used structured resources (for example Ready, Steady, Go) to support transition to adult services.
Figure 19: Composition of the joint transition process (n=76). Figure 20: Composition of the joint transition process in Round 3 April 2018 and November 2019.
Figure 21 shows the various professionals who were routinely involved in transition or transfer to adult services. A majority of the Health Boards and Trusts 83.8% (114/136) had an adult neurologist supporting transition to adult services, whilst 54.4% (74/136) had an adult ESN supporting the transition as shown on Table 36. Other responses included:
- Adult Learning Disability Consultant,
- Adult Learning Disability Psychiatrist,
- Consultant Psychiatrist,
- GP,
- GP and Adult Neurologist,
- GP with Epilepsy interest,
- Education or social care,
- Adult Learning Disability team,
- Adult Learning Disability team/ adult rehab/ GP,
- discussion with adult neurologist and neurophysiologist in Neurophysiology meeting,
- Learning Disability transition nurses,
- specific young people transition clinic with adult neurology, paediatric neurology and adult ESN – run by a different Trust,
- Youth worker from an epilepsy charity may attend,
- Learning Disability Partnership
- Transition nurses, • Details of neurology specialist nurse contact and often offer ESN appointment at neuro hospital.
**Figure 22** shows a comparison of professionals who were routinely involved in transition or transfer to adult services in Round 3 April 2018 and November 2019.
**Figure 21:** Professionals routinely involved in transition or transfer to adult services (n=136).
**Figure 22:** Professionals routinely involved in transition or transfer to adult services in Round 3 April 2018 and November 2019. Figure 23: Percentage of Health Boards and Trusts that were using structured resources to support transition in Round 3 April 2018 and November 2019. Table 29: Health Boards and Trusts that had an agreed referral pathway to adult services.
| Country/network | Yes | No | |-----------------|--------------|---------------| | England and Wales (N=136) | 79.4% (108/136) | 20.6% (28/136) | | England (N=131) | 79.4% (104/131) | 20.6% (27/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | | BRPNF (N=13) | 61.5% (8/13) | 38.5% (5/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | | EPEN (N=14) | 92.9% (13/14) | 7.1% (1/14) | | EPIC (N=9) | 88.9% (8/9) | 11.1% (1/9) | | NTPEN (N=16) | 75.0% (12/16) | 25.0% (4/16) | | NWEIG (N=12) | 75.0% (9/12) | 25.0% (3/12) | | ORENG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | PENNEC (N=8) | 62.5% (5/8) | 37.5% (3/8) | | SETPEG (N=8) | 75.0% (6/8) | 25.0% (2/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | | SWTPEG (N=7) | 100% (7/7) | 0.0% (0/7) | | TEN (N=6) | 83.3% (5/6) | 16.7% (1/6) | | WPNN (N=9) | 77.8% (7/9) | 22.2% (2/9) | | YPEN (N=9) | 100% (9/9) | 0.0% (0/9) |
### Table 30: Health Boards and Trusts that had an outpatient clinic specifically for young people with epilepsies.
| Country/network | Yes (%) | No (%) | |-----------------|---------|--------| | England and Wales (N=136) | 36.8% (50/136) | 63.2% (86/136) | | England (N=131) | 37.4% (49/131) | 62.6% (82/131) | | Wales (N=5) | 20.0% (1/5) | 80.0% (4/5) | | BRPNF (N=13) | 38.5% (5/13) | 61.5% (8/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | | EPEN (N=14) | 57.1% (8/14) | 42.9% (6/14) | | EPIC (N=9) | 22.2% (2/9) | 77.8% (7/9) | | NTPEN (N=16) | 31.3% (5/16) | 68.8% (11/16) | | NWEIG (N=12) | 50.0% (6/12) | 50.0% (6/12) | | ORENG (N=7) | 28.6% (2/7) | 71.4% (5/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | | SETPEG (N=8) | 50.0% (4/8) | 50.0% (4/8) | | SWEP (N=4) | 25.0% (1/4) | 75.0% (3/4) | | SWIPE (N=9) | 33.3% (3/9) | 66.7% (6/9) | | SWTPEG (N=7) | 42.9% (3/7) | 57.1% (4/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | | WPNN (N=9) | 55.6% (5/9) | 44.4% (4/9) | | YPEN (N=9) | 11.1% (1/9) | 88.9% (8/9) |
### Table 31: Age at which the outpatient clinic typically accepted young people with epilepsies
| Country/network | Mean age | Median age | Minimum age | Maximum age | |-----------------|----------|------------|-------------|-------------| | England and Wales (N=50) | 14.7 | 15.0 | 11 | 18 | | England (N=49) | 14.6 | 15.0 | 11 | 18 | | Wales (N=1) | 16.0 | 16.0 | 16 | 16 | | BRPNF (N=5) | 14.8 | 14.0 | 14 | 16 | | CEWT (N=3) | 13.0 | 13.0 | 12 | 14 | | EPEN (N=8) | 14.8 | 15.0 | 13 | 16 | | EPIC (N=2) | 14.0 | 14.0 | 14 | 14 | | NTPEN (N=5) | 14.6 | 15.0 | 12 | 17 | | NWEIG (N=6) | 13.7 | 14.0 | 12 | 16 | | ORENG (N=2) | 16.0 | 16.0 | 16 | 16 | | PENNEC (N=1) | 14.0 | 14.0 | 14 | 14 | | SETPEG (N=4) | 16.0 | 16.0 | 15 | 17 | | SWEP (N=1) | 16.0 | 16.0 | 16 | 16 | | SWIPE (N=3) | 16.7 | 16.0 | 16 | 18 | | SWTPEG (N=3) | 14.7 | 16.0 | 12 | 16 | | TEN (N=1) | 11.0 | 11.0 | 11 | 11 | | WPNN (N=5) | 14.6 | 14.0 | 13 | 16 | | YPEN (N=1) | 15.0 | 15.0 | 15 | 15 |
### Table 32: Health Boards and Trusts that had an outpatient service involving adult and paediatric professionals.
| Country/network | Yes (%) | No (%) | |-----------------|---------|--------| | England and Wales (N=136) | 55.9% (76/136) | 44.1% (60/136) | | England (N=131) | 55.0% (72/131) | 45.0% (59/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | | BRPNF (N=13) | 61.5% (8/13) | 38.5% (5/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | | EPEN (N=14) | 50.0% (7/14) | 50.0% (7/14) | | EPIC (N=9) | 44.4% (4/9) | 55.6% (5/9) | | NTPEN (N=16) | 68.8% (11/16) | 31.3% (5/16) | | NWEIG (N=12) | 66.7% (8/12) | 33.3% (4/12) | | ORENG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | | SETPEG (N=8) | 50.0% (4/8) | 50.0% (4/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 66.7% (6/9) | 33.3% (3/9) | | SWTPEG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | | WPNN (N=9) | 55.6% (5/9) | 44.4% (4/9) | | YPEN (N=9) | 55.6% (5/9) | 44.4% (4/9) |
### Table 33: Structure of outpatient service involving both adult and paediatric professionals.
| Country/network | Several joint appointments (%) | Single joint appointments (%) | Mixed (joint and individual) (%) | Other (%) | |-----------------|--------------------------------|-------------------------------|---------------------------------|-----------| | England and Wales (N=76) | 9.2% (7/76) | 53.9% (41/76) | 27.6% (21/76) | 9.2% (7/76) | | England (N=72) | 9.7% (7/72) | 55.6% (40/72) | 25.0% (18/72) | 9.7% (7/72) | | Wales (N=4) | 0.0% (0/4) | 25.0% (1/4) | 75.0% (3/4) | 0.0% (0/4) | | BRPNF (N=8) | 12.5% (1/8) | 62.5% (5/8) | 25.0% (2/8) | 0.0% (0/8) | | CEWT (N=3) | 66.7% (2/3) | 0.0% (0/3) | 0.0% (0/3) | 33.3% (1/3) | | EPEN (N=7) | 0.0% (0/7) | 42.9% (3/7) | 42.9% (3/7) | 14.3% (1/7) | | EPIC (N=4) | 0.0% (0/4) | 50.0% (2/4) | 25.0% (1/4) | 25.0% (1/4) | | NTPEN (N=11) | 9.1% (1/11) | 63.6% (7/11) | 18.2% (2/11) | 9.1% (1/11) | | NWEIG (N=8) | 0.0% (0/8) | 87.5% (7/8) | 12.5% (1/8) | 0.0% (0/8) | | ORENG (N=5) | 0.0% (0/5) | 60.0% (3/5) | 40.0% (2/5) | 0.0% (0/5) | | PENNEC (N=1) | 0.0% (0/1) | 100% (1/1) | 0.0% (0/1) | 0.0% (0/1) | | SETPEG (N=4) | 0.0% (0/4) | 50.0% (2/4) | 50.0% (2/4) | 0.0% (0/4) | | SWEP (N=3) | 0.0% (0/3) | 33.3% (1/3) | 66.7% (2/3) | 0.0% (0/3) | | SWIPE (N=6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 0.0% (0/6) | | SWTPEG (N=5) | 20.0% (1/5) | 20.0% (1/5) | 20.0% (1/5) | 40.0% (2/5) | | TEN (N=1) | 0.0% (0/1) | 0.0% (0/1) | 0.0% (0/1) | 100% (1/1) | | WPNN (N=5) | 40.0% (2/5) | 40.0% (2/5) | 20.0% (1/5) | 0.0% (0/5) | | YPEN (N=5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | 0.0% (0/5) | Table 34: Estimated percentage of young people transferred to adult services through a joint professional process.
| Country/network | Mean | Minimum | Maximum | |-----------------------|------|---------|---------| | England and Wales | 72.1%| 1.0% | 100.0% | | (N=76) | | | | | England (N=72) | 73.0%| 1.0% | 100.0% | | Wales (N=4) | 56.3%| 30.0% | 80.0% | | BRPNF (N=8) | 79.4%| 10.0% | 100.0% | | CEWT (N=3) | 43.3%| 30.0% | 70.0% | | EPEN (N=7) | 79.8%| 1.0% | 100.0% | | EPIC (N=4) | 75.0%| 20.0% | 100.0% | | NTPEN (N=11) | 65.1%| 1.0% | 100.0% | | NWEIG (N=8) | 75.8%| 50.0% | 100.0% | | ORENG (N=5) | 81.0%| 40.0% | 95.0% | | PENNEC (N=1) | 100.0%| 100.0% | 100.0% | | SETPEG (N=4) | 72.5%| 50.0% | 100.0% | | SWEP (N=3) | 48.3%| 30.0% | 65.0% | | SWIPE (N=6) | 58.3%| 10.0% | 90.0% | | SWTPEG (N=5) | 86.0%| 50.0% | 100.0% | | TEN (N=1) | 100.0%| 100.0% | 100.0% | | WPNN (N=5) | 60.0%| 25.0% | 100.0% | | YPEN (N=5) | 83.0%| 55.0% | 100.0% |
Table 35: Health Boards and Trusts that were using structured resources to support transition.
| Country/network | Yes | No | |-----------------------|-----|----| | England and Wales | 58.1% (79/136) | 41.9% (57/136) | | (N=136) | | | | England (N=131) | 59.5% (78/131) | 40.5% (53/131) | | Wales (N=5) | 20.0% (1/5) | 80.0% (4/5) | | BRPNF (N=13) | 46.2% (6/13) | 53.8% (7/13) | | CEWT (N=5) | 60.0% (3/5) | 40.0% (2/5) | | EPEN (N=14) | 64.3% (9/14) | 35.7% (5/14) | | EPIC (N=9) | 22.2% (2/9) | 77.8% (7/9) | | NTPEN (N=16) | 43.8% (7/16) | 56.3% (9/16) | | NWEIG (N=12) | 75.0% (9/12) | 25.0% (3/12) | | ORENG (N=7) | 57.1% (4/7) | 42.9% (3/7) | | PENNEC (N=8) | 62.5% (5/8) | 37.5% (3/8) | | SETPEG (N=8) | 37.5% (3/8) | 62.5% (5/8) | | SWEP (N=4) | 25.0% (1/4) | 75.0% (3/4) | | SWIPE (N=9) | 88.9% (8/9) | 11.1% (1/9) | | SWTPEG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | TEN (N=6) | 66.7% (4/6) | 33.3% (2/6) | | WPNN (N=9) | 66.7% (6/9) | 33.3% (3/9) | | YPEN (N=9) | 77.8% (7/9) | 22.2% (2/9) | Table 36: Adult professionals routinely involved in transition or transfer to adult services.
| Country/network | Adult epilepsy specialist nurse | Adult learning difficulty ESN | Adult neurologist | Youth worker | Other | |-----------------|---------------------------------|------------------------------|-------------------|--------------|-------| | England and Wales (N=136) | 54.4% (74/136) | 14.7% (20/136) | 83.8% (114/136) | 2.2% (3/136) | 12.5% (17/136) | | England (N=131) | 53.4% (70/131) | 13% (17/131) | 83.2% (109/131) | 2.3% (3/131) | 11.5% (15/131) | | Wales (N=5) | 80.0% (4/5) | 60.0% (3/5) | 100% (5/5) | 0.0% (0/5) | 40.0% (2/5) | | BRPNF (N=13) | 38.5% (5/13) | 7.7% (1/13) | 76.9% (10/13) | 0.0% (0/13) | 7.7% (1/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | 60.0% (3/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 50.0% (7/14) | 21.4% (3/14) | 92.9% (13/14) | 14.3% (2/14) | 28.6% (4/14) | | EPIC (N=9) | 33.3% (3/9) | 0.0% (0/9) | 88.9% (8/9) | 0.0% (0/9) | 33.3% (3/9) | | NTPEN (N=16) | 37.5% (6/16) | 0.0% (0/16) | 93.8% (15/16) | 0.0% (0/16) | 6.3% (1/16) | | NWEIG (N=12) | 58.3% (7/12) | 0.0% (0/12) | 66.7% (8/12) | 0.0% (0/12) | 0.0% (0/12) | | ORENG (N=7) | 85.7% (6/7) | 57.1% (4/7) | 100% (7/7) | 0.0% (0/7) | 14.3% (1/7) | | PENNEC (N=8) | 37.5% (3/8) | 25.0% (2/8) | 75.0% (6/8) | 0.0% (0/8) | 25.0% (2/8) | | SETPEG (N=8) | 50.0% (4/8) | 12.5% (1/8) | 100% (8/8) | 0.0% (0/8) | 0.0% (0/8) | | SWEP (N=4) | 75.0% (3/4) | 75.0% (3/4) | 100% (4/4) | 0.0% (0/4) | 50.0% (2/4) | | SWIPE (N=9) | 66.7% (6/9) | 22.2% (2/9) | 55.6% (5/9) | 0.0% (0/9) | 0.0% (0/9) | | SWTPEG (N=7) | 57.1% (4/7) | 14.3% (1/7) | 100% (7/7) | 0.0% (0/7) | 0.0% (0/7) | | TEN (N=6) | 83.3% (5/6) | 0.0% (0/6) | 83.3% (5/6) | 0.0% (0/6) | 0.0% (0/6) | | WPNN (N=9) | 66.7% (6/9) | 11.1% (1/9) | 88.9% (8/9) | 11.1% (1/9) | 22.2% (2/9) | | YPEN (N=9) | 55.6% (5/9) | 11.1% (1/9) | 77.8% (7/9) | 0.0% (0/9) | 11.1% (1/9) | Mental health
Figure 24 shows the proportion of Health Boards and Trusts that routinely provide formal screening services. 77.2% (105/136) of Health Boards and Trusts undertook no formal screening for Attention Deficit Hyperactivity Disorder (ADHD), Autistic Spectrum Disorder (ASD) or mental health disorders. Only 14.7% (20/136) Health Boards and Trusts routinely provide formal screening services for mental health disorders (Table 37).
Figure 25 shows the comparison of formal screening services in Round 3 April 2018 and November 2019.
Figure 24: Percentage of Health Boards and Trusts routinely providing formal screening services (n=136). Figure 25: Percentage of Health Boards and Trusts routinely providing formal screening services in Round 3 April 2018 and November 2019
41.9% (57/136) of Health Boards were not using any of the questionnaires that were listed for mental health screening, (Table 38). The questionnaires reported to be used by Health Boards and Trusts in mental health screening were:
- 11 (8.1%) Connor’s Questionnaire,
- 10 (7.4%) SDQ (Strength and Difficulties Questionnaire),
- 7 (5.1%) Other,
Other responses included:
- Five point locally made questionnaire,
- NICE signs and symptoms of ASD checklist,
- PI-ED,
- SNAP4,
- Social skills teacher questionnaire,
- York Questionnaire, Vanderbilt and department behaviour assessment questionnaire,
- Wellness questionnaire,
Figure 26 shows the proportion of Health Boards and Trusts that had agreed referral pathways for children and young people with mental health concerns. 42.6% (58/136) of Health Boards and Trusts did not have agreed referral pathways for children with mental health concerns. 54.4% (74/136) of Health Boards and Trusts had agreed referral pathways for children with anxiety; 55.1% (75/136) for depression; 54.4% (74/136) for mood disorder; 37.5% (51/136) for non-epileptic attack disorder, 6.6% (9/136) for other mental health concerns (Table 39). Other responses included:
- Attention Deficit Hyperactivity Disorder (ADHD),
- Behavioural and emotional,
- No agreed pathway, but we refer to Healthy Young Minds when we have these concerns,
- Not specific to epilepsy,
- Referral to Local Healthy Young Minds team,
- A flexible approach with in-house mental health and adolescent medicine teams,
- Referral to psychology for difficulty in coping with diagnosis for patient and family
- Referral to CAMHS for other mental health concerns,
- Tics or Tourette's.
14.0% 19/136 Health Boards and Trusts were able to facilitate mental health provision within epilepsy clinics, (Table 40). 10 of these had epilepsy clinics where mental health professionals can provide direct co-located clinical care and 12 had MDT meetings where epilepsy and mental health professionals discuss individual patients, (Table 41). 7.7% (9/117) of the Health Boards and Trusts that were not able to facilitate mental health provision within epilepsy clinics had an action plan describing steps towards co-located mental health provision, (Table 42).
Figure 27 (below) shows the percentage of Health Boards and Trusts that could refer children and young people to mental health services, either within or outside of your Health Board and Trust where required. 79.4% (108/136) of Health Boards and Trusts were able to refer to clinical psychology services; 92.6% (126/136) to psychiatric services; 46.3% (63/136) to education psychology; 52.2% (71/136) to neuropsychology services and 86.8% (118/136) to formal developmental assessment.
4.4% (6/136) were not able to offer referrals to mental health services, (Table 43).
Figure 28 shows the comparison of ability to refer to mental health services in Round 3 April 2018 and November 2019.
Figure 27: Percentage of Health Boards and Trusts that could refer to mental health services (n=136). Figure 28: Percentage of Health Boards and Trusts that could refer to mental health services in Round 3 April 2018 and November 2019. Table 37: Health Boards and Trusts that formally screen for diagnoses related to epilepsy.
| Country/network | ADHD | ASD | Mental health disorders | None | |-----------------|----------|----------|-------------------------|-----------| | England and Wales (N=136) | 17.6% (24/136) | 18.4% (25/136) | 14.7% (20/136) | 77.2% (105/136) | | England (N=131) | 18.3% (24/131) | 19.1% (25/131) | 15.3% (20/131) | 76.3% (100/131) | | Wales (N=5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 100% (5/5) | | BRPNF (N=13) | 30.8% (4/13) | 30.8% (4/13) | 15.4% (2/13) | 69.2% (9/13) | | CEWT (N=5) | 40.0% (2/5) | 40.0% (2/5) | 20.0% (1/5) | 60.0% (3/5) | | EPEN (N=14) | 7.1% (1/14) | 7.1% (1/14) | 7.1% (1/14) | 85.7% (12/14) | | EPIC (N=9) | 11.1% (1/9) | 11.1% (1/9) | 0.0% (0/9) | 88.9% (8/9) | | NTPEN (N=16) | 18.8% (3/16) | 12.5% (2/16) | 18.8% (3/16) | 75.0% (12/16) | | NWEIG (N=12) | 25.0% (3/12) | 16.7% (2/12) | 25.0% (3/12) | 66.7% (8/12) | | ORENG (N=7) | 42.9% (3/7) | 42.9% (3/7) | 28.6% (2/7) | 57.1% (4/7) | | PENNEC (N=8) | 25.0% (2/8) | 25.0% (2/8) | 25.0% (2/8) | 75.0% (6/8) | | SETPEG (N=8) | 12.5% (1/8) | 12.5% (1/8) | 12.5% (1/8) | 87.5% (7/8) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 100% (4/4) | | SWIPE (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 100% (9/9) | | SWTPEG (N=7) | 14.3% (1/7) | 28.6% (2/7) | 28.6% (2/7) | 57.1% (4/7) | | TEN (N=6) | 16.7% (1/6) | 33.3% (2/6) | 0.0% (0/6) | 66.7% (4/6) | | WPNN (N=9) | 11.1% (1/9) | 11.1% (1/9) | 11.1% (1/9) | 88.9% (8/9) | | YPEN (N=9) | 11.1% (1/9) | 22.2% (2/9) | 22.2% (2/9) | 77.8% (7/9) |
### Table 38: Health Boards and Trusts using particular mental health screening questionnaires.
| Country/Network | BDI - Beck Depression Inventory | Connor's Questionnaire | Emotional Thermometers Tool | GAD - Generalised Anxiety Disorder | GAD 2 - Generalised Anxiety Disorder 2 | GAD 7 - Generalised Anxiety Disorder GAD 7 | HADS - Hospital Anxiety and Depression Scale | MFQ - Mood and Feelings Questionnaire (Child, Parent, adult versions) | NDDI -E Neurological Disorders Depression Inventory for Epilepsy | |-----------------|---------------------------------|------------------------|-----------------------------|-----------------------------------|----------------------------------------|---------------------------------------------|-----------------------------------------------|-------------------------------------------------|-------------------------------------------------| | England and Wales (N=136) | 0.0% (0/136) | 8.1% (11/136) | 0.0% (0/136) | 0.0% (0/136) | 0.0% (0/136) | 0.0% (0/136) | 0.0% (0/136) | 0.0% (0/136) | 0.0% (0/136) | | England (N=131) | 0.0% (0/131) | 8.4% (11/131) | 0.0% (0/131) | 0.0% (0/131) | 0.0% (0/131) | 0.0% (0/131) | 0.0% (0/131) | 0.0% (0/131) | 0.0% (0/131) | | Wales (N=5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 0.0% (0/13) | 7.7% (1/13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | | CEWT (N=5) | 0.0% (0/5) | 20.0% (1/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | 0.0% (0/14) | | EPIC (N=9) | 0.0% (0/9) | 11.1% (1/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | | NTPEN (N=16) | 0.0% (0/16) | 18.8% (3/16) | 0.0% (0/16) | 0.0% (0/16) | 0.0% (0/16) | 0.0% (0/16) | 0.0% (0/16) | 0.0% (0/16) | 0.0% (0/16) | | NWEIG (N=12) | 0.0% (0/12) | 8.3% (1/12) | 0.0% (0/12) | 0.0% (0/12) | 0.0% (0/12) | 0.0% (0/12) | 0.0% (0/12) | 0.0% (0/12) | 0.0% (0/12) | | ORENG (N=7) | 0.0% (0/7) | 28.6% (2/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | | PENNEC (N=8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | | SETPEG (N=8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | | SWTPEG (N=7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | | TEN (N=6) | 0.0% (0/6) | 16.7% (1/6) | 0.0% (0/6) | 0.0% (0/6) | 0.0% (0/6) | 0.0% (0/6) | 0.0% (0/6) | 0.0% (0/6) | 0.0% (0/6) | | WPNN (N=9) | 0.0% (0/9) | 11.1% (1/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | | YPEN (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | Table 38 (continued): Health Boards and Trusts using particular mental health screening questionnaires
| Country/network | PHQ - Patient Health Questionnaire, PHQ 2, PHQ 9 | SDQ (Strength and Difficulties Questionnaire) | Other | None of the above | |-----------------|-----------------------------------------------|-----------------------------------------------|-------|-------------------| | England and Wales (N=136) | 0.0% (0/136) | 7.4% (10/136) | 5.1% (7/136) | 41.9% (57/136) | | England (N=131) | 0.0% (0/131) | 7.6% (10/131) | 5.3% (7/131) | 42.0% (55/131) | | Wales (N=5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | 40.0% (2/5) | | BRPNF (N=13) | 0.0% (0/13) | 15.4% (2/13) | 7.7% (1/13) | 30.8% (4/13) | | CEWT (N=5) | 0.0% (0/5) | 20.0% (1/5) | 0.0% (0/5) | 40.0% (2/5) | | EPEN (N=14) | 0.0% (0/14) | 0.0% (0/14) | 7.1% (1/14) | 50.0% (7/14) | | EPIC (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 33.3% (3/9) | | NTPEN (N=16) | 0.0% (0/16) | 18.8% (3/16) | 6.3% (1/16) | 25.0% (4/16) | | NWEIG (N=12) | 0.0% (0/12) | 8.3% (1/12) | 8.3% (1/12) | 50.0% (6/12) | | ORENG (N=7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | 42.9% (3/7) | | PENNEC (N=8) | 0.0% (0/8) | 0.0% (0/8) | 12.5% (1/8) | 50.0% (4/8) | | SETPEG (N=8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | 50.0% (4/8) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 50.0% (2/4) | | SWIPE (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | 55.6% (5/9) | | SWTPEG (N=7) | 0.0% (0/7) | 14.3% (1/7) | 14.3% (1/7) | 28.6% (2/7) | | TEN (N=6) | 0.0% (0/6) | 16.7% (1/6) | 0.0% (0/6) | 33.3% (2/6) | | WPNN (N=9) | 0.0% (0/9) | 0.0% (0/9) | 11.1% (1/9) | 44.4% (4/9) | | YPEN (N=9) | 0.0% (0/9) | 11.1% (1/9) | 0.0% (0/9) | 55.6% (5/9) | Table 39: Health Boards and Trusts with agreed referral pathways for children and young people with mental health concerns.
| Country/network | Anxiety | Depression | Mood Disorder | Non-epileptic attack disorders | Other | None of the above | |-----------------|---------|------------|--------------|-------------------------------|-------|------------------| | England and Wales (N=136) | 54.4% (74/136) | 55.1% (75/136) | 54.4% (74/136) | 37.5% (51/136) | 6.6% (9/136) | 42.6% (58/136) | | England (N=131) | 55.7% (73/131) | 56.5% (74/131) | 55.7% (73/131) | 38.9% (51/131) | 6.1% (8/131) | 41.2% (54/131) | | Wales (N=5) | 20.0% (1/5) | 20.0% (1/5) | 20.0% (1/5) | 0.0% (0/5) | 20.0% (1/5) | 80.0% (4/5) | | BRPNF (N=13) | 61.5% (8/13) | 61.5% (8/13) | 61.5% (8/13) | 46.2% (6/13) | 0.0% (0/13) | 38.5% (5/13) | | CEWT (N=5) | 80.0% (4/5) | 80.0% (4/5) | 80.0% (4/5) | 40.0% (2/5) | 20.0% (1/5) | 20.0% (1/5) | | EPEN (N=14) | 42.9% (6/14) | 42.9% (6/14) | 42.9% (6/14) | 35.7% (5/14) | 0.0% (0/14) | 50.0% (7/14) | | EPIC (N=9) | 55.6% (5/9) | 66.7% (6/9) | 66.7% (6/9) | 44.4% (4/9) | 22.2% (2/9) | 33.3% (3/9) | | NTPEN (N=16) | 43.8% (7/16) | 43.8% (7/16) | 43.8% (7/16) | 37.5% (6/16) | 12.5% (2/16) | 50.0% (8/16) | | NWEIG (N=12) | 58.3% (7/12) | 58.3% (7/12) | 58.3% (7/12) | 25.0% (3/12) | 16.7% (2/12) | 33.3% (4/12) | | ORENG (N=7) | 28.6% (2/7) | 28.6% (2/7) | 28.6% (2/7) | 14.3% (1/7) | 0.0% (0/7) | 71.4% (5/7) | | PENNEC (N=8) | 87.5% (7/8) | 87.5% (7/8) | 87.5% (7/8) | 62.5% (5/8) | 12.5% (1/8) | 25.0% (2/8) | | SETPEG (N=8) | 62.5% (5/8) | 62.5% (5/8) | 62.5% (5/8) | 50.0% (4/8) | 0.0% (0/8) | 37.5% (3/8) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | 100% (4/4) | | SWIPE (N=9) | 44.4% (4/9) | 44.4% (4/9) | 44.4% (4/9) | 22.2% (2/9) | 0.0% (0/9) | 55.6% (5/9) | | SWTPEG (N=7) | 71.4% (5/7) | 71.4% (5/7) | 71.4% (5/7) | 42.9% (3/7) | 0.0% (0/7) | 28.6% (2/7) | | TEN (N=6) | 66.7% (4/6) | 66.7% (4/6) | 50.0% (3/6) | 33.3% (2/6) | 16.7% (1/6) | 33.3% (2/6) | | WPNN (N=9) | 66.7% (6/9) | 66.7% (6/9) | 66.7% (6/9) | 44.4% (4/9) | 0.0% (0/9) | 33.3% (3/9) | | YPEN (N=9) | 44.4% (4/9) | 44.4% (4/9) | 44.4% (4/9) | 44.4% (4/9) | 0.0% (0/9) | 44.4% (4/9) |
### Table 40: Health Boards and Trusts that were facilitating mental health provision within epilepsy clinics.
| Country/network | Yes | No | |-----------------|-----|----| | England and Wales (N=136) | 14.0% (19/136) | 86.0% (117/136) | | England (N=131) | 14.5% (19/131) | 85.5% (112/131) | | Wales (N=5) | 0.0% (0/5) | 100% (5/5) | | BRPNF (N=13) | 0.0% (0/13) | 100% (13/13) | | CEWT (N=5) | 0.0% (0/5) | 100% (5/5) | | EPEN (N=14) | 14.3% (2/14) | 85.7% (12/14) | | EPIC (N=9) | 22.2% (2/9) | 77.8% (7/9) | | NTPEN (N=16) | 25.0% (4/16) | 75.0% (12/16) | | NWEIG (N=12) | 16.7% (2/12) | 83.3% (10/12) | | ORENG (N=7) | 0.0% (0/7) | 100% (7/7) | | PENNEC (N=8) | 0.0% (0/8) | 100% (8/8) | | SETPEG (N=8) | 37.5% (3/8) | 62.5% (5/8) | | SWEP (N=4) | 0.0% (0/4) | 100% (4/4) | | SWIPE (N=9) | 0.0% (0/9) | 100% (9/9) | | SWTPEG (N=7) | 28.6% (2/7) | 71.4% (5/7) | | TEN (N=6) | 16.7% (1/6) | 83.3% (5/6) | | WPNN (N=9) | 22.2% (2/9) | 77.8% (7/9) | | YPEN (N=9) | 11.1% (1/9) | 88.9% (8/9) |
### Table 41: Composition of mental health provision within epilepsy clinics.
| Country/network | Epilepsy Clinics where mental health professionals can provide direct co-located clinical care | MDT meetings where epilepsy and mental health professionals discuss individual patients | Other | |-----------------|-------------------------------------------------|-------------------------------------------------|-------| | England and Wales (N=136) | 7.4% (10/136) | 8.8% (12/136) | 8.1% (11/136) | | England (N=131) | 7.6% (10/131) | 9.2% (12/131) | 8.4% (11/131) | | Wales (N=5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 0.0% (0/13) | 0.0% (0/13) | 0.0% (0/13) | | CEWT (N=5) | 0.0% (0/5) | 0.0% (0/5) | 0.0% (0/5) | | EPEN (N=14) | 14.3% (2/14) | 14.3% (2/14) | 7.1% (1/14) | | EPIC (N=9) | 11.1% (1/9) | 11.1% (1/9) | 22.2% (2/9) | | NTPEN (N=16) | 6.3% (1/16) | 12.5% (2/16) | 18.8% (3/16) | | NWEIG (N=12) | 8.3% (1/12) | 16.7% (2/12) | 0.0% (0/12) | | ORENG (N=7) | 0.0% (0/7) | 0.0% (0/7) | 0.0% (0/7) | | PENNEC (N=8) | 0.0% (0/8) | 0.0% (0/8) | 0.0% (0/8) | | SETPEG (N=8) | 37.5% (3/8) | 25.0% (2/8) | 12.5% (1/8) | | SWEP (N=4) | 0.0% (0/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 0.0% (0/9) | 0.0% (0/9) | 0.0% (0/9) | | SWTPEG (N=7) | 14.3% (1/7) | 14.3% (1/7) | 14.3% (1/7) | | TEN (N=6) | 0.0% (0/6) | 0.0% (0/6) | 16.7% (1/6) | | WPNN (N=9) | 11.1% (1/9) | 11.1% (1/9) | 11.1% (1/9) | | YPEN (N=9) | 0.0% (0/9) | 11.1% (1/9) | 11.1% (1/9) | Table 42: Health Boards and Trusts that had an action plan describing steps towards co-located mental health provision.
| Country/network | Yes | No | |-----------------|-----------|-----------| | England and Wales (N=117) | 7.7% (9/117) | 92.3% (108/117) | | England (N=112) | 8.0% (9/112) | 92.0% (103/112) | | Wales (N=5) | 0.0% (0/5) | 100% (5/5) | | BRPNF (N=13) | 7.7% (1/13) | 92.3% (12/13) | | CEWT (N=5) | 40.0% (2/5) | 60.0% (3/5) | | EPEN (N=12) | 0.0% (0/12) | 100% (12/12) | | EPIC (N=7) | 14.3% (1/7) | 85.7% (6/7) | | NTPEN (N=12) | 8.3% (1/12) | 91.7% (11/12) | | NWEIG (N=10) | 0.0% (0/10) | 100% (10/10) | | ORENG (N=7) | 0.0% (0/7) | 100% (7/7) | | PENNEC (N=8) | 12.5% (1/8) | 87.5% (7/8) | | SETPEG (N=5) | 0.0% (0/5) | 100% (5/5) | | SWEP (N=4) | 0.0% (0/4) | 100% (4/4) | | SWIPE (N=9) | 0.0% (0/9) | 100% (9/9) | | SWTPEG (N=5) | 0.0% (0/5) | 100% (5/5) | | TEN (N=5) | 20.0% (1/5) | 80.0% (4/5) | | WPNN (N=7) | 0.0% (0/7) | 100% (7/7) | | YPEN (N=8) | 25.0% (2/8) | 75.0% (6/8) | Table 43: Health Boards and Trusts that could refer to mental health services.
| Country/network | Clinical psychology | Psychiatric | Educational psychology | Neuropsychology | Formal developmental | None | |-----------------|---------------------|-------------|------------------------|----------------|---------------------|------| | England and Wales (N=136) | 79.4% (108/136) | 92.6% (126/136) | 46.3% (63/136) | 52.2% (71/136) | 86.8% (118/136) | 4.4% (6/136) | | England (N=131) | 80.2% (105/131) | 92.4% (121/131) | 45.8% (60/131) | 54.2% (71/131) | 86.3% (113/131) | 4.6% (6/131) | | Wales (N=5) | 60.0% (3/5) | 100% (5/5) | 60.0% (3/5) | 0.0% (0/5) | 100% (5/5) | 0.0% (0/5) | | BRPNF (N=13) | 92.3% (12/13) | 100% (13/13) | 69.2% (9/13) | 46.2% (6/13) | 92.3% (12/13) | 0.0% (0/13) | | CEWT (N=5) | 100% (5/5) | 100% (5/5) | 20.0% (1/5) | 80.0% (4/5) | 100% (5/5) | 0.0% (0/5) | | EPEN (N=14) | 64.3% (9/14) | 85.7% (12/14) | 57.1% (8/14) | 28.6% (4/14) | 85.7% (12/14) | 14.3% (2/14) | | EPIC (N=9) | 66.7% (6/9) | 88.9% (8/9) | 22.2% (2/9) | 55.6% (5/9) | 77.8% (7/9) | 0.0% (0/9) | | NTPEN (N=16) | 87.5% (14/16) | 93.8% (15/16) | 31.3% (5/16) | 68.8% (11/16) | 100% (16/16) | 0.0% (0/16) | | NWEIG (N=12) | 91.7% (11/12) | 91.7% (11/12) | 58.3% (7/12) | 58.3% (7/12) | 83.3% (10/12) | 0.0% (0/12) | | ORENG (N=7) | 85.7% (6/7) | 100% (7/7) | 57.1% (4/7) | 71.4% (5/7) | 85.7% (6/7) | 0.0% (0/7) | | PENNEC (N=8) | 87.5% (7/8) | 100% (8/8) | 87.5% (7/8) | 75.0% (6/8) | 100% (8/8) | 0.0% (0/8) | | SETPEG (N=8) | 100% (8/8) | 100% (8/8) | 62.5% (5/8) | 75.0% (6/8) | 100% (8/8) | 0.0% (0/8) | | SWEP (N=4) | 50.0% (2/4) | 100% (4/4) | 50.0% (2/4) | 0.0% (0/4) | 100% (4/4) | 0.0% (0/4) | | SWIPE (N=9) | 88.9% (8/9) | 100% (9/9) | 55.6% (5/9) | 77.8% (7/9) | 77.8% (7/9) | 0.0% (0/9) | | SWTPEG (N=7) | 42.9% (3/7) | 71.4% (5/7) | 14.3% (1/7) | 28.6% (2/7) | 71.4% (5/7) | 28.6% (2/7) | | TEN (N=6) | 50.0% (3/6) | 66.7% (4/6) | 0.0% (0/6) | 33.3% (2/6) | 66.7% (4/6) | 16.7% (1/6) | | WPNN (N=9) | 66.7% (6/9) | 88.9% (8/9) | 33.3% (3/9) | 22.2% (2/9) | 77.8% (7/9) | 11.1% (1/9) | | YPEN (N=9) | 88.9% (8/9) | 100% (9/9) | 44.4% (4/9) | 44.4% (4/9) | 77.8% (7/9) | 0.0% (0/9) | Neurodevelopmental support
16.2% (22/136) of Health Boards and Trusts did not have agreed referral criteria for children and young people with neurodevelopmental problems. 77.2% (105/136) had an agreed referral for children with ADHD; 80.9% (110/136) for ASD; 55.1% (75/136) for behaviour difficulties; 55.9% (76/136) for developmental coordination disorder; 49.3% (67/136) for intellectual disability (Table 44/ Figure 29). In the 5.9% (8/136) that selected other, the responses included:
- Developmental delay,
- CP, development delay, neuromuscular,
- Global developmental delay,
- Challenging behaviour associated with severe learning difficulties,
- Early Health Assessment pathway,
- Referral is to community paediatric service who will direct referral to appropriate pathway,
Conditions details are not seen within our Trust or Health Board.
 Table 44: Health Boards and Trusts that had agreed referral criteria for children and young people with neuro-developmental problems
| Country/network | ADHD | ASD | Behaviour difficulties | Developmental Coordination Disorder | Intellectual disability | Other | None | |-----------------|------------|------------|------------------------|-------------------------------------|-------------------------|-------------|-------------| | England and Wales (N=136) | 77.2% (105/136) | 80.9% (110/136) | 55.1% (75/136) | 55.9% (76/136) | 49.3% (67/136) | 5.9% (8/136) | 16.2% (22/136) | | England (N=131) | 76.3% (100/131) | 80.2% (105/131) | 55.0% (72/131) | 55.0% (72/131) | 49.6% (65/131) | 6.1% (8/131) | 16.8% (22/131) | | Wales (N=5) | 100% (5/5) | 100% (5/5) | 60.0% (3/5) | 80.0% (4/5) | 40.0% (2/5) | 0.0% (0/5) | 0.0% (0/5) | | BRPNF (N=13) | 92.3% (12/13) | 100% (13/13) | 84.6% (11/13) | 76.9% (10/13) | 84.6% (11/13) | 0.0% (0/13) | 0.0% (0/13) | | CEWT (N=5) | 100% (5/5) | 100% (5/5) | 80.0% (4/5) | 80.0% (4/5) | 80.0% (4/5) | 20.0% (1/5) | 0.0% (0/5) | | EPEN (N=14) | 57.1% (8/14) | 57.1% (8/14) | 50.0% (7/14) | 50.0% (7/14) | 21.4% (3/14) | 7.1% (1/14) | 28.6% (4/14) | | EPIC (N=9) | 88.9% (8/9) | 88.9% (8/9) | 55.6% (5/9) | 44.4% (4/9) | 44.4% (4/9) | 11.1% (1/9) | 11.1% (1/9) | | NTPEN (N=16) | 62.5% (10/16) | 75.0% (12/16) | 56.3% (9/16) | 37.5% (6/16) | 50.0% (8/16) | 6.3% (1/16) | 25.0% (4/16) | | NWEIG (N=12) | 91.7% (11/12) | 91.7% (11/12) | 58.3% (7/12) | 75.0% (9/12) | 66.7% (8/12) | 0.0% (0/12) | 8.3% (1/12) | | ORENG (N=7) | 71.4% (5/7) | 71.4% (5/7) | 28.6% (2/7) | 42.9% (3/7) | 28.6% (2/7) | 0.0% (0/7) | 28.6% (2/7) | | PENNEC (N=8) | 87.5% (7/8) | 87.5% (7/8) | 62.5% (5/8) | 62.5% (5/8) | 50.0% (4/8) | 0.0% (0/8) | 12.5% (1/8) | | SETPEG (N=8) | 75.0% (6/8) | 87.5% (7/8) | 62.5% (5/8) | 62.5% (5/8) | 62.5% (5/8) | 0.0% (0/8) | 12.5% (1/8) | | SWEP (N=4) | 100% (4/4) | 100% (4/4) | 75.0% (3/4) | 75.0% (3/4) | 50.0% (2/4) | 0.0% (0/4) | 0.0% (0/4) | | SWIPE (N=9) | 77.8% (7/9) | 77.8% (7/9) | 33.3% (3/9) | 44.4% (4/9) | 33.3% (3/9) | 22.2% (2/9) | 11.1% (1/9) | | SWTPEG (N=7) | 71.4% (5/7) | 85.7% (6/7) | 57.1% (4/7) | 42.9% (3/7) | 57.1% (4/7) | 0.0% (0/7) | 14.3% (1/7) | | TEN (N=6) | 66.7% (4/6) | 83.3% (5/6) | 66.7% (4/6) | 83.3% (5/6) | 50.0% (3/6) | 0.0% (0/6) | 16.7% (1/6) | | WPNN (N=9) | 55.6% (5/9) | 44.4% (4/9) | 33.3% (3/9) | 33.3% (3/9) | 33.3% (3/9) | 11.1% (1/9) | 44.4% (4/9) | | YPEN (N=9) | 88.9% (8/9) | 88.9% (8/9) | 33.3% (3/9) | 55.6% (5/9) | 33.3% (3/9) | 11.1% (1/9) | 11.1% (1/9) | Care planning
80.1% (109/136) of Health Boards and Trusts reported that they routinely undertook comprehensive care planning for children and young people with epilepsy.
Table 45: Health Boards and Trusts that routinely undertake comprehensive care planning for children and young people with epilepsy
| Country/network | Yes | No | |-----------------|--------------|-------------| | England and Wales (N=136) | 80.1% (109/136) | 19.9% (27/136) | | England (N=131) | 80.2% (105/131) | 19.8% (26/131) | | Wales (N=5) | 80.0% (4/5) | 20.0% (1/5) | | BRPNF (N=13) | 76.9% (10/13) | 23.1% (3/13) | | CEWT (N=5) | 80.0% (4/5) | 20.0% (1/5) | | EPEN (N=14) | 85.7% (12/14) | 14.3% (2/14) | | EPIC (N=9) | 88.9% (8/9) | 11.1% (1/9) | | NTPEN (N=16) | 87.5% (14/16) | 12.5% (2/16) | | NWEIG (N=12) | 83.3% (10/12) | 16.7% (2/12) | | ORENG (N=7) | 71.4% (5/7) | 28.6% (2/7) | | PENNEC (N=8) | 62.5% (5/8) | 37.5% (3/8) | | SETPEG (N=8) | 87.5% (7/8) | 12.5% (1/8) | | SWEP (N=4) | 75.0% (3/4) | 25.0% (1/4) | | SWIPE (N=9) | 55.6% (5/9) | 44.4% (4/9) | | SWTPEG (N=7) | 85.7% (6/7) | 14.3% (1/7) | | TEN (N=6) | 83.3% (5/6) | 16.7% (1/6) | | WPNN (N=9) | 77.8% (7/9) | 22.2% (2/9) | | YPEN (N=9) | 88.9% (8/9) | 11.1% (1/9) | Patient database or registry
33.8% (46/136) of Health Boards and Trusts reported that they maintain a database or register for all children and young people with epilepsies; 39.7% (54/136) reported that they maintain a database or register for some children and young people with epilepsies; and 26.5% (36/136) Health Boards and Trusts, reported that they do not maintain a database or register, (Table 46).
Table 46: Health Boards and Trusts maintaining a database or register of children and young people with epilepsies, other than Epilepsy12.
| Country/network | Yes, all | Yes, some | No | |-----------------|----------|-----------|----| | England and Wales (N=136) | 33.8% (46/136) | 39.7% (54/136) | 26.5% (36/136) | | England (N=131) | 35.1% (46/131) | 38.9% (51/131) | 26.0% (34/131) | | Wales (N=5) | 0.0% (0/5) | 60.0% (3/5) | 40.0% (2/5) | | BRPNF (N=13) | 7.7% (1/13) | 53.8% (7/13) | 38.5% (5/13) | | CEWT (N=5) | 0.0% (0/5) | 40.0% (2/5) | 60.0% (3/5) | | EPEN (N=14) | 42.9% (6/14) | 28.6% (4/14) | 28.6% (4/14) | | EPIC (N=9) | 44.4% (4/9) | 22.2% (2/9) | 33.3% (3/9) | | NTPEN (N=16) | 31.3% (5/16) | 50.0% (8/16) | 18.8% (3/16) | | NWEIG (N=12) | 41.7% (5/12) | 41.7% (5/12) | 16.7% (2/12) | | ORENG (N=7) | 28.6% (2/7) | 42.9% (3/7) | 28.6% (2/7) | | PENNEC (N=8) | 37.5% (3/8) | 37.5% (3/8) | 25.0% (2/8) | | SETPEG (N=8) | 50.0% (4/8) | 12.5% (1/8) | 37.5% (3/8) | | SWEP (N=4) | 0.0% (0/4) | 50.0% (2/4) | 50.0% (2/4) | | SWIPE (N=9) | 33.3% (3/9) | 44.4% (4/9) | 22.2% (2/9) | | SWTPEG (N=7) | 42.9% (3/7) | 42.9% (3/7) | 14.3% (1/7) | | TEN (N=6) | 33.3% (2/6) | 33.3% (2/6) | 33.3% (2/6) | | WPNN (N=9) | 44.4% (4/9) | 44.4% (4/9) | 11.1% (1/9) | | YPEN (N=9) | 44.4% (4/9) | 44.4% (4/9) | 11.1% (1/9) | Appendix B: Organisational findings by OPEN UK regional networks
% of Health Boards and Trusts employing a consultant paediatrician with expertise in epilepsy
| Network | Percentage | |------------------------------------------------------------------------|------------| | Yorkshire Paediatric Neurology Network | 100.0% | | Trent Epilepsy Network | 100.0% | | South West Interest Group Paediatric Epilepsy | 100.0% | | South Wales Epilepsy Forum | 100.0% | | South East Thames Paediatric Epilepsy Group | 100.0% | | Paediatric Epilepsy Network for the North East and Cumbria | 100.0% | | Oxford Region Epilepsy Interest Group | 100.0% | | North West Children and Young People's Epilepsy Interest Group | 100.0% | | England and Wales combined | 93.4% | | Eastern Paediatric Epilepsy Network | 92.9% | | Birmingham Regional Paediatric Neurology Forum | 92.3% | | Wessex Paediatric Neurosciences Network | 88.9% | | Mersey and North Wales network 'Epilepsy In Childhood' interest group | 88.9% | | North Thames Paediatric Epilepsy Network | 87.5% | | South West Thames Paediatric Epilepsy Group | 85.7% | | Children's Epilepsy Workstream in Trent | 60.0% | % of Health Boards and Trusts that had a defined paediatric epilepsy clinical lead
- Trent Epilepsy Network: 100.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 100.0%
- Oxford Region Epilepsy Interest Group: 100.0%
- North West Children and Young People’s Epilepsy Interest Group: 100.0%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 100.0%
- Eastern Paediatric Epilepsy Network: 92.9%
- Yorkshire Paediatric Neurology Network: 88.9%
- South West Interest Group Paediatric Epilepsy: 88.9%
- England and Wales combined: 88.2%
- North Thames Paediatric Epilepsy Network: 87.5%
- South West Thames Paediatric Epilepsy Group: 85.7%
- Birmingham Regional Paediatric Neurology Forum: 84.6%
- Children’s Epilepsy Workstream in Trent: 80.0%
- Wessex Paediatric Neurosciences Network: 77.8%
- South Wales Epilepsy Forum: 75.0%
- South East Thames Paediatric Epilepsy Group: 50.0% % of Health Boards and Trusts who had some epilepsy specialist nurse (ESN) provision within their paediatric service
| Organisation | Percentage | |---------------------------------------------------|------------| | Yorkshire Paediatric Neurology Network | 100.0% | | Trent Epilepsy Network | 100.0% | | Mersey and North Wales network 'Epilepsy In Childhood' interest group | 100.0% | | North West Children and Young People's Epilepsy Interest Group | 91.7% | | Wessex Paediatric Neurosciences Network | 88.9% | | Eastern Paediatric Epilepsy Network | 85.7% | | England and Wales combined | 81.6% | | North Thames Paediatric Epilepsy Network | 81.3% | | Children's Epilepsy Workstream in Trent | 80.0% | | South Wales Epilepsy Forum | 75.0% | | South East Thames Paediatric Epilepsy Group | 75.0% | | Paediatric Epilepsy Network for the North East and Cumbria | 75.0% | | South West Thames Paediatric Epilepsy Group | 71.4% | | Oxford Region Epilepsy Interest Group | 71.4% | | South West Interest Group Paediatric Epilepsy | 66.7% | | Birmingham Regional Paediatric Neurology Forum | 61.5% | % of Health Boards Trusts that indicated that they could offer ESN support for rescue medication training for parents
| Organisation | Percentage | |------------------------------------------------------------------------------|------------| | Yorkshire Paediatric Neurology Network | 100.0% | | Trent Epilepsy Network | 100.0% | | Mersey and North Wales network ‘Epilepsy In Childhood’ interest group | 100.0% | | Eastern Paediatric Epilepsy Network | 85.7% | | North West Children and Young People’s Epilepsy Interest Group | 83.3% | | North Thames Paediatric Epilepsy Network | 81.3% | | England and Wales combined | 80.1% | | Children’s Epilepsy Workstream in Trent | 80.0% | | Wessex Paediatric Neurosciences Network | 77.8% | | South Wales Epilepsy Forum | 75.0% | | South East Thames Paediatric Epilepsy Group | 75.0% | | Paediatric Epilepsy Network for the North East and Cumbria | 75.0% | | South West Thames Paediatric Epilepsy Group | 71.4% | | Oxford Region Epilepsy Interest Group | 71.4% | | South West Interest Group Paediatric Epilepsy | 66.7% | | Birmingham Regional Paediatric Neurology Forum | 61.5% | % of Health Boards and Trusts that had a defined epilepsy clinic seeing patients at secondary level
- Trent Epilepsy Network: 100.0%
- South West Thames Paediatric Epilepsy Group: 100.0%
- South Wales Epilepsy Forum: 100.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 100.0%
- North West Children and Young People's Epilepsy Interest Group: 100.0%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 100.0%
- Children's Epilepsy Workstream in Trent: 100.0%
- England and Wales combined: 89.7%
- Yorkshire Paediatric Neurology Network: 88.9%
- Wessex Paediatric Neurosciences Network: 88.9%
- South East Thames Paediatric Epilepsy Group: 87.5%
- North Thames Paediatric Epilepsy Network: 87.5%
- Oxford Region Epilepsy Interest Group: 85.7%
- Eastern Paediatric Epilepsy Network: 85.7%
- South West Interest Group Paediatric Epilepsy: 77.8%
- Birmingham Regional Paediatric Neurology Forum: 69.2% % of Trusts in England that currently run Epilepsy Best Practice Criteria (BPC) clinics
- Wessex Paediatric Neurosciences Network: 66.7%
- Trent Epilepsy Network: 66.7%
- Children’s Epilepsy Workstream in Trent: 60.0%
- South West Thames Paediatric Epilepsy Group: 57.1%
- Oxford region epilepsy interest group: 57.1%
- Yorkshire Paediatric Neurology Network: 55.6%
- Paediatric Epilepsy Network for the North East and Cumbria: 50.0%
- Eastern Paediatric Epilepsy Network: 50.0%
- England only: 46.6%
- South West Interest Group Paediatric Epilepsy: 44.4%
- North West Children and Young People’s Epilepsy Interest Group: 41.7%
- South East Thames Paediatric Epilepsy Group: 37.5%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 37.5%
- North Thames Paediatric Epilepsy Network: 31.3%
- Birmingham Regional Paediatric Neurology Forum: 30.8% % of Health Boards and Trusts that have some tertiary provision within their paediatric service (paediatric neurologists who manage children with epilepsy (acutely and/or non-acutely))
- Children's Epilepsy Workstream in Trent: 40.0%
- Trent Epilepsy Network: 33.3%
- South Wales Epilepsy Forum: 25.0%
- South East Thames Paediatric Epilepsy Group: 25.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 25.0%
- North Thames Paediatric Epilepsy Network: 25.0%
- England and Wales Combined: 16.9%
- North West Children and Young People's Epilepsy Interest Group: 16.7%
- South West Thames Paediatric Epilepsy Group: 14.3%
- Oxford region epilepsy interest group: 14.3%
- Yorkshire Paediatric Neurology Network: 11.1%
- Wessex Paediatric Neurosciences Network: 11.1%
- South West Interest Group Paediatric Epilepsy: 11.1%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 11.1%
- Birmingham Regional Paediatric Neurology Forum: 7.7%
- Eastern Paediatric Epilepsy Network: 7.1% % of Health Boards and Trusts that had agreed referral pathways to tertiary paediatric neurology services
| Organisation | Percentage | |------------------------------------------------------------------------------|------------| | Trent Epilepsy Network | 100.0% | | South West Thames Paediatric Epilepsy Group | 100.0% | | South East Thames Paediatric Epilepsy Group | 100.0% | | North Thames Paediatric Epilepsy Network | 100.0% | | Mersey and North Wales network ‘Epilepsy In Childhood’ interest group | 100.0% | | Eastern Paediatric Epilepsy Network | 100.0% | | Children’s Epilepsy Workstream in Trent | 100.0% | | England and Wales Combined | 92.6% | | North West Children and Young People’s Epilepsy Interest Group | 91.7% | | Yorkshire Paediatric Neurology Network | 88.9% | | Wessex Paediatric Neurosciences Network | 88.9% | | South West Interest Group Paediatric Epilepsy | 88.9% | | Paediatric Epilepsy Network for the North East and Cumbria | 87.5% | | Oxford region epilepsy interest group | 85.7% | | Birmingham Regional Paediatric Neurology Forum | 76.9% | | South Wales Epilepsy Forum | 75.0% | % of Health Boards and Trusts that were able to facilitate Vagal Nerve Stimulation (VNS) review at a location within the Health Board or Trust
- South Wales Epilepsy Forum: 75.0%
- South East Thames Paediatric Epilepsy Group: 50.0%
- South West Interest Group Paediatric Epilepsy: 44.4%
- Children's Epilepsy Workstream in Trent: 40.0%
- Trent Epilepsy Network: 33.3%
- Paediatric Epilepsy Network for the North East and Cumbria: 25.0%
- North West Children and Young People's Epilepsy Interest Group: 25.0%
- Yorkshire Paediatric Neurology Network: 22.2%
- England and Wales Combined: 21.3%
- Oxford region epilepsy interest group: 14.3%
- Eastern Paediatric Epilepsy Network: 14.3%
- Wessex Paediatric Neurosciences Network: 11.1%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 11.1%
- Birmingham Regional Paediatric Neurology Forum: 7.7%
- North Thames Paediatric Epilepsy Network: 6.3%
- South West Thames Paediatric Epilepsy Group: 0.0% % of Health Boards and Trusts that could provide specialist advice between scheduled reviews every weekday for 52 weeks per year
- Children’s Epilepsy Workstream in Trent: 80.0%
- Yorkshire Paediatric Neurology Network: 77.8%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 77.8%
- South Wales Epilepsy Forum: 75.0%
- North West Children and Young People’s Epilepsy Interest Group: 75.0%
- Oxford region epilepsy interest group: 57.1%
- Wessex Paediatric Neurosciences Network: 55.6%
- England and Wales Combined: 48.5%
- North Thames Paediatric Epilepsy Network: 43.8%
- Eastern Paediatric Epilepsy Network: 42.9%
- Birmingham Regional Paediatric Neurology Forum: 38.5%
- Trent Epilepsy Network: 33.3%
- South East Thames Paediatric Epilepsy Group: 25.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 25.0%
- South West Interest Group Paediatric Epilepsy: 22.2%
- South West Thames Paediatric Epilepsy Group: 14.3% % of Health Boards and Trusts that have evidence of a clear point of contact for non-paediatric professionals seeking paediatric epilepsy support.
- South Wales Epilepsy Forum: 100.0%
- North West Children and Young People’s Epilepsy Interest Group: 91.7%
- Mersey and North Wales network ‘Epilepsy in Childhood’ interest group: 88.9%
- Eastern Paediatric Epilepsy Network: 85.7%
- Trent Epilepsy Network: 83.3%
- North Thames Paediatric Epilepsy Network: 81.3%
- Yorkshire Paediatric Neurology Network: 77.8%
- South West Interest Group Paediatric Epilepsy: 77.8%
- England and Wales Combined: 76.5%
- South East Thames Paediatric Epilepsy Group: 75.0%
- South West Thames Paediatric Epilepsy Group: 71.4%
- Oxford region epilepsy interest group: 71.4%
- Wessex Paediatric Neurosciences Network: 66.7%
- Birmingham Regional Paediatric Neurology Forum: 61.5%
- Children’s Epilepsy Workstream in Trent: 60.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 50.0% % of Health Boards and Trusts that have agreed referral pathway to adult services.
- Yorkshire Paediatric Neurology Network: 100.0%
- South West Thames Paediatric Epilepsy Group: 100.0%
- Eastern Paediatric Epilepsy Network: 92.9%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 88.9%
- Oxford region epilepsy interest group: 85.7%
- Trent Epilepsy Network: 83.3%
- Children’s Epilepsy Workstream in Trent: 80.0%
- England and Wales Combined: 79.4%
- Wessex Paediatric Neurosciences Network: 77.8%
- South Wales Epilepsy Forum: 75.0%
- South East Thames Paediatric Epilepsy Group: 75.0%
- North West Children and Young People’s Epilepsy Interest Group: 75.0%
- North Thames Paediatric Epilepsy Network: 75.0%
- South West Interest Group Paediatric Epilepsy: 66.7%
- Paediatric Epilepsy Network for the North East and Cumbria: 62.5%
- Birmingham Regional Paediatric Neurology Forum: 61.5% % of Health Boards and Trusts that have an outpatient clinic specifically for young people with epilepsies
- Children's Epilepsy Workstream in Trent: 60.0%
- Eastern Paediatric Epilepsy Network: 57.1%
- Wessex Paediatric Neurosciences Network: 55.6%
- South East Thames Paediatric Epilepsy Group: 50.0%
- North West Children and Young People's Epilepsy Interest Group: 50.0%
- South West Thames Paediatric Epilepsy Group: 42.9%
- Birmingham Regional Paediatric Neurology Forum: 38.5%
- England and Wales Combined: 36.8%
- South West Interest Group Paediatric Epilepsy: 33.3%
- North Thames Paediatric Epilepsy Network: 31.3%
- Oxford region epilepsy interest group: 28.6%
- South Wales Epilepsy Forum: 25.0%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 22.2%
- Trent Epilepsy Network: 16.7%
- Paediatric Epilepsy Network for the North East and Cumbria: 12.5%
- Yorkshire Paediatric Neurology Network: 11.1% % of Health Boards and Trusts that have an outpatient epilepsy service involving adult and paediatric professionals
- South Wales Epilepsy Forum: 75.0%
- South West Thames Paediatric Epilepsy Group: 71.4%
- Oxford region epilepsy interest group: 71.4%
- North Thames Paediatric Epilepsy Network: 68.8%
- South West Interest Group Paediatric Epilepsy: 66.7%
- North West Children and Young People’s Epilepsy Interest Group: 66.7%
- Birmingham Regional Paediatric Neurology Forum: 61.5%
- Children’s Epilepsy Workstream in Trent: 60.0%
- England and Wales Combined: 55.9%
- Yorkshire Paediatric Neurology Network: 55.6%
- Wessex Paediatric Neurosciences Network: 55.6%
- South East Thames Paediatric Epilepsy Group: 50.0%
- Eastern Paediatric Epilepsy Network: 50.0%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 44.4%
- Trent Epilepsy Network: 16.7%
- Paediatric Epilepsy Network for the North East and Cumbria: 12.5% % of Health Boards and Trusts that have structured resources to support Young People transition
- South West Interest Group Paediatric Epilepsy: 88.9%
- Yorkshire Paediatric Neurology Network: 77.8%
- North West Children and Young People's Epilepsy Interest Group: 75.0%
- South West Thames Paediatric Epilepsy Group: 71.4%
- Wessex Paediatric Neurosciences Network: 66.7%
- Trent Epilepsy Network: 66.7%
- Eastern Paediatric Epilepsy Network: 64.3%
- Paediatric Epilepsy Network for the North East and Cumbria: 62.5%
- Children's Epilepsy Workstream in Trent: 60.0%
- England and Wales Combined: 58.1%
- Oxford region epilepsy interest group: 57.1%
- Birmingham Regional Paediatric Neurology Forum: 46.2%
- North Thames Paediatric Epilepsy Network: 43.8%
- South East Thames Paediatric Epilepsy Group: 37.5%
- South Wales Epilepsy Forum: 25.0%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 22.2% % of Health Boards and Trusts that facilitate mental health provision within epilepsy clinics
- South East Thames Paediatric Epilepsy Group: 37.5%
- South West Thames Paediatric Epilepsy Group: 28.6%
- North Thames Paediatric Epilepsy Network: 25.0%
- Wessex Paediatric Neurosciences Network: 22.2%
- Mersey and North Wales network 'Epilepsy in Childhood' interest group: 22.2%
- Trent Epilepsy Network: 16.7%
- North West Children and Young People's Epilepsy Interest Group: 16.7%
- Eastern Paediatric Epilepsy Network: 14.3%
- England and Wales Combined: 14.0%
- Yorkshire Paediatric Neurology Network: 11.1%
- South West Interest Group Paediatric Epilepsy: 0.0%
- South Wales Epilepsy Forum: 0.0%
- Paediatric Epilepsy Network for the North East and Cumbria: 0.0%
- Oxford region epilepsy interest group: 0.0%
- Children's Epilepsy Workstream in Trent: 0.0%
- Birmingham Regional Paediatric Neurology Forum: 0.0% % of Health Boards and Trusts that routinely undertook comprehensive care planning for children with epilepsy
- Yorkshire Paediatric Neurology Network: 88.9%
- Mersey and North Wales network ‘Epilepsy In Childhood’ interest group: 88.9%
- South East Thames Paediatric Epilepsy Group: 87.5%
- North Thames Paediatric Epilepsy Network: 87.5%
- South West Thames Paediatric Epilepsy Group: 85.7%
- Eastern Paediatric Epilepsy Network: 85.7%
- Trent Epilepsy Network: 83.3%
- North West Children and Young People’s Epilepsy Interest Group: 83.3%
- England and Wales Combined: 80.1%
- Children’s Epilepsy Workstream in Trent: 80.0%
- Wessex Paediatric Neurosciences Network: 77.8%
- Birmingham Regional Paediatric Neurology Forum: 76.9%
- South Wales Epilepsy Forum: 75.0%
- Oxford region epilepsy interest group: 71.4%
- Paediatric Epilepsy Network for the North East and Cumbria: 62.5%
- South West Interest Group Paediatric Epilepsy: 55.6% % of Health Boards and Trusts that maintain a database or register for all the children with epilepsies
- South East Thames Paediatric Epilepsy Group: 50.0%
- Yorkshire Paediatric Neurology Network: 44.4%
- Wessex Paediatric Neurosciences Network: 44.4%
- Mersey and North Wales network 'Epilepsy In Childhood' interest group: 44.4%
- South West Thames Paediatric Epilepsy Group: 42.9%
- Eastern Paediatric Epilepsy Network: 42.9%
- North West Children and Young People's Epilepsy Interest Group: 41.7%
- Paediatric Epilepsy Network for the North East and Cumbria: 37.5%
- England and Wales Combined: 33.8%
- Trent Epilepsy Network: 33.3%
- South West Interest Group Paediatric Epilepsy: 33.3%
- North Thames Paediatric Epilepsy Network: 31.3%
- Oxford region epilepsy interest group: 28.6%
- Birmingham Regional Paediatric Neurology Forum: 7.7%
- South Wales Epilepsy Forum: 0.0%
- Children's Epilepsy Workstream in Trent: 0.0% Appendix C: List of Organisational data figures & tables
Figure 1: Total whole-time equivalent consultant paediatrician with ‘expertise in epilepsy’ employed in England and Wales in Round 1, Round 2, Round 3 April 2018 and Round 3 November 2019. – page 7
Figure 2: Total Whole Time Equivalent epilepsy specialist nurses employed in England and Wales in Round 1, Round 2, Round 3 April 2018 and November 2019. – page 10
Figure 3: Percentage of Health Boards and Trusts that could support epilepsy specialist nurse functions (n=136) – page 11
Figure 4: Percentage of Health Boards and Trusts that could support epilepsy specialist nurse functions in in Round 3 April 2018 and November 2019. – page 12
Figure 5: Total number of consultant or associate specialist led secondary level epilepsy clinics in Round 1, Round 2, Round 3 April 2018 and November 2019. – page 18
Figure 6: Percentage of Trusts receiving TFC 223 Epilepsy Best Practice Criteria (England only) (n=131) – page 22
Figure 7: Percentage of Trusts receiving TFC 223 Epilepsy Best Practice Criteria (England only) in Round 3 April 2018 and November 2019. – page 22
Figure 8: Percentage of Health Boards and Trusts that could provide ketogenetic diet and vagal nerve stimulator services (n=136) – page 27
Figure 9: Percentage of Health Boards and Trusts that could provide ketogenetic diet and vagal nerve stimulator services in Round 3 April 2018 and November 2019 – page 28
Figure 10: Percentage of Health Boards and Trusts that could provide investigation services (n=136) – page 31
Figure 11: Percentage of Health Boards and Trusts that could provide investigation services in Round 3 April 2018 and November 2019– page 32
Figure 12: Availability of specialist advice between scheduled reviews (n=136) – page 38
Figure 13: Percentage availability of specialist advice between scheduled reviews in Round 3 April 2018 and November 2019 – page 39
Figure 14: Typical response time for specialist advice (n=130) – page 40
Figure 15: Typical response time for specialist advice in Round 3 April 2018 and November 2019 – page 40
Figure 16: Professional who ‘typically’ provides initial specialist advice (n=130) – page 41
Figure 17: Professional who ‘typically’ provides initial specialist advice Round 3 April 2018 and November 2019 – page 41
Figure 18: Clinics for young people across Rounds 1, Round 2, Round 3 April 2018 and November 2019 – page 47
Figure 19: Composition of joint transition process (n=76) – page 48
Figure 20: Composition of joint transition process in Round 3 November 2019 and April 2018. – page 49
Figure 21: Professionals routinely involved in transition or transfer to adult services (n=136) – page 50 Figure 22: Professionals routinely involved in transition or transfer to adult services in Round 3 April 2018 and November 2019 - page 50
Figure 23: Percentage of Health Boards and Trusts that were using structured resources to support transition in Round 3 April 2018 and November 2019 - page 51
Figure 24: Percentage of Health Boards and Trusts routinely providing formal screening services (n=136) - page 57
Figure 25: Percentage of Health Boards and Trusts routinely providing formal screening services in Round 3 April 2018 and November 2019 - page 58
Figure 26: Percentage of Health Boards and Trusts with agreed referral pathways for children with mental health concerns (n=136) - page 59
Figure 27: Percentage of Health Boards and Trusts that could refer to mental health services (n=136) - page 60
Figure 28: Percentage of Health Boards and Trusts that could refer to mental health services in Round 3 April 2018 and November 2019 - page 61
Figure 29: Percentage of Health Boards and Trusts that had agreed referral criteria for children and young people with neuro-developmental problems (n=136) - page 69
Tables for the organisational audit
Table 1: Epilepsy12 Round 3 2019 Organisational Audit participation by Paediatric Epilepsy Networks and by country - page 6
Table 2: Whole time equivalent (WTE) general paediatric consultants, community or hospital based, employed within Health Boards or Trusts - page 8
Table 3: Whole time equivalent (WTE) general paediatric consultants with 'expertise in epilepsy', excluding paediatric neurologists, employed within Health Boards or Trusts - page 8
Table 4: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) consultant paediatrician with 'expertise in epilepsy' - page 9
Table 5: Health Boards and Trusts that had a defined paediatric epilepsy clinical lead - page 9
Table 6: Whole time equivalent (WTE) epilepsy specialist nurses employed within Health Boards or Trust - page 13
Table 7: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) epilepsy specialist nurse - page 13
Table 8: Health Boards and Trusts that could support epilepsy nurse functions (n=136) - page 14
Table 8 (continued): Health Boards and Trusts that could support epilepsy nurse functions (n=136) - page 15
Table 9: Health Boards and Trusts that could support epilepsy nurse functions (n=111) - page 16
Table 9 (continued): Health Boards and Trusts that could support epilepsy nurse functions (n=111) - page 17 Table 10: Health Boards and Trusts that had a defined epilepsy – page 19 Table 11: Number of consultant or associate specialist led secondary level 'epilepsy clinics' taking place within Health Boards and Trusts per week – page 20 Table 12: Defined epilepsy clinics that allowed at least 20 minutes with a consultant with 'expertise in epilepsy' and/or an epilepsy specialist nurse – page 21 Table 13: Trusts that were running TFC 223 Epilepsy Best Practice Criteria (BPC) clinics – page 23 Table 14: Whole time equivalent (WTE) paediatric neurologists, acutely and/or non-acutely, employed within Health Boards or Trusts – page 24 Table 15: Health Boards and Trusts that employed at least some level of whole time equivalent (WTE) paediatric neurologists, acutely and/or non-acutely – page 24 Table 16: Health Boards and Trusts with agreed referral pathways to tertiary paediatric neurology services – page 25 Table 17a: Health Boards and Trusts that could receive paediatric neurological direct referrals from general practice and emergency departments – page 25 Table 17b: Health Boards and Trusts that could receive paediatric neurological direct referrals from general practice and emergency departments (excl. N/A) – page 26 Table 18: Health Boards and Trusts that were hosting satellite paediatric neurology clinics – page 26 Table 19: Health Boards and Trusts that could facilitate the commencement of a ketogenic diet – page 29 Table 20: Health Boards and Trusts that could undertake ongoing review of a ketogenic diet – page 29 Table 21: Health Boards and Trusts that were able to insert vagal nerve stimulator – page 30 Table 22: Health Boards and Trusts that were able to review vagal nerve stimulator – page 30 Table 23: Health Boards and Trusts that could provide epilepsy investigation services – page 33 Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services – page 34 Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services – page 35 Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services – page 36 Table 23 (continued): Health Boards and Trusts that could provide epilepsy investigation services – page 37 Table 24: Health Boards and Trusts providing specialist advice between scheduled reviews – page 42 Table 25: Availability of Health Boards and Trusts between scheduled reviews – page 43 Table 26: Typical response time to specialist advice – page 44 Table 27: Professional who ‘typically’ provides initial specialist advice – page 45 Table 28: Health Boards and Trusts with evidence of a clear point of contact for non-paediatric professionals seeking paediatric epilepsy support – page 46 Table 29: Health Boards and Trusts that had an agreed referral pathway to adult services - page 52 Table 30: Health Boards and Trusts that had an outpatient clinic specifically for young people with epilepsies - page 53 Table 31: Age at which the outpatient clinic typically accepted young people with epilepsies - page 53 Table 32: Health Boards and Trusts that had an outpatient service involving adult and paediatric professionals - page 54 Table 33: Structure of outpatient service involving both adult and paediatric professionals - page 54 Table 34: Estimated percentage of young people transferred to adult services through a joint professional process - page 55 Table 35: Health Boards and Trusts that were using structured resources to support transition - page 55 Table 36: Adult professionals routinely involved in transition or transfer to adult services - page 56 Table 37: Health Boards and Trusts that formally screen for diagnoses related to epilepsy - page 62 Table 38: Health Boards and Trusts using particular mental health screening questionnaires - page 63 Table 38 (continued): Health Boards and Trusts using particular mental health screening questionnaires - page 64 Table 39: Health Boards and Trusts with agreed referral pathways for children and young people with mental health concerns - page 65 Table 40: Health Boards and Trusts that were facilitating mental health provision within epilepsy clinics - page 66 Table 41: Composition of mental health provision within epilepsy clinics - page 66 Table 42: Health Boards and Trusts that had an action plan describing steps towards co-located mental health provision - page 67 Table 43: Health Boards and Trusts that could refer to mental health services - page 68 Table 44: Health Boards and Trusts that had agreed referral criteria for children and young people with neuro-developmental problems - page 70 Table 45: Health Boards and Trusts that routinely undertake comprehensive care planning for children and young people with epilepsy - page 71 Table 46: Health Boards and Trusts maintaining a database or register of children and young people with epilepsies, other than Epilepsy12 - page 72 Appendix D: Participating Health Boards and Trusts by OPEN UK region
The following list shows the NHS Health Boards and Trusts across England and Wales that submitted data to the Epilepsy12 Round 3 clinical and organisational audit in 2018-19.
| Birmingham Regional Paediatric Neurology Forum (BRPNF) | |--------------------------------------------------------| | Birmingham Community Healthcare NHS Foundation Trust | | Birmingham Women’s and Children’s NHS Foundation Trust | | Burton Hospitals NHS Foundation Trust\* | | Coventry and Warwickshire Partnership NHS Trust | | George Eliot Hospital NHS Trust | | Sandwell and West Birmingham Hospitals NHS Trust | | South Warwickshire NHS Foundation Trust | | The Dudley Group NHS Foundation Trust | | The Royal Wolverhampton NHS Trust | | University Hospitals Birmingham NHS Foundation Trust | | University Hospitals Coventry and Warwickshire NHS Trust| | Walsall Healthcare NHS Trust | | Worcestershire Acute Hospitals NHS Trust | | Worcestershire Health and Care NHS Trust | | Wye Valley NHS Trust |
| Children’s Epilepsy Workstream in Trent (CEWT) | |--------------------------------------------------------| | Derby Teaching Hospitals NHS Foundation Trust\* | | Leicestershire Partnership NHS Trust | | Nottingham University Hospitals NHS Trust | | Sherwood Forest Hospitals NHS Foundation Trust | | United Lincolnshire Hospitals NHS Trust | | University Hospitals of Leicester NHS Trust |
| Eastern Paediatric Epilepsy Network (EPEN) | |--------------------------------------------------------| | Bedford Hospital NHS Trust | | Cambridge University Hospitals NHS Foundation Trust | | Cambridgeshire Community Services NHS Trust | | Colchester Hospital University NHS Foundation Trust\* | | East and North Hertfordshire NHS Trust | | Ipswich Hospital NHS Trust\* | | Hospital Name | Trust Name | |------------------------------------------------------------------------------|----------------------------------------------------------------------------| | James Paget University Hospitals NHS Foundation Trust | Luton and Dunstable University Hospital NHS Foundation Trust | | Mid Essex Hospital Services NHS Trust | Norfolk and Norwich University Hospitals NHS Foundation Trust | | Norfolk Community Health and Care NHS Trust | North West Anglia NHS Foundation Trust | | North West Anglia NHS Foundation Trust | The Princess Alexandra Hospital NHS Trust | | The Queen Elizabeth Hospital, King’s Lynn, NHS Foundation Trust | West Suffolk NHS Foundation Trust | | Mersey and North Wales network ‘Epilepsy In Childhood’ interest group (EPIC) | Alder Hey Children’s NHS Foundation Trust | | Betsi Cadwaladr University LHB | Countess of Chester Hospital NHS Foundation Trust | | Mid Cheshire Hospitals NHS Foundation Trust | Shrewsbury and Telford Hospital NHS Trust | | Southport and Ormskirk Hospital NHS Trust | St Helens and Knowsley Hospitals NHS Trust | | Warrington and Halton Hospitals NHS Foundation Trust | Wirral University Teaching Hospital NHS Foundation Trust | | North Thames Paediatric Epilepsy Network (NTPEN) | Barking, Havering and Redbridge University Hospitals NHS Trust | | Barts Health NHS Trust | Basildon and Thurrock University Hospitals NHS Foundation Trust | | Central and North West London NHS Foundation Trust | Chelsea and Westminster Hospital NHS Foundation Trust | | Great Ormond Street Hospital For Children NHS Foundation Trust | Homerton University Hospital NHS Foundation Trust | | Imperial College Healthcare NHS Trust | London North West Healthcare NHS Trust | | North East London NHS Foundation Trust | North Middlesex University Hospital NHS Trust | | Royal Free London NHS Foundation Trust | Southend University Hospital NHS Foundation Trust | | The Hillingdon Hospitals NHS Foundation Trust | The Whittington Hospital NHS Trust | | University College London Hospitals NHS Foundation Trust | West Hertfordshire Hospitals NHS Trust | | North West Children and Young People's Epilepsy Interest Group (NWEIG) | |---------------------------------------------------------------| | Blackpool Teaching Hospitals NHS Foundation Trust | | Bolton NHS Foundation Trust | | East Cheshire NHS Trust | | East Lancashire Hospitals NHS Trust | | Lancashire Teaching Hospitals NHS Foundation Trust | | Manchester University NHS Foundation Trust | | Northern Care Alliance NHS Group | | Salford Royal NHS Foundation Trust\* | | Stockport NHS Foundation Trust | | Tameside and Glossop Integrated Care NHS Foundation Trust | | University Hospitals of Morecambe Bay NHS Foundation Trust | | University Hospitals of North Midlands NHS Trust | | Wrightington, Wigan and Leigh NHS Foundation Trust |
| Oxford region epilepsy interest group (ORENG) | |--------------------------------------------------------------| | Buckinghamshire Healthcare NHS Trust | | Great Western Hospitals NHS Foundation Trust | | Kettering General Hospital NHS Foundation Trust | | Milton Keynes University Hospital NHS Foundation Trust | | Northampton General Hospital NHS Trust | | Oxford University Hospitals NHS Foundation Trust | | Royal Berkshire NHS Foundation Trust |
| Paediatric Epilepsy Network for the North East and Cumbria (PENNEC) | |---------------------------------------------------------------------| | City Hospitals Sunderland NHS Foundation Trust\* | | County Durham and Darlington NHS Foundation Trust | | Gateshead Health NHS Foundation Trust | | North Cumbria University Hospitals NHS Trust | | North Tees and Hartlepool NHS Foundation Trust | | Northumbria Healthcare NHS Foundation Trust | | South Tees Hospitals NHS Foundation Trust | | South Tyneside NHS Foundation Trust\* | | The Newcastle Upon Tyne Hospitals NHS Foundation Trust |
| South East Thames Paediatric Epilepsy Group (SETPEG) | |----------------------------------------------------------------| | Brighton and Sussex University Hospitals NHS Trust | | Dartford and Gravesham NHS Trust | | East Kent : QEQM, Margate and WHM, Ashford, Kent | | East Sussex Healthcare NHS Trust | | Trust Name | |---------------------------------------------------------------------------| | Guy’s and St Thomas’ NHS Foundation Trust | | King’s College Hospital NHS Foundation Trust | | Lewisham and Greenwich NHS Trust | | Maidstone and Tunbridge Wells NHS Trust | | Medway NHS Foundation Trust | | Sussex Community NHS Foundation Trust | | **South Wales Epilepsy Forum (SWEP)** | | Abertawe Bro Morgannwg University LHB | | Aneurin Bevan LHB | | \*Cardiff & Vale University LHB | | Cwm Taf LHB | | Hywel Dda LHB | | **South West Interest Group Paediatric Epilepsy (SWIPE)** | | Gloucestershire Hospitals NHS Foundation Trust | | Northern Devon Healthcare NHS Trust | | Plymouth Hospitals NHS Trust | | Royal Cornwall Hospitals NHS Trust | | Royal Devon and Exeter NHS Foundation Trust | | Royal United Hospitals Bath NHS Foundation Trust | | Taunton and Somerset NHS Foundation Trust | | Torbay and South Devon NHS Foundation Trust | | University Hospitals Bristol NHS Foundation Trust | | Weston Area Health NHS Trust | | Yeovil District Hospital NHS Foundation Trust | | **South West Thames Paediatric Epilepsy Group (SWTPEG)** | | Ashford and St Peter's Hospitals NHS Foundation Trust | | Croydon Health Services NHS Trust | | Epsom and St Helier University Hospitals NHS Trust | | Frimley Health NHS Foundation Trust | | Kingston Hospital NHS Foundation Trust | | Royal Surrey County Hospital NHS Foundation Trust | | St George's University Hospitals NHS Foundation Trust | | Surrey and Sussex Healthcare NHS Trust | | **Trent Epilepsy Network (TEN)** | | Barnsley Hospital NHS Foundation Trust | | Chesterfield Royal Hospital NHS Foundation Trust | | Doncaster and Bassetlaw Teaching Hospitals Foundation Trust | | Northern Lincolnshire and Goole NHS Foundation Trust | | Sheffield Children’s NHS Foundation Trust | | The Rotherham NHS Foundation Trust | | **Wessex Paediatric Neurosciences Network (WPNN)** | | Dorset County Hospital NHS Foundation Trust | | Hampshire Hospitals NHS Foundation Trust | | Isle of Wight NHS Trust | | Poole Hospital NHS Foundation Trust | | Portsmouth Hospitals NHS Trust | | Salisbury NHS Foundation Trust | | Solent NHS Trust | | University Hospital Southampton NHS Foundation Trust | | Western Sussex Hospitals NHS Foundation Trust | | **Yorkshire Paediatric Neurology Network (YPEN)** | | Airedale NHS Foundation Trust | | Bradford Teaching Hospitals NHS Foundation Trust | | Calderdale and Huddersfield NHS Foundation Trust | | Harrogate and District NHS Foundation Trust | | Hull and East Yorkshire Hospitals NHS Trust | | Leeds Community Healthcare NHS Trust | | Leeds Teaching Hospitals NHS Trust | | Mid Yorkshire Hospitals NHS Trust | | York Teaching Hospital NHS Foundation Trust |
The following Trusts merged prior to the November 2019 organisational audit.
| Trust mergers | | **East Suffolk and North Essex NHS Foundation Trust** (formerly Colchester Hospital University NHS Foundation Trust & Ipswich Hospital NHS Trust, merged July 2018) | | **Northern care Alliance** (Merged with Salford Royal NHS Foundation Trust, April 2017) | | **University Hospitals of Derby and Burton NHS Foundation Trust** (formerly Burton Hospitals NHS Foundation Trust & Derby Hospitals NHS Foundation Trust, merged July 2018) | | **South Tyneside and Sunderland NHS Foundation Trust** (formerly South Tyneside NHS Foundation Trust & City Hospitals Sunderland NHS Foundation Trust, merged April 2019) | Appendix E: Data completeness
The Epilepsy12 project team originally identified 163 Health Boards and Trusts (acute, community and tertiary) with paediatric services across England and Wales in August 2017 as potentially eligible to participate in Round 3 of Epilepsy12. This was based on information from the 2017 British Association for Community Child Health (BACCH) and Royal College of Paediatrics and Child Health (RCPCH) publication "Covering all bases - Community Child Health: A paediatric workforce guide".
Of the 163, one Health Board in Wales did not register and five acute Trusts in England were no longer eligible due to mergers. Nine of the remaining 157 were community Trusts which were excluded because they either had no paediatric services, or they defined their paediatric service as not assessing or managing children with seizures or epilepsies.
This left 148 registered Health Boards or Trusts, all of whom provided a submitted a full 2018 organisational audit submission for Round 3 of Epilepsy12 (including 100% of acute Trusts in England).
The 2019 Organisational audit saw the inclusion of Birmingham Community Healthcare NHS Foundation Trust which made 149 registered Health Boards or Trusts. There were eight separate Trusts mergers which meant a total of 141 of Health Boards or Trusts.
The following Health Boards and Trusts were not included within the 2019 organisational audit results:
| Health Board or Trust | Regional Network | |-----------------------------------------------------------|------------------| | 1 Brighton and Sussex University Hospitals NHS Trust\* | SETPEG | | 2 Cardiff & Vale University LHB\* | SWEP | | 3 Coventry and Warwickshire Partnership NHS Trust\* | BRPNF | | 4 Gloucestershire Hospitals NHS Foundation Trust | SWIPE | | 5 Leicestershire Partnership NHS Trust | CEWT | | 6 Maidstone and Tunbridge Wells NHS Trust\* | SETPEG | | 7 North East London NHS Foundation Trust\* | NTPEN | | 8 Plymouth Hospitals NHS Trust\* | SWIPE | | 9 Surrey and Sussex Healthcare NHS Trust\* | SWTPEG |
\*Trusts that were not included within the 2019 Organisational results due to data that was either not submitted in time, or not ‘locked’ (a form of verification). Appendix F: Useful resources
The Royal College of Paediatrics and Child Health
The Royal College of Paediatrics and Child Health (RCPCH) was founded in 1996. We play a major role in postgraduate medical education, professional standards, research and policy. The RCPCH has a number of useful resources, including:
- **British Paediatric Surveillance Unit** [www.rcpch.ac.uk/work-we-do/bpsu](http://www.rcpch.ac.uk/work-we-do/bpsu) The BPSU is a world leading centre for rare paediatric disease surveillance. It enables doctors and researchers to investigate how many children in the UK and Republic of Ireland are affected by particular rare diseases, conditions or treatments each year.
- **Courses and online learning** [www.rcpch.ac.uk/education/courses](http://www.rcpch.ac.uk/education/courses)
- **Continuing professional development** [www.rcpch.ac.uk/education/continuing-professional-development](http://www.rcpch.ac.uk/education/continuing-professional-development)
- **Invited reviews** [www.rcpch.ac.uk/invitedreviews](http://www.rcpch.ac.uk/invitedreviews) We support healthcare organisations, commissioners and clinical teams to resolve concerns about paediatric service provision, safety, training, compliance with standards, and proposals for paediatric reconfiguration or service design. Our service is confidential, established and influential, and tailored to each organisation’s needs.
- **Medicines for Children** [www.medicinesforchildren.org.uk](http://www.medicinesforchildren.org.uk) The Medicines for Children website provides parents and carers with information they can trust on over 200 medicines commonly prescribed to children. It offers free access to patient information leaflets and videos specifically developed to advice parents and carers how to give medicine to their child.
- **MedsIQ** [www.qicentral.org.uk/meds-ig](http://www.qicentral.org.uk/meds-ig) Medication errors are a significant but preventable cause of harm to children and young people.
- **Research activities** [www.rcpch.ac.uk/work-we-do/research-activities](http://www.rcpch.ac.uk/work-we-do/research-activities) We aim to improve children’s health outcomes through supporting high quality and trusted research. Let’s share our expertise, collaborate with others and promote the evidence to drive forward improvements in child health.
- **RCPCH QI Central**: [www.qicentral.org.uk](http://www.qicentral.org.uk) QI Central is a free online resource open to all child health professionals to help embed QI projects in clinical practice and continually improve services and outcomes for infants, children and young people. As an online repository of peer-reviewed tools and projects, healthcare professionals are also able to submit their own projects and resources to share their experiences with others and propagate knowledge in quality improvement.
- **Workforce and service design** [www.rcpch.ac.uk/workforce](http://www.rcpch.ac.uk/workforce) We play a key role in workforce planning to ensure there is an appropriately trained paediatric medical workforce to deliver safe and sustainable services for children in the UK - in the present and in the future. Epilepsy12 Audit Key Stakeholder Organisations
British Paediatric Neurology Association [bpna.org.uk](http://bpna.org.uk) The British Paediatric Neurology Association is the professional organisation for doctors who specialise in the care of children with neurological disorders.
Epilepsy Action [www.epilepsy.org.uk](http://www.epilepsy.org.uk) Epilepsy Action is a community of people committed to a better life for everyone affected by epilepsy. We want high quality, accessible epilepsy healthcare services, so that people with epilepsy have the support they need to manage their condition. We want wider awareness and understanding of epilepsy, so that people living with the condition are treated with fairness and respect.
Epilepsy Scotland [www.epilepsyscotland.org.uk](http://www.epilepsyscotland.org.uk) In Scotland 54,000 people live with epilepsy. Children and older people are most at risk of developing this common serious neurological condition but anyone can develop epilepsy at any time, and 8 people a day in Scotland do. We want to make sure the needs of people with epilepsy are met. This is why we campaign for improved healthcare, better information provision and an end to stigma.
Royal College of Nursing [www.rcn.org.uk](http://www.rcn.org.uk) The RCN is a membership organisation of more than 435,000 registered nurses, midwives, health care assistants and nursing students. We are both a professional body, carrying out work on nursing standards, education and practice, and a trade union.
Epilepsy Specialist Nurses Association (ESNA) [www.esna-online.org.uk](http://www.esna-online.org.uk) ESNA is a professional organisation whose membership consists of nurses and other health professionals working to support people with epilepsy in the fields of adults, learning disabilities and paediatrics. ESNA works with its membership to raise the profile of epilepsy and to encourage a holistic and co-ordinated approach to care to enable our patients to reach the goal of self-management.
Young Epilepsy [www.youngepilepsy.org.uk](http://www.youngepilepsy.org.uk) Young Epilepsy is the national charity supporting children and young people aged 25 and under with epilepsy and associated conditions, as well as their families. With over 100 years expertise we provide world class diagnosis, assessment and rehabilitation for children and young people with epilepsy. We also undertake research into the condition and how it can be treated.
British Academy of Childhood Disability [www.bacdis.org.uk](http://www.bacdis.org.uk) Membership is open to all professionals working in the field of childhood disability, including paediatrics, psychiatry, specialist nursing, speech and language therapy, physiotherapy, occupational therapy, psychology and education.
British Society for Clinical Neurophysiology [www.bscn.org.uk](http://www.bscn.org.uk) The BSCN is a medical charity whose aims, set out in our articles of association, are “to promote and encourage for the public benefit the science and practice of clinical neurophysiology and related sciences”.
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a412d60470a8e2dd4da46ea63b85eeafc243daf9 | Making decisions on the duty to carry out Safeguarding Adults enquiries
A suggested framework to support practice, reporting and recording
Appendices The purpose of the framework developed on behalf of the Association of Directors of Adult Social Services (ADASS) and the Local Government Association (LGA) is to offer support in making decisions about whether or not a reported safeguarding adults concern requires a statutory enquiry under the Section 42 (S42) duty of the Care Act, 2014. It aims to support practice, recording and reporting in order to positively impact on outcomes for people and accountability for those outcomes. These five appendices support the report.
Contents
Appendix 1 Putting the six safeguarding adults principles into practice 2 Appendix 2 Legal literacy 8 Appendix 3 Why are there significant differences in the proportion of concerns dealt with within the S42 duty to make enquiries? Reflections from the workshops (LGA, November 2018) 10 Appendix 4 What does the national data tell us? 17 Appendix 5 Case studies which include factors that divide opinion on whether or not the criteria set out in S42(1) Care Act (2014) are met. 19
The report that these five appendices support can be found with other Making Safeguarding Personal resources at www.local.gov.uk/making-decisions-duty-carry-out-safeguarding-adults-enquiries-resources
## Appendix 1
### Putting the six safeguarding adults principles into practice
What did participants in the LGA/ADASS workshops (November 2018) emphasise as important?
| Safeguarding adults principle | What has this principle got to do with decision-making within the S42 duty? | What will help to support this? | |-------------------------------|--------------------------------------------------------------------------|---------------------------------| | **Empowerment** | People should be involved at all stages of a safeguarding concern. | Making the right information available in the right way to inform and involve the person from the beginning. Making sure that, when asked the approach they want to take, the person has the right information on which to base their decision. | | | In answer to a question ‘How important is it that they talk to you about how they help? Right from the start?’ a person using services said: | Using language that is understandable and avoiding jargon. | | | “It is important they involve me as to how they can help. If it is worrying me, then best to let me know from the start. I would want to be ‘quietly involved.’”¹ | Supporting the person so that they have a competent and confident voice. | | | When someone declines support, empowerment is not about walking away but rather supporting an informed decision in the context of presenting risks and weighing the person’s wishes against the duty of care. | Having the right person to support the individual - whoever the person feels is right for them. | | | | Accessibility of advocacy support (including within MASH and triage arrangements) | | | | In cases where the person declines support, staff need to be supported and competent/confident to know where the level of risk and legal responsibilities indicate that doing nothing is not an option. |
¹ A comment from conversations with several people at five different services across Cheshire East; adults with learning disabilities and physical disabilities. | Safeguarding adults principle | What has this principle got to do with decision-making within the S42 duty? | What will help to support this? | |-------------------------------|--------------------------------------------------------------------------|---------------------------------| | Prevention | ‘It is about working together to reduce the chances of something happening; that’s what it’s all about!’<sup>2</sup>\
People can be supported to keep themselves safe without an enquiry under S42. This is a sign of success not failure.\
Information and data needs to capture this activity and its outcomes locally to demonstrate effective early intervention and prevention alongside the safeguarding adults collection (SAC) data. | Establish local mechanisms for recording safeguarding concerns, activity and outcomes where the S42 duty is not met, and safeguarding actions are taken under powers rather than duties. This facilitates understanding where local risks and issues are and where to target early intervention and prevention.\
Establish a shared understanding across organisations about provider quality concerns and safeguarding concerns. There needs to be clarity locally about routes for dealing with and recording the range of these concerns.\
Working proactively with all providers to pre-empt situations where a decline in care quality could result in abuse or neglect. Offering support to providers to identify and deal with the underlying problems.\
Build in a system of learning across the multi-disciplinary team to support this area of practice.\
Work with local community groups to raise awareness about people’s rights to protection against abuse and neglect and identify pathways for concerns to be raised. |
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<sup>2</sup> Observation from participant attending one of the S42 workshops (November 2018) | Safeguarding adults principle | What has this principle got to do with decision-making within the S42 duty? | What will help to support this? | |-------------------------------|--------------------------------------------------------------------------|--------------------------------| | Partnership | “We need multi-agency agreement and collaboration from concern to outcome.” Be clear about information sharing. Not undertaking an enquiry under S42 does not preclude sharing information. Initiating an enquiry under S42 is sometimes seen as a ‘passport’ to a multi-agency discussion. This should not be necessary and can usefully take place at the preliminary stage of assessing a concern and considering the most effective response. The Care Quality Commission (CQC) has developed clear guidance about circumstances in which notifications must come from providers to CQC. This is clear regarding medication errors and says that these should only be notified where there is a degree of harm to the individual(s). This work will support system wide learning and greater clarity about the nature of safeguarding concerns and enquiries under S42 and quality issues. | Strong partnership between commissioning and contracting teams, supporting shared understanding and more consistent responses for effective outcomes. Strengthening this partnership through protocols with providers. When the local authority ‘causes’ a provider to make enquiries, it is made clear what is being asked of them. Local information and data needs to be capable of showing the impact of this work on safeguarding. Developing a shared understanding and conversations about the appropriate route for dealing with situations. Partners know what to refer into the local authority and, when they do so, they are clear as to which route will be taken to address the concerns. Share tools to support decision-making across sectors. For example, the CQC plans to develop scenario-based advice for providers on notifications. This will be helpful across local authority areas in shared conversations about what is a concern or an enquiry under S42. | | Safeguarding adults principle | What has this principle got to do with decision-making within the S42 duty? | What will help to support this? | |-------------------------------|--------------------------------------------------------------------------|---------------------------------| | Protection | “Making Safeguarding Personal is not an excuse to walk away.”³ | Have a clear local understanding about what will lead to an enquiry under S42 and how to record that decision. | | | If a person declines safeguarding support and/or a S42 enquiry that is not the end of the matter. Empowerment must be balanced with Duty of Care and the principles of the Mental Capacity Act must come into play. Best practice in working with risk must be considered (see under Empowerment, above) Protection and safety must be balanced with wellbeing.⁴ | Be equally clear in recording actions outside an enquiry under the S42 duty, which may include: | | | Whatever the decision about undertaking an enquiry under the S42 duty, the objective is to understand if there is any risk to the person and, if so, to support the person to reduce it if possible. Staff need to be clear on what they are doing if they don’t undertake a S42 enquiry. They need to record this or it won’t be clear that individuals, about whom an enquiry under S42 is not carried out, have nevertheless been ‘protected’ (ie the risk has been reduced). | • pass to quality assurance team – for specific targeted interventions or as part of a wider care service surveillance | | | | • Care Act (2014) Assessment (S9) | | | | • referral to other agency (GP, Police, Other LA, Acute Health, MH, Domestic Abuse Services etc) | | | | • formal complaint | | | | • advice and information⁵ | | | | • any other actions. |
³ Observation from participant attending one of the S42 workshops (November 2018) ⁴ [www.local.gov.uk/our-support/our-improvement-offer/care-and-health-improvement/making-safeguarding-personal/working-risk](http://www.local.gov.uk/our-support/our-improvement-offer/care-and-health-improvement/making-safeguarding-personal/working-risk) ⁵ London Borough of Bexley presentation S42 workshop, LGA/ADASS, November 28, 2018 | Safeguarding adults principle | What has this principle got to do decision-making within the S42 duty? | What will help to support this? | |-------------------------------|---------------------------------------------------------------------|---------------------------------| | Proportionality | “We will always acknowledge when safeguarding duties apply but the recommendation and decision to close will also evidence the principle of proportionality, the least intrusive response appropriate to the risk presented.”⁶ | Having clarity in policies and procedures (locally or regionally) about the range of support options outside safeguarding services and activities that could be used to reduce risk or harm. Having a decision-making tool that assists people who are referring a concern to see the different levels of risk of harm and the route for support which would be most likely and appropriate. Monitoring and reporting on the outcomes for people who receive support outside of an enquiry under the S42 duty, to ensure that these are positive and effective. This is also important in the context of accountability (see next section). |
⁶ Devon County Council presentation S42 workshop, LGA/ADASS, November 28, 2018 | Safeguarding adults principle | What has this principle got to do with decision-making within the S42 duty? | What will help to support this? | |-------------------------------|--------------------------------------------------------------------------|--------------------------------| | Accountability | “…data collection is important to me as someone could be seriously hurt without looking at the wider picture to stop abuse.”⁷ | Transparency and openness about the process, approach and understanding and recording why the approach that was taken supports accountability. | | | Within this principle the practice and the recording of making decisions on S42 enquiries come together. | Having a comprehensive assurance framework that enables the safeguarding adults board (SAB) to triangulate information and This would include: | | | Accountability means: | • case file audits | | | • being able to explain how an issue has been addressed | • monitoring outcomes for people | | | • accounting for actions taken | • feedback from people who have had safeguarding support | | | • accepting responsibility for actions and outcomes | • internal audit | | | • understanding mutual roles across organisations | • benchmarking and peer review against other authorities in the region. | | | • reporting regularly and openly on the above acting to address problems.| Discussions across the region to understand the differences and the issues (as in Yorkshire and the Humber). |
⁷ A comment from conversations with several people at five different services across Cheshire East; adults with learning disabilities and physical disabilities. Appendix 2
Legal literacy
Core message one For any decision-making to be effective it must be legally literate. Decisions must conform to legislation that supports and protects the rights and safety of citizens. Legal obligations are non-negotiable in making these decisions.
Each matter must be decided on the facts of that specific case, taking into account the duties in legislation, regulations and guidance. As these are public law decisions practitioners must also be confident that they can demonstrate, in court if necessary, that they have:
- Upheld principles that decision-making is **lawful, reasonable and fair**.
- Protected against breaches of the adult’s human rights and advanced the principles of the Equality Act 2010.
- Ensured that all decisions respect autonomy and that where there is reasonable cause to suspect a person lacks capacity that all decisions are made with regards to the duties set out in the Mental Capacity Act 2005. Practitioners also need to be mindful of external pressures than can impair free will.
- Met obligations under the Data Protection Act 2018 and regulations.
The diagram below illustrates a process for sound decision-making. It is important to remember that all safeguarding decisions are public law matters that can be challenged – by the adult concerned, their representative or by the person accused of causing harm – through a complaint or judicial process.
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8 This diagram is from Fiona Bateman's presentation to the LGA/ADASS workshops in November 2018. For an enquiry to be conducted under S42 there must be ‘reasonable cause to suspect’ that an adult covered by the scope of the legislation is suffering, or at risk of suffering, abuse or neglect. In many cases this may be achieved through initial, information gathering to establish the facts, in other cases more detailed exploration may be necessary. This should involve the adult concerned and requires the use of professional judgment to weigh up all available evidence (proactively looking for corroborating information) obtained from a proportionate review of case records and other relevant enquiries. Appendix 3
Why are there significant differences in the proportion of concerns dealt with within the S42 duty to make enquiries? Reflections from the workshops (LGA, November 2018).
It was never the intention of the Care Act (2014) to impose a rigid and prescribed set of processes on local authorities for the protection of adults against abuse and neglect. Indeed, one of the major criticisms of practice under the preceding ‘No Secrets’ guidance was that it was too process driven and did not have the flexibility to respond fully to the wishes of the adult concerned.
“We’re doing safeguarding work and activity in different ways. That might be alright. We should accommodate differences in the ways we support people to manage risk.”
It was clear from the workshops that staff take different approaches in terms of how they respond to the duty to conduct safeguarding enquiries in individual circumstances. However, the degree of inconsistency and uncertainty supports an argument for suggesting a way of achieving greater consistency and confidence going forward. The term used to describe how the advice in this report might be used was as ‘scaffolding’ to support practice. The suggested way of interpreting the relevant aspects of the Care and Support Statutory Guidance (DHSC, 2018), including being explicit in putting into practice the six safeguarding adults principles, is one part of that scaffolding.
Arrangements for first contact with the local authority
There is a range of organisational structures and processes across the country for receiving and acting on safeguarding concerns.
Almost half of local authorities have a triage process for evaluating concerns initially and NHS Digital have calculated that about 50 per cent of concerns go no further than this stage. In many councils, concerns will go to a generic team (usually one which deals with all enquiries about social care and support) who will determine whether it is a safeguarding matter and therefore whether it should be referred on. For instance, in many areas, concerns that relate to care quality will be referred to the team dealing with care contracts and commissioning rather than being treated as a safeguarding concern.
The skill sets within these teams vary. Some include qualified social workers but others do not. Some of these teams will gather information, usually by obtaining other information from their records and by telephoning or emailing the relevant people who can help establish the facts. The information gathering may go no further than this or it may be referred on to another team for further work. How this information is recorded also varies. Some will be reported as enquiries under S42(2), others as concerns and some may not be reported at all within safeguarding.
In some areas the concern will be received by a multi-agency safeguarding hub (MASH) and recording practices also vary within these. This may result in a higher number of concerns.
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9 Observation from a participant attending one of the decision-making workshops in November 2018. 10 Safeguarding Adults Collection, Survey of Local Definitions 2018, NHS Digital, November 2018 being recorded in some areas which, in turn, affects the proportion of concerns that become enquiries under S42(2).
In other areas concerns go directly to a specialist safeguarding team in the local authority without being triaged by a ‘first contact’ team.
The variety of organisational and staffing arrangements for first receipt of a safeguarding concern is highlighted as a contributing factor to the variations in recording and reporting decision-making practice.
**Views of the person concerned and the extent to which (and how/at what point) these influence decision-making**
The principle of shared decision-making, involving people in clinical or professional decisions that affect their lives, should underpin good health and social care practice. This is the bedrock of Making Safeguarding Personal. Conversations with service users in Cheshire East generated comments including:
“It is important that I know what is happening to me, no decision about me, without me.”
“It is certainly important to have control, be respected and listened to. I would want a worker to be pleasant and respectful and chat to me – not go off on their own agenda.”
This is reflected in the Care and Support Statutory Guidance (DHSC, 2018)(^\\text{11}) which states that ‘policies and procedures should assist those working with adults how to develop swift and personalised safeguarding responses and how to involve adults in this decision making’. The guidance assumes that adults have capacity to take part in decision-making but that where the adult has a ‘substantial difficulty’ in being involved that a suitable person or advocate must be found to support them.(^\\text{12})
The Care and Support Statutory Guidance (DHSC, 2018) states “The scope of that enquiry, who leads it and its nature, and how long it takes, will depend on the particular circumstances. It will usually start with asking the adult their view and wishes which will often determine what next steps to take. Everyone involved in an enquiry must focus on improving the adult’s wellbeing and work together to that shared aim.”(^\\text{13}) Participants at the workshops supported the principle of getting the views of the adult from the outset and that, ideally, this should be done by the person referring the concern, ie checking with the adult that they agreed to or were aware of the referral. Some authorities are unwilling to accept a referral from a third party unless this has been done.
Participants at the two workshops were asked how much influence they thought the views of the adult concerned have on a decision to undertake an enquiry under S42(2). Responses to this included:
“It [the concern] may be closed at the request of the service user, but it would still be a S42 enquiry in the first instance.”
“The Mental Capacity Act guidance and principles and risk assessment are key to decisions as to how far to accept the wishes of the person at face value.”
There seemed to be a general consensus that, although obtaining the views of the adult was of prime importance in determining what outcomes should come from a safeguarding
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(^{11}) Paragraph 14.52, Care and Support Statutory Guidance, DHSC, October 2018
(^{12}) Paragraph 14.54, Care and Support Statutory Guidance
(^{13}) Paragraph 14.93, Care and Support Statutory Guidance enquiry, this should not be the overriding factor in determining the process of that enquiry, ie it would be for the authority to determine, taking all the circumstances into account, the most appropriate way to conduct an enquiry under S42(2), which could include a process outside of safeguarding such as a care review. Some of the factors that influenced this view were about ensuring that any response is proportionate to the circumstances and a lack of clarity about what the added value was of conducting an enquiry under S42(2) compared with other options to assist the adult.
Participants were also asked their views about whether an enquiry under S42(2) should be carried out if the adult concerned did not want this. There was more confidence in addressing this issue, reflecting the principles underpinning Making Safeguarding Personal (MSP) about placing people at the centre of decision-making. It is important to understand that MSP does not mean walking away from someone who is suffering abuse or neglect but who is reluctant to support a safeguarding intervention. A stronger relationship may have to be established in order to create trust and to give time for the adult to think about their options. Participants said that other factors would have to be weighed against an adult’s opposition to an enquiry being made. These included coercion by another person, the level of risk to the adult or to others, public interest and whether a crime had been committed.
The views of the adult are central to determining the desired outcomes in a case but should not be the overriding factor in determining the process.
How should the six safeguarding adults principles\\textsuperscript{14} be employed in the context of the S42 duty to make enquiries?
It was clear from the LGA/ADASS workshops that the six safeguarding adults principles set out in the Care and Support Statutory Guidance (DHSC, 2018) are well known to practitioners but that some are more explicitly influential on decision-making than others.
Many participants referred to proportionality in determining the best way to respond to a concern. One workshop participant said they “would record proportionality but probably not the others”.
There were also indications from the workshops that MSP and the empowerment principle are embedded in practice, although this may simply be referred to by practitioners as a person-centred approach.
The other four principles – prevention, protection, partnership and accountability – were not prominent in discussions at the workshops. Participants said that they bring the six safeguarding adults principles into play in decision-making but many struggled to say how or evidence in what way and for what purpose they do so.
The Care and Support Statutory Guidance (DHSC, 2018) states that all of these principles must underpin decision-making.\\textsuperscript{15} These are set out in the framework and in Appendix 1 (above). Being explicit about applying principles supports transparency and clarity about the rationale for decision-making and evidences individualised responses.
\\textsuperscript{14} Paragraph 14.13, Care and Support Statutory Guidance
\\textsuperscript{15} Paragraph 14.92, Care and Support Statutory Guidance Interpretations of what constitutes a safeguarding enquiry
Section 42 of the Care Act (2014) sets out the criteria which would result in a duty for the local authority to make ‘whatever enquiries it thinks necessary’. The Care and Support Statutory Guidance (DHSC, 2018) clarifies what the enquiry is intended to achieve:
‘The purpose of the enquiry is to decide whether or not the local authority or another organisation, or person, should do something to help and protect the adult.’
Section 42 does not define what an enquiry is. The Care and Support Statutory Guidance (DHS, 2018) says:
‘An enquiry could range from a conversation with the adult, or if they lack capacity, or have substantial difficulty in understanding the enquiry their representative or advocate, prior to initiating a formal enquiry under section 42, right through to a much more formal multi-agency plan or course of action.’
The guidance therefore describes a broad range of activity that would constitute an enquiry and/or information gathering that precedes a decision to initiate an enquiry under S42(2).
In the context of perceived ambiguities and a lack of clear and explicit guidance, local authorities have to some extent developed local definitions of what constitutes an enquiry under the S42 duty, leading to very different recording and reporting practices across the country.
For example, it is clear that there is inconsistency in how local authorities opt to record information gathering that is carried out to determine whether the statutory criteria for S42(1) are met. (Not all these approaches are supported within the suggested framework in the report.) The workshops (LGA, November 2018) included indications that:
- For some it is a matter of scale. If the enquiries to gather information are extensive then they are reported as an enquiry under S42(2) but if they are minimal and short then they remain as concerns.
- In many cases information gathering will establish that the incident was minor, or that the issue has been dealt with and resolved and no further action is needed. Some local authorities would report this work as an enquiry under S42(2) whereas others would not.
- A degree of support offered at the stage of information gathering can resolve the issue. In that case it may not be reported as an enquiry under S42(2) even though a safeguarding concern has been resolved.
- Some participants at the workshops said that their local authorities would not identify the S42 duty to make enquiries until there has been a conversation with the person concerned.
- Some authorities opt to report all work that looks into safeguarding concerns, as part of an enquiries under the S42(2) duty.
- In Yorkshire and the Humber a detailed analysis of case studies by all local authorities in the region found that enquiries reported as being within the S42(2) duty, ranged from minimal responses to telephone enquiries, resolution at early enquiry stage and right through to a multi-agency enquiry.
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16 Paragraph 14.78, Care and Support Statutory Guidance 17 Paragraph 14.77, Care and Support Statutory Guidance Approach to establishing the statutory criteria for a safeguarding enquiry
The evidence, from the survey carried out by NHS Digital and observations at the workshops in November 2018, is that all local authorities are using the criteria set out in Section 42(1) (Care Act, 2014) to determine whether a safeguarding enquiry must be undertaken. In theory, this would mean that all concerns where there is reasonable cause to suspect that these meet the statutory criteria for S42(1) would be reported as enquiries under the S42(2) duty. However, there are perceived ambiguities in the Care and Support Statutory Guidance (DHSC, 2018) as set out above. This leads to different approaches to applying the guidance. Professional judgements vary as to what is best dealt with through an enquiry under the S42(2) duty and what could be best dealt with through a process outside of safeguarding, for example, a new care assessment and care plan.
Local authorities report a relatively small number of enquiries into cases that do not meet the S42(1) criteria. These enquiries are usually reported as ‘Other’ safeguarding in the SAC returns. The most common reasons for this are that the person concerned is dead; or does not appear to have a care and support need; or where there is a pattern of concerns; or there is a matter of public interest. It was also clear from workshop discussions (LGA, November 2018) that some local authorities report some situations of self-neglect and domestic abuse as an ‘other’ enquiry.
In Yorkshire and the Humber the Regional ADASS group have conducted a stocktake on progress in MSP and identified very significant variances, across the fifteen local authorities in the region, in decision-making about enquiries under S42(2). Workshops were held to try and identify what lay behind these differences in practice and it was decided to carry out a ‘deep dive’ exercise. Sixteen scenarios, based on real cases, were considered by representatives from all the local authorities.18
This exercise demonstrated that even in a region where a lot of work had been done to agree principles for data collection, and where common procedures were shared across several local authority areas, there was still a wide divergence of opinion on whether the statutory criteria under S42(1) had been met or not.
The case studies in Appendix 5 show how the framework in the report can be used in practice. Specific judgements may still vary but the framework has been piloted on a number of cases in a region and this indicated a shift towards more consistent decision-making.
The application of a range of ‘thresholds’ in decision-making
An assessment of the level of risk of harm is a critical factor in determining whether there is reasonable cause to suspect that the statutory criteria for S42(1) are met and any subsequent activity.
“The first priority should always be to ensure the safety and wellbeing of the adult.”19
Most local authorities set out examples of harm and risk to show different levels of severity and to indicate what action might be appropriate. This is usually in the form of a matrix that is referred to as a ‘threshold’ document or as a ‘decision-making tool’.
Over 80 per cent of local authorities responding to the SAC Survey by NHS Digital in 201820 stated that they have thresholds in place for adult safeguarding decisions. Decision-making
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18 Workshop slides presented by Y&H Programme Director at LGA/ADASS workshops, November 2018
19 Paragraph 14.95, Care and Support Statutory Guidance
20 Safeguarding Adults Collection, Survey of Local Definitions 2018, NHS Digital, November 2018 tools have also been adopted regionally in some areas to increase consistency of response across local authority areas.
Concerns have been expressed that the use of thresholds can lead to a mechanistic or tick-box approach assessment that is inconsistent with a MSP approach. For the person involved the ‘test’ of meeting a ‘threshold’ of risk might appear inappropriate and be a barrier to achieving safety and wellbeing. With that in mind, it is preferable to have a decision-making tool rather than a threshold document – that is, something that assists in decision-making and not a document that determines a decision.
It has not been possible within the scope of this framework to analyse in detail the types of thresholds guidance being used across the country and the extent to which they inform decisions about the S42 duty or decisions about when to refer concerns into the local authority.
Threshold documents are probably best used in offering examples to guide those who are not specialists in safeguarding to help them understand whether they need to raise a concern with the local authority and what kind of action may follow, rather than to set down clear lines about who can or cannot access safeguarding support.
Given the variance in practice across the country, these tools do not seem to have achieved consistency in decision-making, at least in whether or not an enquiry under the S42(2) duty is indicated, even where common policies are shared.
Further consideration will be given to this area of guidance and practice in considering (in workshops and a briefing during 2019) where concerns require referring into a local authority because they need a safeguarding response. This will reference work underway in the CQC which aims to support greater clarity on identification of safeguarding issues that need to be referred to the regulator as safeguarding concerns by providers. Appendix 4
What does the national data tell us?
The data identify a wide range in the numbers of concerns submitted by local authorities, and the number of these that progress to an enquiry under the S42(2) duty (known as the ‘conversion rate’ of concerns to enquiries).
Concerns raised during 2017/18 and the reported route taken to offering a response and support
There were 394,655 safeguarding concerns raised during 2017/18, an increase of 8.2 per cent on 2016/17. A total of 150,070 adult safeguarding enquiries were reported as starting during the year. Of these, 131,860 were enquiries under S42 (87.9 per cent of the total), and there were 18,210 ‘other’ safeguarding enquiries.
The ratio of total enquiries (S42(2) plus ‘other’) to concerns gives a ‘conversion rate’. This combined figure gives an overall conversion rate during 2017/18 for England of 38 per cent; that is, for every 100 concerns that were raised there were 38 Section 42 and ‘other’ enquiries that were started.
The range of conversion rates varied across all the different local authorities from 3.9 per cent to 100 per cent. Eight local authorities had a 100 per cent conversion rate, ie all their concerns were recorded as becoming enquiries. Regionally, the conversion rate varied from 31.0 per cent in the West Midlands to 45.9 per cent in the north east.
Some commentators(^{21}) have sought to establish what a ‘good’ conversion rate should be by using this data, but this is not a reliable indicator of the quality of decision-making or the effectiveness of the response. Data should not simply be used to draw general conclusions but is better used to understand the differences in practice at local level that result in these variances, ie as a ‘can opener’ to ask pertinent questions about practice rather than as the basis on which to draw general conclusions.
(See the presentation on the approach the East of England region took to analysing a relatively low conversion rate of concerns to S42 enquiries.)(^{22})
There was a prevalent view at the workshops (LGA, November 2018) that by focusing on practice there is more likely to be an improvement in outcomes. As one participant in the workshops said, “responding appropriately and proportionately is more important”. A service user from Cheshire East commented: “the most important thing to me is getting the right help”.
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(^{21}) A Patchwork of Practice, Action on Elder Abuse, December 2017
(^{22}) Workshop slides presented by Claire Bruin at S42 workshops, LGA, 2018 Does it matter whether enquiries are classified and reported differently?
“It is important to record data so that abuse is stopped.”
The data is important. It has been a catalyst for this work. There is an important principle of accountability that must be satisfied. This exists at an individual level in relation to the support provided to an adult at risk of abuse and neglect, and it also exists in relation to the work of safeguarding adults boards, the statutory duties of local authorities and the overview by the Department of Health and Social Care.
The data reflects inconsistencies in recording and reporting practice in relation to the S42(2) duty to carry out safeguarding adults enquiries. This inconsistency follows from differences across local authorities in interpreting the Care and Support Statutory Guidance (DHSC, 2018). If consistent interpretation of the guidance is supported and developed, consistent reporting should follow. A way forward in supporting that consistency is suggested in this framework.
All those enquiries carried out under the S42(2) duty generate information through the SAC. This supports accountability. However, at the same time local authorities and SABs should collect supplementary, local data and information to support understanding of those situations which do not progress to an enquiry under S42(2) and to improve local monitoring of the quality of safeguarding activity.
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23 A comment from conversations with several people at five different services across Cheshire East; adults with learning disabilities and physical disabilities. Appendix 5
Case studies which include factors that divide opinion on whether or not the criteria set out in S42(1) Care Act (2014) are met.
Whilst a consistent framework is offered in terms of the factors that determine whether a S42(2) duty to make enquiries exists this cannot take away the need for professional judgements, based on individual circumstances, about which situations meet the criteria set out in S42(1) of the Care Act (2014) and which do not.
The framework set in the report supports the view that that there is a duty from the outset which starts with S42(1) information gathering to inform a decision as to whether that duty will continue into a statutory S42(2) enquiry. Only if it is established that there is reasonable cause to suspect that the three criteria in S42(1) are fulfilled is the duty under S42(2) to make enquiries triggered. Only then will it be reported as a S42(2) enquiry to NHS Digital in the SAC.
The following case studies include factors where opinion is often divided (particularly in respect of S42(1) (b); whether the person is experiencing, or is at risk of, abuse or neglect. Concerns about medication errors and about service user on service user ‘abuse’ are also amongst those that divide opinion.
What is important here is that the report is taken account of and that the judgement is made against the core principles and tools provided in the legislation and associated guidance. There must be transparency and accountability for the decision against that background. Not everyone will agree on each, specific decision, but there will be greater consistency if decisions are taken using the same tools.
These case studies illustrate the level of transparency required and how the decision fits with available guidance.
Case study 4 – Peter
Case outline The situation was referred as a safeguarding adults concern by a day centre to the local authority on the day on which the incident took place.
The adult at risk is Peter, a 26-year-old male with severe autism and learning disabilities who attends day care on three days per week. The person alleged to have caused harm (PACH) is another service user. The allegation is one of physical abuse. Both services users were travelling to the day centre and were sat together as usual. The PACH reached over to Peter and pinched him on the left arm.
The bus was immediately stopped, and staff separated both service users to different seats. Distraction techniques were used. Staff advised the PACH that their actions were not appropriate. Having reached the day centre, Peter and the PACH were kept apart by their 1:1 members of staff. Peter was initially distressed but soon calmed down. He was checked for injuries and he had a red bruise with the imprint of three fingers from contact. This was recorded on a body map. Peter’s mother has been informed of the incident, advised of actions taken to minimise risk, including them being kept apart by staff members. She is happy with the measures put in place. Peter’s mother is consenting to this being addressed through safeguarding adults procedures and is likely to contribute where needed.
Suggested decision-making in this case, reflecting the approach set out in the report
If the criteria set out in Section 42 (1) are applied and ‘reasonable cause to suspect’ is considered, Peter:
(a) has needs for care and support (whether or not the authority is meeting any of those needs) (b) is experiencing, or is at risk of, abuse or neglect (there are physical marks and measures are still in place to protect him) (c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it. (It is judged that members of staff on a 1:1 basis need to monitor and keep Peter and the PACH apart.)
Reasonable cause to suspect The presentation of this case supports a view that Peter is at risk because he has physical marks from the incident, and it is felt that measures need to be in place to protect him from further similar incidents.
Following the framework set out in the report, the S42(2) duty to make enquiries is triggered and Section 42(2) will follow:
S42(2) ‘The local authority must make (or cause to be made) whatever enquiries it thinks necessary to enable it to decide whether any action should be taken in the adult’s case (whether under this Part or otherwise) and, if so, what and by whom.’
Information gathering indicates that:
- initial actions have been necessary straight away to minimise risk, including keeping the two individuals apart
- there has been communication with Peter’s mother, engaging her in understanding that this is a safeguarding concern and seeking her consent and contribution to address it as such
- the incident has been recorded.
Further enquiries under the Section 42(2) duty will be needed in line with the purpose and objectives of an enquiry as set out in the statutory guidance (including in paragraphs 14.78, 14.93 and 14.94, DHSC, 2018).
Initial actions have been taken but further conversations and support are needed to secure sustainable protection planning. Whilst immediate safety is secured a number of the objectives in paragraph 14.94 are not fulfilled. This will be done within the Section 42(2) duty to make enquiries. Consideration of this situation against these aspects of the Care and Support Statutory Guidance (DHSC, 2018) will support a decision as to whether the local authority is sufficiently assured that a provider’s response has been robust enough to deal with a safeguarding issue, or whether a S42(2) enquiry is needed (see paragraph 14.69, Care and Support Statutory Guidance (DHSC, 2018)):
14.78 The purpose of the enquiry is to decide whether or not the local authority or another organisation, or person, should do something to help and protect the adult...
14.93 Local authorities must make enquiries, or cause another agency to do so, whenever abuse or neglect are suspected in relation to an adult and the local authority thinks it necessary to enable it to decide what (if any) action is needed to help and protect the adult. The scope of that enquiry, who leads it and its nature, and how long it takes, will depend on the particular circumstances. It will usually start with asking the adult their view and wishes which will often determine what next steps to take. Everyone involved in an enquiry must focus on improving the adult’s wellbeing and work together to that shared aim. At this stage, the local authority also has a duty to consider whether the adult requires an independent advocate to represent and support the adult in the enquiry.
14.94 The objectives of an enquiry into abuse or neglect are to:
- establish facts
- ascertain the adult’s views and wishes
- assess the needs of the adult for protection, support and redress and how they might be met
- protect from the abuse and neglect, in accordance with the wishes of the adult
- make decisions as to what follow-up action should be taken with regard to the person or organisation responsible for the abuse or neglect
- enable the adult to achieve resolution and recovery.
24 14.69 When an employer is aware of abuse or neglect in their organisation, then they are under a duty to correct this and protect the adult from harm as soon as possible and inform the local authority, CQC and CCG where the latter is the commissioner. Where a local authority has reasonable cause to suspect that an adult may be experiencing or at risk of abuse or neglect, then it is still under a duty to make (or cause to be made) whatever enquiries it thinks necessary to decide what if any action needs to be taken and by whom. The local authority may well be reassured by the employer’s response so that no further action is required. However, a local authority would have to satisfy itself that an employer’s response has been sufficient to deal with the safeguarding issue and, if not, to undertake any enquiry of its own and any appropriate follow up action (for example, referral to CQC, professional regulators). Case study 5 – Mr Wilson
Referred by care home (team leaders).
Case outline Mr Wilson's medication had been changed from Madopar to Co-Bendaloper. The last dose of Madopar should have been on the night of 14 August. The Co-Bendaloper should have commenced on the morning of 15 August. However, the Madopar had not been stopped on the Medicines Administration Record (MAR) or removed from the medicines trolley. The team leader administering medication that morning gave both Madopar and Co-Bendaloper and did so again at lunchtime.
On carrying out the medication audit after lunch, this error was noted. The GP was contacted, and the GP stated that Mr Wilson should be fine as both medicines are short acting and any complications would have arisen already. The advice was to monitor and continue with the Co-Bendaloper dose for the rest of the day and to contact the GP again if there were any concerns.
The local authority receiving the referral of this concern telephoned the care home deputy manager who advised that this error had been an oversight and due to the error, she is in the process of carrying out a random audit to check that no further errors have been noted. At this stage none has been found. The error that occurred was in regard to a change in Mr Wilson’s medication for Parkinson's Disease. The error led to him being given his old medication as well as his new medication.
The home had immediately contacted the GP who advised on the consequences (as above) and that it was alright to continue the medication as prescribed going forward. Mr Wilson was asked how he felt; he said he felt no different and that his capabilities with his mobility/balance had not been impacted. Mr Wilson agreed that a safeguarding concern could be raised but didn't want any fuss.
Applying the framework The below sets out one rationale by one local authority for making a judgment about whether this situation meets the statutory criteria set out in S42(1). It is not the only possible conclusion as to whether the criteria are met but it does show a clear rationale for deciding one way or the other.
Factors such as local procedures on medication errors and safeguarding will play a part in decisions. (In some instances, the framework in the report may lead to revisiting local procedures). National developments including those being developed by CQC may also impact upon a more consistent reading of these situations involving medication errors (and upon local procedures). An associated framework to support considering what constitutes a safeguarding concern will aim to further clarify the position on concerns such as medication errors during 2019/20). The following judgment about whether the criteria in S42(1) are met is based on the local context:
Local procedures in the local authority area state that where two or more consecutive medication errors occur involving the same adult then this is a safeguarding matter. In this context, the local authority decides that the criterion in S42(1) (b) that the adult is experiencing, or is at risk of, abuse or neglect, is met. As part of establishing reasonable cause to suspect that all three criteria are met, the local authority considers the information gathered from the care home, which indicates:
- more than one medication error involving an adult with care and support needs (due to Parkinson’s Disease)
- that the adult is in receipt of care and support and is reliant on staff to administer his medication so unable to protect himself.
The fact that it happened twice (in the morning and then again at lunchtime) is enough in this local authority area to meet s42(1) (b) and consequently the local authority should discuss with the home the need to make enquiries and find out how the correct medication will be dispensed and by whom. Therefore, their decision is that the S42(1) duty continues to a S42(2) enquiry.25
The local authority may make the enquiries or might ‘cause’ or ‘require’ others to undertake them. (‘The local authority, in its lead and coordinating role, should assure itself that the enquiry satisfies its duty under section 42(2) to decide what action (if any) is necessary to help and protect the adult and by whom and to ensure that such action is taken when necessary’. (Paragraph 14.100, Care and Support Statutory Guidance (DHSC, 2018))
Decisions need to be taken about what action is necessary and by whom to address the concerns under activity within the Section 42(2) duty enquiries. Paragraph 14.94 of the statutory guidance states that the objectives of an enquiry are to:
- establish facts
- ascertain the adult’s views and wishes
- assess the needs of the adult for protection, support and redress and how they might be met
- protect from the abuse and neglect, in accordance with the wishes of the adult
- make decisions as to what follow-up action should be taken with regard to the person or organisation responsible for the abuse or neglect
- enable the adult to achieve resolution and recovery
25 It is acknowledged that other local authorities may not have come to the same judgement in this case (ie that Mr Wilson had suffered abuse or neglect) but would have opted to mitigate the risk of future medication errors by actions outside of S42. In reality, many of these actions would have been very similar to those carried out under S42(2) in this case study. Activity needs to reflect the six key safeguarding adults principles and might include:
- checking with the GP, information received from the care home and asking about any previous concerns (same resident or other medication errors/ concerns) gain assurance regarding impact on the resident and clarify recommended timeframe within which the home will need to monitor the resident
- checking local authority records about any previous medication incidents or medication related concerns
- checking CQC inspection reports, share concerns with CQC and commissioners, inform them and the care home that the S42(2) duty has been triggered and enquiries are being made to decide what action is necessary
- considering action taken by the home to involve the adult and address the immediate risks to the adult/others
- checking the views, wishes and expressed outcomes of the adult
- ensuring the adult/their representative are fully involved
- consider advocacy under the statutory duty (Care Act (2014) Section 68) to support the adult during the enquiries
- considering the need for assessment/reassessment of the adult's needs (Care Act (2014) Section 9).
The enquiry will determine whether action needs to be taken and by whom. There may be no further action required (in which case the case can be closed to safeguarding) or further actions may be required by the local authority and/or others.
‘One outcome of the enquiry may be the formulation of agreed action for the adult which should be recorded on their care plan. This will be the responsibility of the relevant agencies to implement’. (Care and Support Statutory Guidance (DHSC, 2018) Paragraph 14.110)
In relation to the adult, this should set out:
- what steps are to be taken to assure their safety in future
- the provision of any support, treatment or therapy including on-going advocacy
- any modifications needed in the way services are provided (for example, same gender care or placement; appointment of an Office of the Public Guardian deputy)
- how best to support the adult through any action they take to seek justice or redress
- any on-going risk management strategy as appropriate
- any action to be taken in relation to the person or organisation that has caused the concern.
(Care and Support Statutory Guidance (DHSC, 2018) Paragraph 14.111)
In this case this might include the care home formulating a plan for this and other residents to prevent the error in the future; a root cause analysis establishing the causes of the error; a review of staff training and recording processes; an apology to the resident.
The local authority would determine if the resident is in need of an assessment/review (Section 9, Care Act (2014)) and is satisfied with the outcomes. The local authority would inform resident and partner agencies that the s42(2) duty has been met or, if not, what further enquiries are needed. Case Study 6 – Julie
This case study concerns domestic abuse and contains a level of complexity about whether the statutory criteria under S42(1) are met. It illustrates how, dependent on the information that emerges, the decision might be made one way or the other.
Case outline Julie is 35. She lives with her husband of 10 years. They have no children. She goes to see her GP and tells the GP she is depressed and anxious and would like some medication to help. She confides in the GP that her husband refuses to give her any money and won’t allow her friends to visit or Julie to leave the house. Julie appears to be suffering with low moods and speaks of an increased dependence on alcohol. Julie further discloses emotional, physiological, physical, financial abuse and coercion.
The GP prescribes anti-depressants and a referral to Talking Therapies. Julie agrees for the referral to be made. The psychological therapist decides to call the local authority as she thinks that this is a safeguarding adults concern.
Decision-making in this case, reflecting the approach set out in the report
Scenario one: In carrying out the S42(1) duty it might be established that there is reasonable cause to suspect that Julie:
(a) has needs for care and support (whether or not the authority is meeting any of those needs) (b) is experiencing, or is at risk of, abuse or neglect, and (c) as a result of those needs is unable to protect himself or herself against the abuse or neglect or the risk of it.
The conclusion might be reached that the reported domestic abuse has had such a significant impact on Julie’s mental health, as well as on her general circumstances, that she has had to seek support because she could not recognise this as abuse, has little insight into the risks and is unable to deal with this on her own (ie she had been under such coercion/control that she was effectively rendered unable to understand the GPs concerns or weigh up her options and so could not act to protect herself).
In order to come to a judgment on this, the person conducting the information gathering will need to establish Julie’s capacity to understand the risks and to take action to protect herself. This must be done either in conversation with Julie or, should it not be safe to speak to her directly, with her GP.
Within this perspective there could be reasonable cause to suspect that the three criteria in S42(1) are met and therefore it is necessary to continue to a section 42(2) duty to make enquiries in order to decide what action is necessary and by whom to address the concerns.
Where the local authority proceeds to make those enquiries and uses these to inform decisions on actions then that should be reported under S42(2).
Any form of conversation/enquiry that agrees what action is needed to keep the person safe is a S42(2) enquiry. In this case this might include: • Exploring the extent of the abuse and level of risk (to Julie and/or others) alongside Julie. This might include completing a MARAC\\textsuperscript{26} DASH\\textsuperscript{27} risk assessment tool and possible referral to a MARAC. • Exploring Julie’s rights and options and who/what is available to help/support. • Contingency plans in case the risk escalates. • Empowering Julie to reach a point where she has insight into her situation and knows how to seek help and take steps to deal with it.
The enquiry here will require a risk assessment alongside Julie to look at what is going on, the level of risk and any actions that might possibly mitigate risks.
**Scenario two:** An alternative perspective on whether the S42 duty should continue to a S42(2) enquiry:
It might be the case that (through conversations within the gathering of information to establish if the three criteria are met) it is demonstrated that Julie does have insight into the coercion and control, the abuse and the level of risk and is therefore capable of understanding the concerns and weighing up her options.
In this scenario it might be assessed that S42(1) (c) is not met because she is able to protect herself and this includes that she is capable of seeking the necessary support, armed with information and advice. She might still be offered support, but this might not be recorded under the S42(2) enquiry duty. Risk would be assessed as part of information gathering to establish whether the three statutory criteria are met and support offered through prevention and advice/information (S2 and S4 Care Act (2014) duties).
Conversations within information gathering to establish whether the three statutory criteria are met might have taken in the following but because Julie’s situation did not meet the criteria the risk is assessed and the advice is offered through prevention rather than through safeguarding enquiry.
This might include:
• exploration of the type, nature, level of abuse Julie is experiencing and whether any children or other adults with care and support needs live within the household; this may include conducting a MARAC DASH risk tool and discussions about a MARAC referral if appropriate • explanation of her right to live free from abuse and that there are steps she can take to protect herself from abuse • offer of a safe space for Julie and ways she can report if she is in immediate danger or the abuse escalates • offer a referral to independent domestic abuse adviser (IDVA) service • consideration of whether Julie is able to understand this information, weigh up her options and act to protect herself.
Whether or not the S42(2) duty to make enquiries is triggered some of the same conversations and actions will take place. One route is not in or of itself more effective than the other. It is for SABs, police and local authorities to be clear about effectiveness and outcomes whichever route is followed.
\\textsuperscript{26} Multi Agency Risk Assessment Conference (where professionals share information on high risk cases of domestic violence and abuse and put in place a risk management plan). \\textsuperscript{27} The Domestic Abuse, Stalking and Honour Based Violence (DASH 2009) Risk Identification, Assessment and Management Model was implemented across all police services in the UK from March 2009. Application of the six safeguarding adults principles that should underpin all adult safeguarding work are set out in section three of the main report and in Appendix 1.
These might be reflected as follows:
- **Empowerment** – involving Julie and possibly others whom she trusts and who can support her. Best practice might engage an independent domestic violence advocate or potentially a family group conference to involve and engage other family members in exploring needs, risks and potential support as part of both the enquiry and the ongoing actions. Empower Julie with information about options.
- **Protection** – enquiries are made, and action planned to protect and empower Julie. The level of risk is assessed alongside Julie so that she can have better insight into the level of risk.
- **Prevention** – proactive support at this stage might stop escalation of control/harm.
- **Proportionality** – the risk is assessed alongside those involved and this informs a proportionate response.
- **Partnership** – work is undertaken in partnership with Julie and if possible other members of her family/support network as well as with professionals and support workers who can contribute.
- **Accountability** – the rationale for the decision to undertake an enquiry (and then later decisions about actions coming out of the enquiry) are clearly recorded.
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e113e6810a37c375a26f2ab0d09113adae1f031b | Hammersmith & Fulham
Executive Summary of Ofsted Self-Evaluation – September 2020 Children’s Service Vision:
- to improve the lives and life chances of our children and young people
- intervene early to give them the best start in life and promote their wellbeing
- to ensure children and young people are protected from harm
- and ensure that all children have access to an excellent education that helps them achieve their potential
- all of this will be done whilst reducing costs and improving service effectiveness Socio-demographic and factual data
- There are 36,898 children under the age of 18 (20% of the total H&F population)
- 32% of all children are of an ethnic minority
- The average deprivation levels (expressed as an IDACI score and percentage) of children living in H&F for 2019 was 18.6%. This is a decrease from 26.7% in 2015 and makes H&F the 14th most deprived borough in London.
- 945 children and young people had been identified as needing specialist support from the local authority, at 31 March 2020.
- 141 (39 per 10,000 children) children and young people were the subject of a child protection plan
- 252 (68 per 10,000) children and young people were looked after by the local authority, an increase from 245 (66 per 10,000 children) at 31 March 2019.
- Since the last inspection, two serious incident notifications have been submitted to Ofsted and two rapid reviews have been completed, and we are currently completing two serious case reviews (commissioned prior to new arrangements).
- 93% of state funded schools in the borough are rated as good or outstanding. Hammersmith & Fulham Context
- Hammersmith and Fulham is an ambitious authority with the high level of support from the political leadership.
- Children's Services have a new DCS who joined in November 2019, and is leading an experienced management team.
- Children’s services is innovative and ambitious and is continually striving to improve our service delivery.
- We are proud to lead stable and robust services, with a strong focus on recruiting and retaining staff with a high skill level to deliver excellent services.
- Our well embedded Systemic Practice model helps to build effective relationships and contributes to achieving positive and sustained changes for families.
- We take pride in our focus on supporting our children and young people to achieve improved outcomes.
- Hammersmith and Fulham continues to strengthen the voice of children and young people in our decision making and service development processes.
- In May we formed Vulnerable Children’s Working Group in response to C19 to ensure that we worked closely with schools to track attendance and ensure robust oversight of all our vulnerable children during COVID-19. Shared Services
Shared services with Bi-Borough
- LSCP
- MASH
- Fostering & Permanence
- Missing Coordinator
- GMACE
- Emergency Duty Team (EDT)
- Centre for Systemic Social Work
- Children’s Placement Team
Shared Service with Ealing, Hounslow and Brent
- Adoption Service (since October 2019) Focus on Practice – service developments
- **Trailblazer Mental Health Support Teams** - H&F is part of both the first and second mental health trailblazer programmes. The first wave started in September 2019 and the second wave will start later this year. The programme complements existing mental health services and targeted at meeting low-to-moderate levels of need in schools including alternative provisions.
- **Transition and Resilience service** – successful bid by Family Support, funded by the Youth Endowment Fund. Aims to tackle youth violence by reducing school exclusions. It will do this by providing intense support to children and young people during key moments of transition and brain development.
- **Specialist Behaviour Service** - new multi-disciplinary behaviour support service to support children and young people with learning disabilities and autism who are at risk of tier 4 hospital admission or residential placement.
- **Oversight of complex and high risk cases** - a panel, with membership at assistant director level, that offer strategic oversight and operational direction to managing complex and high-risk cases that the existing frameworks and processes are proving ineffective in safeguarding and supporting the children and young people.
- **NHSE Keyworker pilot** - successful bid for a NHSE keyworker pilot. This will bring a new model of co-ordination across the NHS and LA Focus on Practice – service developments
- **Response to serious youth violence** - new Gangs Violence and Exploitation Unit became operational in August 2020. Joint Local Authority and Metropolitan Police initiative to focus on early intervention and diversion of young people who are at risk of involvement in serious youth violence.
- **Supporting Families Against Youth Crime (SFAYC)** - funded by MHCLG through successful bid. And commenced in October 2019. A Contextual Safeguarding Coordinator works with selected Voluntary and Community Sector partners to support children and young people at risk of or involved in offending and their families. As at 30/06/20, the project has worked with 55 children and young people, with reported significant reductions in involvement in crime. 78% reduction in reported crime among the engaged cohort in the first quarter.
- **Family Support Digital Service - COVID:**
- Home learning activities and past virtual sessions
- Alby TV and interactive Facebook sessions
- Time to Connect and Overloaded toolbox for families
- Building Resilience: Returning to School Programme: guidance and training to help prepare schools and staff post lockdown
- Counselling and educational materials for home-schooling to support families no longer able to access Children’s Centres Corporate Parenting and Participation
- Development of Corporate Parenting Board and Steering Group
- Agenda led by young people
- Well supported by political senior leaders & other LA departments.
- You said we did informing practice changes
- Youth take over challenge day
- Biggest Youth Take Over Challenge – *With Me 4 Me* – event in November 2019.
- 120 children from diverse backgrounds including those in care, care leavers, children in need and those not involved with service
- Children’s Advocate – advocates for looked after children and children subject to child protection plan.
- Participation officer
- Coordinates CiCC & Care Leavers Group; consultation activities; drop in/group sessions (health and wellbeing, cooking, quiz nights, trips to the zoo etc); achievement event.
- Gary Lineker event; care leaver apprenticeship at Otto’s
- Activities continued virtually during COVID – lockdown survey
- Virtual achievement event in July – 78 awards for children & young people
- Restoration lead – consultation and engagement for children & young people involved with YOS
- LSCP engagement officer – recruiting young safeguarding scrutineers
Hammersmith & Fulham Council Children looked after and care leavers virtual awards 2020
- The Corporate Parenting Board held a virtual version of our highly successful achievement and celebration event for children looked after and care leavers on 29th July 2020.
- Seventy-eight of our children and young people were nominated for their fabulous achievements across seven categories: significant contribution, young leader, education, young artist, making a difference, overcoming adversity, and achievement in sports.
- We had an incredible 98 people on the Microsoft Teams event with staff, carers and young people joining in. The evening included individual awards for 78 young people, videos from members of the Children in Care Council sharing their achievements, a beautiful song written and performed by one of our young people, and some of the amazing submissions from the creative challenge. Focus on outcomes
Children needing help and protection
- Timeliness of assessments increased from 75.5% at the end of March 2020 to 94% YTD.
- Re-referrals YTD is 18% - this is lower than the SN and national average of 19.0% and 23.0% respectively.
- ICPCs timeliness of 86% - higher than the SN and inner London average at 74.0% and 76.0% respectively.
- There is good engagement between Family Support, statutory social care and partners agencies with 20% of cases jointly allocated with social care.
Looked After Children:
- At the end of August 2020, 8.3% children and young people had three or more placements. This represents strong performance as London and national average stands at 10% and 10.4% respectively.
- 40% of our children looked after achieving grade 4 or above in English and Mathematics GCSE this year, with 25% achieving grade 5 and above (compared to 7.2 nationally in 2019).
- In 2019/2020 we had 3 adoptions, 22 SGOs and 4 CAOs.
- No permanent exclusions. Fixed term exclusions reduced from 21 to 11 children.
Care Leavers:
- Provision of high quality accommodation to support care leavers to live independently
- 60% are EET
- 94% are in suitable accommodation
- We are in touch with all care leavers except with those who are long term missing
- 32 are attending university Operating context
High CLA rate Historically high rate of CLA. 242 (66 per 10,000) CLA as at 31/08/20. A decrease from 252 (68 per 10,000) in March 2020.
Increasing rate of CPP 180 children subject to a child protection plan as at 31/08/20. An increase of 27.7% since March 2020. Key learning– areas of development
Adolescent and edge of care
- To provide timely and effective support to children at risk of coming into care and families finding it hard to manage adolescent behaviours
- A workstream has started and is pulling together all services for adolescents in order to design a more effective offer for adolescents
Permanence planning and oversight
- To improve timeliness and oversight of permanence planning
- The terms of reference for the Permanency Tracker Panel and Permanence Board have been updated to track, monitor and respond to likely delays earlier in the journey of the child
Independent living skills training and transitions
- To ensure that young people can move and live successful adult lives
- A workstream has been launched to review the existing offer and develop a more holistic independent living skills programme
Disproportionality
- We have high rates of children from Black, Asian and Minority Ethnic groups in our children looked after and youth offending cohorts
- We have started pulling together data and responses from services, including multiagency partners, to understand why this is so and agree a workable intervention plan
Business intelligence
- To ensure we have full suite of performance report for strategic and operational managers to understand and improve services for children and families
- A business intelligence activity plan and timetable has been implemented with operational oversight from the Mosaic Board and senior oversight from the steering group and Statutory Accountabilities Board Ofsted recommendation 1
Availability of robust performance data
We have committed a significant investment of resources enabling us to provide access to a wider range of reliable data and live tools, and to strengthen our performance framework.
Delivery Milestone
- A specialist children’s social care BI lead and data analyst have brought in sector expertise to enhance the pace of development of a full suite of high-quality performance reports
- We have invested in the roles of Assistant Director for Performance and Improvement and Head of Performance and Improvement to enhance the pace and commitment, and to embed a stronger performance culture
- We have developed a much stronger collaboration with the BI and Mosaic teams to jointly own the improvement work which is overseen by a steering group of senior officers
- A new performance management framework has been in place since December 2020
- Data now available includes weekly performance summaries, a monthly performance report, a Covid-19 and vulnerable children dataset and a developing suite of live dashboards
- Managers are supported to use the new tools and held to account for their team’s performance at monthly practice boards
- An ambitious timeline has been agreed for completion of the full performance suite by April 21—Appendix 4. The work is supported by the Mosaic Board and overseen by the Performance Management Board, chaired by the DCS
Impact
- Availability and access to performance reports are leading to a better understanding and responses from managers including improvements in the timeliness of visits, assessments and supervision
- Live performance dashboards accessible to team managers
- Improved intelligence is supporting better understanding and strategic planning Ofsted recommendation 2
Case recording, including supervision records and robust recording of the management of allegations
Delivery Milestone
- Weekly Mosaic training and surgeries are being delivered to social workers and a Mosaic Change Board involving heads of service and the Mosaic team is taking place
- Changes have been made to Mosaic steps and quick reference practice guides produced on specific areas of work
- A new manual recording system and an action plan for the management of allegations has been implemented. A plan to develop a case management system on Mosaic is underway
- Oversight has been strengthened by Independent Reviewing Officers (IROs) through mid-point reviews, IRO conflict resolution/escalation protocol and a Mosaic recording step
Impact
- Performance reports show sustained improvements in timeliness of assessments, supervision and visits
- Practice week audit in February 2020 showed improvements in case recording, updated chronologies, the timeliness of supervision and management oversight.
- Supervision audits reported improvements in the timeliness of supervision and management oversight Ofsted recommendation 3 Capacity within the early help and contact and assessment services
- Family Support (early help) capacity was reviewed in January 2020 and capacity increased by 17%. We are currently reviewing the Family Support offer because of budgetary constraints. This will impact on staffing levels but ensure better interface with social care and a focus on vulnerable families.
- New centralised allocations and workload management systems in Family Support commenced in March 2020.
- An external audit of Family Support was completed in February 2020. The review highlighted positive practices and recommended areas for improvement. An action plan is in place.
- A Social Care caseload benchmarking and workload management system is currently in development.
- Family Support has recruited a senior Business Intelligence lead to help the service better understand the families they are working with and to target the right families. This work will improve the interface between the Family Support and Family Services and help us to better understand the impact of our early help service.
Impact
- Timely responses to families with many cases resolved without needing allocation.
- New centralised allocation system leading to effective and coordinated responses.
- Workload management ensures timely and proportionate allocation of cases.
- Timely and improved performance reporting is enabling managers to track allocations and capacity and allowing flexibility when needed. This has ensured that social workers have manageable caseloads and assessment timeliness significantly improved.
Hammersmith & Fulham Council Ofsted recommendation 4 Consistency of multi-agency information sharing and participation at strategy discussions
Delivery Milestone
- Work has taken place at Safeguarding Partnership meetings to increase participation at strategy discussions
- Participation is discussed quarterly at Safeguarding Partnership Meetings and with CCG and Police leads
- A thematic audit of strategy discussion and section 47s has been completed and learning shared. The September 2020 Practice Week will dip sample strategy discussions and section 47s to assess their quality
- A one-minute guide on section 47s has been developed
Impact
- Participation/attendance at strategy discussions/meetings by health & Police has significantly improved, enhanced by the switch to virtual meetings since COVID-19
- Virtual strategy discussions/meetings are being established as part of our practice model Ofsted recommendation 5 The quality of planning for children in need
Delivery Milestone
- This is an area where we still have insufficient data and, as a result, our oversight of practice is not as strong as we would want. We have therefore commissioned an external auditor to review CIN work and thresholds. This work started in September 2020, after a delay due to the COVID-19 lockdown
- The BI team is developing reporting capability for CIN plans and reviews.
- Good quality examples of CIN plans are shared with social workers
- Team managers are routinely checking quality, outcomes and duration of CIN at supervision
- The Vulnerable Children’s working group, in response to COVID-19, RAG rated all cases, including children in need. The RAG ratings are subject to regular reviews
Impact
- Increased oversight by team managers
- Improved CIN plans Learning and Improvement Framework. How we know about our performance?
- **Performance Management Framework**
- Performance Management Board - It scrutinises high level business and performance reports and identifies key lines of enquiries for further interrogation and reporting.
- Improvement Board – It brings challenge and rigour to the improvement process and provides assurance and monitoring of improvement activities.
- Practice Forum – focuses on in-depth interrogation of performance by service area.
- Performance and Quality Forum brings together all managers including Independent Reviewing Officers (IROs) and Child Protection Advisers (CPAs) to review key performance, themes from audits and to share learning.
- Learning and Improvement Workshops bring together social workers and managers to consider key performance, themes from audits and reviews, and the resultant learning.
- External audits and reviews – CIN reviews, high risk cases review, family support audit.
- **Engagement of children and families** – Practice Week, Customer Care month, FS Trustpilot
- **Complaints and compliments** – delay in annual reporting
- **External audits/reviews** – Family Support, Complex & high risk cases (September 2020).
- **Serious case/child safeguarding reviews**
- **Governance and accountability arrangements** - Cabinet Member Briefings, Statutory Accountability Board, Local Children Safeguarding Partnership, Corporate Parenting Board, Bi-monthly Children and Education Policy and Accountability Committee (CEPAC) Learning and Improvement Framework. How we know about our performance?
Audit Framework
➢ Practice Week It had shown that social workers and practitioners know their cases well, appropriately assessing need and risk. The voice of the child and their lived experience were evident in 85% of cases Good management guidance was reported in 95% of cases
➢ Mental Health Audit Social workers have good knowledge of children’ need and advocated on their behalf, Good care arrangements and input from carers advocated, evidence of effective multi agency work
➢ Supervision Audit showed improvements in case recording, updated chronologies, the timeliness of supervision and management oversight
➢ COVID Audit Framework A range of audit activities were carried out from April 2020 to provide assurance that safeguarding practice was robust during the COVID lockdown
➢ Effectiveness of Child Protection Plans Thresholds were found to be appropriately applied during this period in respect of ICPCs. Risk assessments were completed, and RAG rating updated following each visit. The Quality Assurance function had been strengthened with Child Protection Advisors conducting mid-point monitoring on child protection plans Learning and Improvement Framework. How we know about our performance?
➢ Child Protection Visits Visits audited during lockdown were of good quality and those that were conducted virtually were found to be insightful and addressed risks. There was positive engagement with the families. Social workers engaged with children and families in a range of innovative ways such as a fitness session and a video CV writing session with a hard to reach young person. Good co-working and joint visits were undertaken with partner agencies including the Violence Intervention Project (VIP) and with CaMHS.
➢ Repeat Child Protection Plans In all the cases a repeat CPP decision was appropriate at the time however in some cases more could have done either before or after step down of the preceding CPP; responses could have been sharper when concerns started to re-emerge after step-down/closure; or other planning frameworks could have been considered.
➢ Missing Children There was a co-ordinated response based on the local COVID missing list and the MASH list compiled by the Missing Child Co-ordinator. The Missing Child Co-Ordinator reported an improvement in the recording of missing episodes in terms of accuracy and stronger management oversight, especially in the Looked After Children service. Cross-borough work was facilitated by the Missing Child Co-ordinator and there was strong examples of cross borough strategy meetings and mapping work. There was evidence of good quality Return Home Interviews. Governance and accountability arrangements
The council maintains a high support, high challenge and high expectations culture that combines being compassionate and financially ruthless. This culture runs through the council’s leadership, governance and oversight arrangements, including:
- **Cabinet Member Briefing**, where the Lead Member for children and education meets with the Director of Children Services and Assistant Directors fortnightly to discuss strategic issues and interrogate performance.
- **Statutory Accountability Board**, where directors and chief officers have sight of key reports and performance to interrogate and understand performance in relation to children and families and recommend next steps.
- **Local Children Safeguarding Partnership**. This remains a Tri-borough partnership arrangement. An independent review, which includes consideration of a move to a sovereign arrangement, is taking place with a report due imminently.
- **Corporate Parenting Board** quarterly forum where the Lead Member, councillors, senior leaders and children in care council meet to question and review practice and outcomes for children looked after and care leavers and agree areas for further development. The Board has met virtually during the COVID-19 lockdown.
- **Bi-monthly Children and Education Policy and Accountability Committee (CEPAC)** where councillors and residents scrutinise performance and hold senior managers to account and develop policy recommendations to improve our services.
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07e3b0ad214166ef4607e880d50c97fcca7e5c98 | BLABY DISTRICT COUNCIL PAY POLICY STATEMENT 2017/18
1. Introduction
1.1 Section 38 of the Localism Act 2011 requires local authorities to produce an Annual Pay Policy Statement
1.2 This Pay Policy Statement includes:
(a) the level and elements of remuneration for Chief Officers; (b) the remuneration of the lowest paid employees; (c) the pay differential, known as the ‘pay multiple’ between the remuneration of Chief Officers and other officers and (d) other aspects of Chief Officer remuneration, fees and charges and other discretionary payments
2. Principles
2.1 Blaby District Council recognises that, in the context of managing scarce resources, remuneration at all levels needs to be adequate to secure high quality employees who provide excellent services to the public, yet at the same time needs to avoid being unnecessarily generous or otherwise excessive. This pay policy sets out how the Council determines pay decisions across all aspects of pay and provides a framework to assist council Members in determining a pay strategy in a fair and equitable way within the council’s Medium Term Financial Strategy.
2.2 The Public Sector Equality Duty also requires the Council to develop and publish a policy on how it is meeting its duty, having due regard to the need to eliminate unlawful discrimination particularly in relation to employment and pay. The council supports the principle of equal opportunities in employment and acknowledges that men and women should receive equal pay for the same or broadly similar work, for work rated as equivalent and for work of equal value. This Pay Policy sets out the Council’s approach in ensuring equality of pay in line with those legal requirements.
2.3 It is important that local authorities are able to determine their own pay structures in order to address local priorities and to compete in the local labour market.
3. Scope
3.1 The policy covers all staff employed by the Council irrespective of grade and conditions of service. It will have reference to national agreements which affect pay and grading including:
- National Agreement on Pay and Conditions of Service (the Green book, for all staff below Head of Service) Joint Negotiating Committee for Chief Officers Joint Negotiating Committee for Chief Executives
A copy of the Council’s salary scales is at Appendix A.
4. Remuneration of senior officers
4.1 In this policy the senior pay group refers to posts within the top three tiers of the organisation. These include the Chief Executive (x 1), Directors (x 2), Group Managers (x 5) and Strategic Managers (x 2). This policy also reflects the changes to the pay scales for Directors, Group Managers and Strategic Managers which was agreed at Council on 14 November 2017 and took effect from 1 December 2017.
4.2 Chief Executive
4.2.1 The Chief Executive is the head of the council’s paid service. The salary paid to the Chief Executive is approved by full Council at the time of appointment, and excludes Returning Officer fees which are paid separately.
4.2.2 The current salary range for the Chief Executive is £89,659 - £102,010 per annum; the range contains 5 increments and is subject to cost of living increases agreed by the Joint National Council (JNC). This is a local grade which was established in 2011, following an analysis of the degree of responsibility in the role, benchmarking with other comparators and the ability to recruit and retain an exceptional candidate.
4.2.3 The Chief Executive Remuneration Panel, which comprises of the elected leader and the leaders of the opposition groups, determines incremental pay progression on an annual basis with the potential to increase one point every year subject to agreed priorities being met. The current Chief Executive is currently on point 3 of a 5 point scale.
4.2.4 Other conditions of service are as prescribed by the JNC for Local Authority Chief Executives national conditions.
4.3 Directors, Group Managers & Strategic Managers
4.3.1 The pay and grading for the Group Managers and Strategic Managers are evaluated using a local evaluation scheme. Its methodology reviews current job information including: job descriptions, staff structure including lines of accountability and capital and revenue budget responsibility. This information is used to determine the value of the job size and comparison with other Councils.
4.3.2 From 1 December 2017, the grades are as follows:
| Role | Salary Range | |-----------------------|----------------| | Directors | £73,427 - £83,500 | | Group Managers | £56,000 - £67,662 | | Strategic Managers | £46,279 - £54,007 | Prior to these changes (i.e. from 1 April 2017 until 30 November 2017) the following grades were used:
| Grade | Salary Range | |----------------|----------------| | Directors | £66,662 - £79,373 | | Chief Officers | £46,279 - £63,277 |
4.3.3 These salaries are subject to cost of living increases agreed by Joint Negotiating Committee for Chief Officers. Other conditions of service are as prescribed by the JNC for Local Authority Chief Officers.
4.4 Other allowances
4.4.1 The Council operates an essential car user scheme in accordance with JNC handbook.
4.4.2 Fees are payable for Returning Officer duties which are not part of the post holder’s substantive role. Whilst appointed by the council, the role of the Returning Officer is one which involves and incurs personal responsibility and accountability and is statutorily separate from his/her duties as an employee of the council. Returning Officer fees are variable and paid based upon the number of electors per election. The Returning Officer for the council is the Chief Executive.
4.4.3 For any Chief Officer who undertakes duties that have been procured by another local authority, a discretionary payment (honorarium) will be made following an assessment of the additional time that the Chief Officer will spend in carrying out these additional duties.
4.4.4 There are two additional proper officer appointments within the Council; that of S151 Officer and the Monitoring Officer. The S151 Officer role is currently undertaken by a Strategic Director and recompense for this responsibility is subsumed within the current salary for this role. The Monitoring Officer appointment is currently carried out by a Group Manager who receives an additional responsibility allowance.
4.4.5 One Group Manager also receives a nominal sum for acting as the first point of contact for the Council in time of emergencies. As such they could be contacted at any time of day or any day of the week to help co-ordinate urgent responses at a time of crisis. There are no other additional elements of remuneration in respect of overtime, bank holiday working, standby payments etc. paid to senior staff as they are expected to undertake duties outside their contractual hours and working patterns without additional payment.
5. Pay Structure
5.1 The current pay structure (Grades 1-9) applies to all employees excluding the senior pay group. Salaries within the pay spine are subject to pay awards as agreed by the National Agreement on Pay and Conditions of Service (NJC). From 1 April 2017 the lowest point on the pay spine is spinal point 6, which is based within Scale 1 and has a full time equivalent basic pay rate of £15,014 per annum.
5.2 All posts are evaluated using the NJC Job Evaluation Scheme, which is recognized by public sector employers and unions nationally. This scheme allows for robust measurement against set criteria resulting in fair and objective evaluations and ensures equal pay.
5.3 Progression within the grade for all staff takes place annually on 1 April, with the exception of newly appointed employees with start dates between November and March, who will receive their first increment six months after their start date. Any subsequent increments will then occur on 1 April in line with all other employees.
5.4 The grading structure aims to meet the current and/or market position for most jobs. At certain times some types of jobs are very scarce either because of national shortages or high demand for certain skills.
6. Other allowances
6.1 NJC employees may claim allowances which may be locally and nationally agreed in the course of their work duties. A list of typical allowances that employees can claim is set out at Appendix B.
7. Pension Arrangements
7.1 All employees of the council, irrespective of pay group, are entitled to join the Local Government Pension Scheme. The table below sets out the varied rates that employees are required to contribute based upon their whole time salary.
The employee contribution rates for 2017/18 are below:
| Actual Pensionable Pay | Gross contribution rate | |------------------------|-------------------------| | Up to £13,600 | 5.5% | | £13,601 to £21,200 | 5.8% | | £21,201 to £34,400 | 6.5% | | £34,401 to £43,500 | 6.8% | | £43,501 to £60,700 | 8.5% | | £60,701 to £86,000 | 9.9% | | £86,001 to £101,200 | 10.5% | | £101,201 to £151,800 | 11.4% | |----------------------|------| | More than £151,801 | 12.5%|
The council, as an employer, currently contributes 20.59% of the employee’s basic salary plus an overall flat rate cash contribution of £153,000 to the fund. This equates to approximately 23.8% of pensionable pay.
8. **Multipliers**
8.1 Publishing the pay ratio of the organisation’s top earner to that of its lowest paid earner and median earner has been recommended to support the principles of Fair Pay (Will Hutton, 2011) and transparency.
8.2 In the context of the council’s payroll the Chief Executive, who is the top earner in the Council, currently earns £97,604 per annum. This is 3.81 times the average earnings in the Council, 4.28 times the median earnings and 6.14 times the lowest earner.
8.3 The multipliers will be monitored each year as part of the review of the Pay Policy Statement.
9.0 **Severance Payments**
9.1 The council operates a voluntary severance scheme which is applicable to all employees of the Council. The scheme applies to:
- Redundancy
- Voluntary early retirement
9.2 **Redundancy**
Redundancy payments are payable to Employees, who are dismissed on the grounds of redundancy and who have at least two years’ continuous employment at the date of termination of employment. Redundancy payments use an actual week's pay (annual salary divided by 52 pro rata’d as appropriate) or the statutory capped figure, whichever is the higher.
9.3 **Early Retirement – efficiency grounds**
Employees who will be 55 or more and have at least 2 years’ pensionable service in the Local Government Pension Scheme (LGPS) may retire early upon entering into a formal agreement with the Council which will include a mutually agreed retirement date, where it is considered to be in the interests of the efficient exercise of the Council’s functions. The employee will not receive a severance payment or additional year’s service but will have access to the pension scheme. The capital cost of early payment of pension benefits is subject to approval by Council. 9.4 Flexible Retirement
An employee who is a member of the LGPS and 55 years or over may request, with the Council's consent, to reduce their hours and/or grade and make an election to the administering authority for payment of their accrued benefits without having retired from employment. However, the council will only agree to release pension where there is no capital cost to the authority.
10. Re-employment/engagement of senior managers
10.1 Where a senior manager, as defined under paragraph 4.1, has left the authority on redundancy or early retirement grounds, the authority will not normally re-employ at a later stage or re-engage the former employee as a consultant.
11. Decision Making
11.1 Decisions on remuneration are made as follows:
(a) Chief Executive local pay structure approved by full Council (b) Performance progression of Chief Executive approved by Chief Executives Remuneration Panel (c) Pay structure for Directors and Chief Officers posts approved by full Council
## BLABY DISTRICT COUNCIL SALARY SCALES
### 1 APRIL 2017
| Scale 1 | Scale 2 | Scale 3 | |----------|----------|----------| | (0-279) | (280-379)| (380-428)| | S.P. | £ | S.P. | £ | S.P. | £ | | 6 | 15,014 | 12 | 16,123 | 18 | 18,070 | | 7 | 15,115 | 13 | 16,491 | 19 | 18,746 | | 8 | 15,246 | 14 | 16,781 | 20 | 19,430 | | 9 | 15,375 | 15 | 17,072 | 21 | 20,138 | | 10 | 15,613 | 16 | 17,419 | 22 | 20,661 | | 11 | 15,807 | 17 | 17,772 | | |
| Scale 4 | Scale 5 | Scale 6 | |----------|----------|----------| | (429-468)| (469-554)| (555-609)| | S.P. | £ | S.P. | £ | S.P. | £ | | 23 | 21,268 | 28 | 24,964 | 35 | 30,785 | | 24 | 21,962 | 29 | 25,951 | 36 | 31,601 | | 25 | 22,658 | 30 | 26,822 | 37 | 32,486 | | 26 | 23,398 | 31 | 27,668 | 38 | 33,437 | | 27 | 24,174 | 32 | 28,485 | 39 | 34,538 | | | | 33 | 29,323 | | | | | | 34 | 30,153 | | |
| Scale 7 | Scale 8 | Scale 9 | |----------|----------|----------| | (610-639)| (640-654)| (655-669)| | S.P. | £ | S.P. | £ | S.P. | £ | | 39 | 34,583 | 43 | 38,237 | 48 | 42,899 | | 40 | 35,444 | 44 | 39,177 | 49 | 43,821 | | 41 | 36,379 | 45 | 40,057 | | | | 42 | 37,306 | 46 | 41,025 | | | | 43 | 38,237 | 47 | 41,967 | | | CHIEF EXECUTIVE & CHIEF OFFICER PAY SCALES
1 APRIL 2017 – 30 NOVEMBER 2017
**Chief Officers**
| Scale 10 | Scale 11 | Scale 12 | |----------|----------|----------| | (670-689) | (690-710) | (711 - ) | | S.P. £ | S.P. £ | S.P. £ | | A 46,279 | A 50,381 | A 56,000 | | B 49,699 | B 54,007 | B 59,638 | | C | | C 63,277 |
**Directors**
| Scale 13 | Scale 14 | |----------|----------| | S.P. £ | S.P. £ | | A 67,662 | A 75,629 | | B 69,755 | B 79,373 | | C 73,427 | |
**Chief Executive**
| S.P. £ | |--------| | A 89,659 | | B 93,570 | | C 97,064 | | D 100,557 | | E 102,010 |
# CHIEF EXECUTIVE & CHIEF OFFICER PAY SCALES
1 DECEMBER 2017
## Strategic Managers
**Scale 11**
| Grade | Pay Range | S.P. (£) | |-------|-----------|----------| | A | 670-710 | 46,279 | | B | | 49,699 | | C | | 50,381 | | D | | 52,194 | | E | | 54,007 |
## Group Managers
**Scale 12**
| Grade | Pay Range | S.P. (£) | |-------|-----------|----------| | A | 711-711 | 56,000 | | B | | 59,638 | | C | | 63,277 | | D | | 65,525 | | E | | 67,662 |
## Directors
**Scale 14**
| Grade | Pay Range | S.P. (£) | |-------|-----------|----------| | A | 73,427 | | | B | 75,629 | | | C | 79,373 | | | D | 81,400 | | | E | 83,500 | |
## Chief Executive
**Scale 16**
| Grade | Pay Range | S.P. (£) | |-------|-----------|----------| | A | 89,659 | | | B | 93,570 | | | C | 97,064 | | | D | 100,557 | | | E | 102,010 | | Appendix B
Local Allowances – NJC Staff
Saturday and Sunday Working:
If weekend working is not part of a normal working week (that is regular rostered weekend working) then the following payments apply.
Saturday - Time and half Sunday - Time and half if basic pay above SCP 11 Double time if basic pay at or below SCP 11
If weekend working is part of a normal working week then plain time rates apply unless part of an approved overtime arrangements in which circumstance overtime rates will apply.
Additional Hours and Overtime Payments
Employees, on or below SCP 34, and required to work additional hours beyond a full 37 hour week (or average 37 hour week) are entitled to receive time and half for additional hours worked Monday to Saturday and double time for additional hours worked on a Sunday.
Part time workers are entitled to these enhancements only after a 37-hour week (or average 37 hour week) is exceeded, although rostered work on a Saturday and Sunday will attract the overtime allowance.
For employees on or above SCP 35 enhanced rates will not be paid. In exceptional circumstances the Group Manager may agree that overtime at plain time rates may be paid in order to clear backlogs or catch up on projects. In normal circumstance employees are expected to accrue and bank approved additional hours as time off in lieu. Managers have a responsibility under health and safety legislation to ensure that excessive hours are not worked and that accumulated TOIL is taken on a regular basis.
Overtime payments are full settlement and are not enhanced by any other allowance e.g. a shift allowance that is paid on normal working hours.
Public and Extra Statutory Days
Employees required to work on a public or extra statutory day shall be paid at plain time for all hours worked within their normal working hours for that day. In addition, time off with pay shall be allowed as follows: Less than half normal hours worked – half day More than half normal hour’s worked – full day
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a014afe669e16556670bb4df2ad36c7c28ece238 | Appendix 1
Sites Consultation Local Plan Part 2 October 2017
Regeneration, Enterprise & Planning Northampton Borough Council, The Guildhall, St Giles Square Northampton NN1 1DE 0300 330 7000 www.northampton.gov.uk Contents
Introduction............................................................................................................................................4 What is the Local Plan Part 2? ............................................................................................................4 The purpose of the Sites Consultation ...............................................................................................4 What has been done so far? ...............................................................................................................4 This Consultation ....................................................................................................................................5 How to respond ......................................................................................................................................6 The Planning Context..............................................................................................................................6 Previous Consultation on the Local Plan Part 2 ..................................................................................6 Housing...............................................................................................................................................7 Employment .......................................................................................................................................9 Consultation Questions ........................................................................................................................10 Northampton Local Plan Part 2 - Sites Consultation
Introduction
What is the Local Plan Part 2?
1.1 The Council is preparing the second part of the Local Plan. The Local Plan Part 2 will help to deliver the strategy set out in the West Northamptonshire Joint Core Strategy, which is Part 1 of the Local Plan for Northampton, Daventry and South Northamptonshire.
1.2 The Local Plan Part 2 will address the supply of sites in the Borough to deliver more homes, maintain and expand employment opportunities, enhance the Town Centre, protect the historic and natural environment, and provide detailed development management policies for the Borough as a whole.
1.3 These policies will be used to determine planning applications for new development and identify sites where new development should go to meet the requirements set out in Part 1 of the Local Plan up to 2029.
The purpose of the Sites Consultation
1.4 The purpose of this consultation is to gather views on the potential future uses of sites to deliver the strategy and development required in Part 1 of the Local Plan. Any views will be considered alongside further work before deciding what goes into the Draft Local Plan Part 2. The Draft Plan will be subject to further consultation prior to a formal examination hearing.
1.5 In order to meet the development requirements set out in Part 1 of the Local Plan, the Local Plan Part 2 will need to allocate sites for development, including land for housing. This is the first public consultation that sets out a list of sites to be considered for further investigation in preparing the Local Plan Part 2.
1.6 The list contains sites that were submitted to the Council by land owners and developers, and for completeness includes council owned sites. It is important that all site options are explored for accommodating future development at this stage.
1.7 It should be noted that no decisions have been made about any of the sites mentioned in this consultation, and that all consultation responses will be taken into account when we draw up a more detailed draft plan for the next stage of the consultation process.
What has been done so far?
1.8 The Sites Consultation follows on from two rounds of consultation carried out in 2016 in which views were sought on the issues to be addressed in the Local Plan Part 2 and the options for how they might be dealt with in the Local Plan Part 2. These represented the first two stages in the process for producing the Local Plan Part 2 and provided the community of Northampton and other stakeholders with the opportunity to suggest any issues that they felt should be addressed and to comment on the options they thought were most appropriate.
1.9 The Local Plan Part 2 process is set out below. This Consultation
2.1 This document has been prepared following a review and update of the Council’s background evidence, consideration of responses to the Issues and Options consultations and having regard to national policy and best practice guidance.
2.2 Appendix A is a list of sites that have been assessed as being suitable for further consideration in preparing the Local Plan Part 2. Appendix B is a list of sites that have been assessed as not being suitable for further consideration. 2.3 It is important to note that the inclusion of sites in this consultation does not mean that they will be considered appropriate for development in the Local Plan Part 2. Comments received during this consultation and further work will be required before any decisions are made about what will go into the Draft Plan.
2.4 The purpose of this exercise is to help assess whether or not sites are worthy of further consideration. We would therefore like your views on the on the potential future uses of these sites, including which sites would be most appropriate for development, which sites would be least appropriate for development, and which sites should be protected? The Council also wants to know if there are any other sites that have not been included in this consultation which should be considered in the preparation of the Local Plan Part 2 (Call for Sites).
2.5 A series of Consultation Questions are at the end of this document. Please use the Councils online response form to respond to this consultation.
How to respond 3.1 The best way to have your say is at www.northampton.gov.uk/localplan.
3.2 If you are unable to comment online, you can also:
- Email [email protected]
- Write to: Planning Policy, Northampton Borough Council, The Guildhall, St Giles Square, Northampton, NN1 1DE
3.3 The deadline for responses is 5pm on Monday 13 November 2017.
The Planning Context Previous Consultation on the Local Plan Part 2 4.1 Comments on the issues consultation showed a general consensus on the need to identify sufficient housing sites in the Local Plan Part 2 to reach the Joint Core Strategy target of 18,870 net additional dwellings in Northampton from 2011-2029 as part of a wider strategy for the whole of the wider Northampton Related Development Area involving co-operation with Daventry District Council and South Northamptonshire Council.
4.2 Comments were also raised about the need to identify a demonstrable five year housing land supply and the need for flexible policies to kickstart housing delivery. There was also a comment that many new homes are likely to be delivered on small- and medium-sized sites and that the Local Plan needs to identify a range of such sites. This has been taken into account in this consultation document.
4.3 A number of sites not currently allocated for employment were suggested in comments as being suitable for employment. Some of these have been actively promoted for employment. Most of the comments on the issues consultation relate more to matters that will need to be considered in relation to the next stage of Local Plan consultation. 4.4 A number of responses to the Options Consultation supported the assurance that the Local Plan Part 2 would explore reasonable options to provide land to accommodate new homes, employment and other types of land use supporting growth.
4.5 Details of the responses received to the Issues and Options consultations are set out on the Council’s website http://www.northampton.gov.uk/info/200205/planning-for-the-future/2199/northampton-local-plan-part-2-issues-and-options-consultation
Housing
4.6 Part 1 of the Local Plan (The West Northamptonshire Joint Core Strategy 2014) has set the housing requirement for Northampton at 18,870 new homes from 2011 to 2029, with a trajectory for the rate at which they should be completed. Table 1 sets out the trajectory in Part 1 of the Local Plan and yearly housing completions to date. Table 1 - Housing trajectory for Northampton set out in the West Northamptonshire Joint Core Strategy, December 2014
| Year | 2011/12 | 2012/13 | 2013/14 | 2014/15 | 2015/16 | 2016/17 | 2017/18 | 2018/19 | 2019/20 | 2020/21 | |------------|---------|---------|---------|---------|---------|---------|---------|---------|---------|---------| | Core Strategy requirement for Northampton | | | | | | | | | | | | Annual | 423 | 516 | 785 | 1,039 | 1,132 | 1,292 | 1,426 | 1,544 | 1,588 | 1,491 | | Cumulative (a) | 423 | 939 | 1,724 | 2,763 | 3,895 | 5,187 | 6,613 | 8,157 | 9,745 | 11,236 | | Completions | | | | | | | | | | | | Annual | 423 | 516 | 834 | 877 | 739 | 884 | | | | | | Cumulative (b) | 423 | 939 | 1,773 | 2,650 | 3,389 | 4,273 | | | | | | Difference between (a) and (b) | 0 | 0 | +49 | -113 | -506 | -914 | | | | |
| Year | 2021/22 | 2022/23 | 2023/24 | 2024/25 | 2025/26 | 2026/27 | 2027/28 | 2028/29 | |------------|---------|---------|---------|---------|---------|---------|---------|---------| | Core Strategy requirement for Northampton | | | | | | | | | | Annual | 1,355 | 1,278 | 1,025 | 900 | 875 | 815 | 695 | 694 | | Cumulative (a) | 12,591 | 13,869 | 14,894 | 15,794 | 16,669 | 17,484 | 18,179 | 18,873 | | Completions | | | | | | | | | | Annual | | | | | | | | | | Cumulative (b) | | | | | | | | | | Difference between (a) and (b) | | | | | | | | | 4.7 Part 1 of the Local Plan has already allocated a series of Sustainable Urban Extensions (SUEs) around the edge of Northampton. Some of these are entirely within Northampton Borough and others fall within the boundaries of Daventry District Council and South Northamptonshire Council. Because these SUEs are already allocated in Part 1 of the Local Plan, it will not be necessary to allocate them in the Local Plan Part 2, so this consultation does not reconsider these sites.
4.8 Whilst the Local Plan Part 2 has to seek to meet the housing requirement in Part 1 of the Local Plan, it does not have to identify every single site that will come forward over the plan period. It only has to identify those that are key to the delivery of its strategy. This consultation only considers sites that are considered able to accommodate five or more dwellings as it is not intended to allocate smaller sites.
4.9 Even though not all sites have to be specifically identified, the Council will need to demonstrate, through its evidence that it has made a robust assessment of the sources of the supply of housing land that will come forward to meet its housing target. The Land Availability Assessment sets out the Council’s technical assessment based on information submitted so far. This may need to be reviewed and updated before we publish the draft Local Plan Part 2.
4.10 Table 2 below sets out how many homes have been built in Northampton since 2011; how many are currently under construction; how many have planning permission; and how many have been allocated in Part 1 of the Local Plan. It also shows how many houses are expected to be built on windfall sites. The capacity for new housing identified in the Land Availability Assessment on sites without planning permission is also included. This figure of 4,350 houses is comprised of the sites considered suitable for further investigation in Appendix A.
4.11 Taking into account the number of houses completed, with planning permission, and allocated in the Local Plan Part 1, leaves a balance of 3,033 against the target of 18,870 houses in Part 1 of the Local Plan. However, it is important to note that not all sites with planning permission or allocated will be delivered before 2029. Further work will need to be done on the timing and rates of delivery, particularly on large sites, to establish the amount of houses that the Local Plan (Part 2) will need to plan for.
4.12 The Land Availability Assessment indicates that beyond what has already got planning permission or is allocated in Part 1 of the Local Plan, there is sufficient land to accommodate a further 4,350 homes. Taking this into account and the potential windfall allowance of 2,400 houses, there could be sufficient land available to meet the target of 18,870 in Part 1 of the Local Plan.
4.13 Sites for housing in Northampton that the Council considers should be investigated further in preparation for the Local Plan Part 2 are set out in Appendix A. Sufficient sites without planning permission have been identified in the Council’s Land Availability Assessment to accommodate an estimated 4,350 dwellings. Table 2 – Existing completions and commitments
| Dwellings | |------------------------------------------------| | Completions, 2011 to 2017 | 4,273 | | Under construction | 368 | | With full planning permission but not yet | 2,109 | | started | | With outline permission (includes Sustainable | 4,522 | | Urban Extensions allocated in the joint Core | | Strategy) | | Allocated in the Joint Core Strategy, but | 4,565 | | without outline planning permission | | Windfall allowance (2017 -2029) | 2,400 | | LAA sites without planning permission | 4,350 | | Total | 22,587|
Employment
4.14 The Local Plan has to ensure that there is sufficient land available for employment uses (offices, industry and warehousing) and ensure that land allocated for those uses is still appropriate for those uses. The employment requirement set out in Part 1 of the Local Plan is 28,000 net additional jobs from 2008 to 2029. This is not split between the three constituent council areas, but evidence across West Northamptonshire indicates that there are broadly sufficient reserves across that area allowing for the allocation of strategic sites that will serve Northampton, such as the proposed business park at Junction 16 of the M1, just outside the borough. It is important, however, that changes in the amount of employment land are closely monitored and that existing employment land is protected and not lost to other uses unless it is no longer viable for employment generating activities. This is reflected in Part 1 of the Local Plan.
4.15 The Local Plan Part 2 only has to identify those employment sites that are key to the delivery of its strategy. Sites of less than 0.25 hectares have not been considered.
4.16 Even though not all sites have to be specifically identified, the Council will need to demonstrate, through its evidence, that it has made a robust assessment of the sources of supply of employment land that will come forward to meet its requirement for employment land. The Land Availability Assessment sets out the Council’s technical assessment based on information submitted so far. This may need to be reviewed and updated before we publish the proposed submission version of the Local Plan Part 2. Consultation Questions
Please use the online response form (see above for details)
1. Which sites that have been assessed as being suitable for further consideration (Appendix A) do you think are most appropriate for development?
Please state site number(s) – e.g LAA0999
Please tell us why you think these sites are most appropriate
2. Which sites that have been assessed as being suitable for further consideration (Appendix A) do you think are least appropriate for development?
Please state site number(s) – e.g LAA0999
Please tell us why you think these sites are least appropriate
3. Which sites do you think should be protected?
Please state site number(s) – e.g LAA0999
Please tell us why you think these sites should be protected
4. Are there any sites that have been assessed as not being suitable for further consideration (Appendix B) that should be?
Please state site number(s) – e.g LAA0999
Please tell us why you think these sites should be protected
5. Which sites do you think should be used for other purposes?
*Please state site number(s) – e.g LAA0999*
*What do you think would be the best use for these sites? Please tick*
[ ] Residential
[ ] Employment uses
[ ] Retail
[ ] Community facilities
[ ] Open space / green space
[ ] Waste
[ ] Other
*If you have answered Other, please specify*
*Please state why you think these sites would be better suited to these uses.*
6. Are there any other sites you think are suitable for the Council to consider in preparing the Local Plan Part 2?
*Please give further details on the Call for Sites form available on the Council’s website*
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41fbbf4f58c56f85e8f6c695dfb4868f00b9d2ea | Appendix 1
HOUSES IN MULTIPLE OCCUPATION ARTICLE 4 DIRECTIONS FOR FAR COTTON, DELAPRE AND CLIFTONVILLE JUSTIFICATION REPORT (Planning and Private Sector Housing)
1 Introduction to the Use Class Order
In 2010, the Government changed the Town and Country Planning (Use Classes) Order 1987 (as amended)(UCO) and introduced a new Use Class C4 (Houses in Multiple Occupation). This use covers small shared dwelling houses or flats occupied by between 3 and 6 unrelated individuals who share basic amenities. Small bedsits are also classified as Houses in Multiple Occupation (HMOs).
A house in multiple occupation is a house or a flat shared by an unrelated group of 3 people or more. In a typical case, they have their own bedrooms but share the bathroom and/or kitchen or other communal facilities.
The Government made a further change to the General Permitted Development Order (GPDO) in October 2010. Under this new planning legislation, planning permission is not now required to change the use from a dwelling house (C3) to a HMO (C4). This is known as a national permitted development right. Planning permission is still required for change of use from a dwelling house to a HMO for 6 or more people. Planning permission is also always required for a new build residential property of any kind.
This flexibility and increasing demand, has led to an increase in the number of property owners converting their properties for HMOs for 3 – 6 unrelated people. The consequences of this were both positive and negative. HMOs offer affordable housing for those who cannot afford to buy a property, and also housing for those looking to rent because they are not ready to settle in the area. They also offer affordable rented units for students, particularly those studying at Universities. However, where there is a concentration of HMOs, there can also be some adverse consequences related to the physical and social environments which can affect the wellbeing of both occupants and adjoining residents. As a result, in 2011, Northampton Borough Council issued Article 4 Directions in areas such as Semilong and Sunnyside, which are close to the current University of Northampton campuses (Park and Avenue campuses) to assist in managing the concentrations of HMOs.
However, the University of Northampton is consolidating and subsequently moving its campuses to a site adjoining the Avon Cosmetics Headquarters site. This means that students will want to move to accommodation closer to this site. 2 Article 4 Direction
An Article 4 direction allows local planning authorities to remove the relevant permitted development rights, if it is considered that this will help a specific area. National Planning Practice Guidance (NPPG) states that the use of Article 4 directions should be limited to situations where this is necessary to protect local amenity or the wellbeing of the area. The potential harm that the direction is intended to address should be clearly identified.
Where there is evidenced local need to control the spread of HMOs, local planning authorities are able to use powers to make an Article 4 direction to remove these permitted development rights and therefore require planning applications for such changes of use. An Article 4 direction removing permitted development rights may be introduced if the Council considers that the change of use from C3 to C4 would be prejudicial to the proper planning of an area or constitute a threat to the amenities of the area.
The existing Article 4 Direction areas in Northampton are:
- North and Central
- Sunnyside
These areas are shown on the map at the end of this report.
However, there are various changes that are taking place in Northampton which will affect HMOs and their future locations. These include the relocation of the University of Northampton to the Avon Nunn Mills site. It was therefore considered that the potential growth of HMOs in the areas of Far Cotton, Delapre and Cliftonville be managed through an Article 4 Direction to ensure that their concentrations are managed in accordance with planning policy and that the wellbeing of both residents and occupants continue to be managed.
4 Far Cotton, Delapre and Cliftonville: Justifications for the Article 4 direction
a Government evidence base
The problems associated with high concentrations of HMOs are well documented and have been recognised nationally by residents, local organisations (such as resident associations), the press and the Government.
The Government commissioned ECOTEC to gather evidence about HMOs and the problems associated with high concentrations of HMOs. Although it was published some time ago, the issues are still considered relevant today.
The study was commissioned because concentrations of HMOs and the geographical concentrations of certain groups residing in them can lead to substantial changes and problems in the nature of particular locations. For instance, the social infrastructure of a neighbourhood can change. The report states that the problems associated with HMOs and the tensions within local neighbourhoods are well known, particularly in high concentrations of student housing and population, leading to the term “studentification”.
The report, completed in 2008, highlighted the following problems:
- Noise and anti-social behaviour
- Imbalanced and unsuitable communities
- Negative impacts on the physical environment
- Pressures upon parking provision
- Growth in private rented sector at the expense of owner occupation
- Increased crime
- Pressure upon local communities and
- Restructuring of retail, commercial services and recreational facilities to suit the lifestyle of the predominant population
More recently, in 2015, the Welsh Government examined the extent of concentrations of HMOs in Wales and the issues with them, reviewing the existing legislation and considering best practice in both Welsh and non-Welsh authorities. The report confirms that very high concentrations of HMOs exist around long term universities. Although it is less around newer universities (where higher levels of student accommodation are provided), nonetheless, the level of HMO concentrations was still high. The report adds that these concentrations have led to major concerns such as displacement of established communities, exclusion of first time buyers, anti-social behaviour, degrading of the environment and street scenes, and parking problems.
The report also revealed that there are variations in the extent of concentrations, but all had some very limited areas, adjacent to higher education institutions, where the proportion of HMOs could reach 80 – 90% higher. The report mentioned that authorities with high student populations reported that there had been a growth in student numbers during the 1990s but this had accelerated with very substantial growth in student numbers in 2000/1. This was regarded as a significant factor in the increased HMO concentrations because of the significant increase in the amount of accommodation provided by higher education authorities.
Therefore, one of the justifications for the proposal to introduce an Article 4 direction in any specific area is associated with the extent of HMO uses in that area and the local impact associated with concentrations of use. It is clear from both studies that HMOs themselves do not cause a problem. They perform a key role in providing suitable, affordable homes to those who need them including students, those on low income and young professionals. The issue arises where there is a high concentration of HMOs and particularly so when they are occupied predominantly by a social group.
There is evidence to show that properties are being used for HMOs in the Far Cotton, Delapre and Cliftonville areas with concentrations evident in some areas. This is because the University of Northampton is relocating to the Avon Nunn Mills area which is located along the south east of the Central Area. It is likely that student accommodation demand will increase. There is therefore a need to be proactive in managing the growth of HMOs prior to the opening of the new University in 2018. b. Development Plans and Interim Planning Policy Statement
i. West Northamptonshire Joint Core Strategy
Another reason for introducing an Article 4 Direction in the Far Cotton, Delapre and Cliftonville area is to ensure that the policies contained in the development plan and relevant supplementary documents are complied with.
The West Northamptonshire Joint Core Strategy was adopted in December 2014. Policy H5 states that the existing housing stock will be managed and safeguarded by allowing houses in multiple occupation where they would not adversely affect the character and amenity of existing residential areas. Para 9.23 adds that where there is a local need to control the spread of HMOs, the local authorities are able to use existing powers, in the form of Article 4 directions, to require planning applications in the area.
The strategic policy is therefore clear that there needs to be a balance between providing affordable units for rent through HMOs, whilst ensuring that they should not adversely affect the character and amenity of existing residential areas.
ii. Interim Planning Policy Statement on houses in multiple occupation
In November 2014, the Council approved the adoption of an Interim Planning Policy Statement (IPPS) on houses in multiple occupation. This IPPS has several planning principles which applicants need to take into account when considering a proposal to change the use of a dwellinghouse to a house in multiple occupation for 3 – 6 unrelated people. The adoption of this IPPS confirms the Council’s commitment towards managing the concentration of the HMO stock in a sustainable manner, which allows the provision to continue but not to the detriment of the character of the street. A threshold of 15% within a 50m radius will therefore assist in ensuring that the character of the streets within these areas will not be adversely affected by the concentration of HMOs in the future.
In extending the boundary of the Article 4 Direction, the Council will continue to secure a balance between securing enough HMOs to meet demand and ensuring that the amenity of the area and the wellbeing of residents are properly accounted for.
iii. Parking requirements
Both the Central Area Action Plan and the Northamptonshire Parking Standards provide parking standards for HMOs. In issuing an Article 4 Direction, and seeking planning applications for change of use from dwellinghouses to HMOs for 3 – 6 unrelated people, the Council is able to properly consider the parking requirements associated with each application and minimise the issues associated with parking matters. The Northampton Central Area Action Plan was adopted in January 2013. The Plan includes a policy on parking (Policy 10). For houses in multiple occupation, the standards are as follows:
| Car parking: | 1 space per bedroom | | Cycle parking: | 1 space per two bedrooms |
The Northamptonshire County Council’s Parking Standards were adopted in September 2016. In the document, it states:
If parking demand on-street exceeds capacity, then this leads to highway safety concerns such as parking on double yellow lines (which are there for safety reasons), parking across dropped kerbs, on the corners of junctions or double parking. In addition to highway safety concerns, when there is a lack of parking spaces available to residents, this negatively affects their amenity, which results in tensions within the communities.
HMO shall provide on plot parking at the ration of 1 parking space per bedroom.
Where less than 1 parking space per bedroom on plot parking is proposed for the HMO, the Highway Authority will require a parking beat survey of the surrounding streets. The methodology of the parking beat survey must be agreed with the Highway Authority before it is undertaken.
If the resulting residual parking demand (ie the difference between the parking expected to be generated by the existing dwelling (C3 use) and the proposed HMO) cannot be accommodated on the adjoining streets, then the Highway Authority shall object to the planning application.
NCC’s parking standards provide clear guidelines on the requirements to provide adequate parking for HMOs.
Therefore, anyone applying for planning approval for the change of use of their dwellinghouses to HMOs for 3 – 6 unrelated people within the Article 4 direction area will need to comply with these requirements unless there is justification not to do so, for instance, the proximity to public transport services. This will ensure that there is adequate provision for parking. This also helps with the management of HMO growth and associated requirements within the area.
The relocation of the University of Northampton into the town centre
In July 2011, Cabinet confirmed the immediate Article 4 direction which removed permitted development rights for change of use from C3 to C4 for an area bound by Holly Lodge Road to the north of the area, the Borough boundary to the east, Boughton Green Road to the south and Harborough Road to the west. In addition, Cabinet confirmed the non-immediate Article 4 direction which removed permitted development rights for change of use from C3 to C4 for the rest of the area comprising the central and northern parts of the Borough. These were areas affected by the Park and Avenue campuses, where HMOs were on the increase because of student demand.
However, in 2013, outline planning permission was granted to the University of Northampton for the redevelopment of the site off Nunn Mills Road, on the south eastern corner of the Central Area.
The scheme is for (extracts):
- 40,000 sq.m of university floorspace
- 15,000 sq.m of university expansion floorspace
- 35,000 sq.m of commercial B1 floorspace
- 3,550 sq.m of retail floorspace
- 1,500 sq.m of student accommodation
- 7,000 sq.m of hotel floorspace (around 150 bedrooms)
- Floodlit sports facilities
- A new road bridge and junction onto Bedford Road
- Reconfiguration of Midsummer Meadow car park
- New pedestrian footbridge connecting the site to Becket’s Park
The project is already underway with the new road bridge and junction on Bedford Road now under construction. This means that the Park and Avenue campuses will subsequently be closed down. Outline planning approval was granted for Park Campus (N/2014/0475) for the demolition of University facilities and the erection of new buildings comprising residential for up to 800 units and associated car parking and retail. Outline application for the demolition of existing university buildings, the demolition of existing university facilities and the erection of new buildings including 200 residential units at the Avenue Campus is in progress (N/2016/0810).
The University is expected to be completed in 2018, in time for the September intake. In 2014/15, there were just under 14,000¹ students studying in this University and this is expected to rise to around 15,000. The University is clear about its ambition in raising its profile and reputation, which may increase its attractiveness as a university of choice for both national and international students. It is also likely that students will want to move away from the areas close to the Park and Avenue campuses and move closer to the new, more modern university and be within walking distance to the town centre, its retail and leisure services, and especially its evening economy.
There is therefore potential for the demand for student and staff accommodation (and subsequently HMOs) within the vicinity of the new University campus. This demand could be met in established residential units within Delapre and Far Cotton and parts of the Cliftonville area which are within 10 – 30 minute walking distance to the new university site. Student demand for accommodation is expected to be the case in spite of the purpose built student accommodation in St John’s (464 rooms), the proposed accommodation on the new campus site (1,500 rooms) and the
¹ http://www.thecompleteuniversityguide.co.uk/northampton/ proposed 339 units at the former Greyfriars bus station site. This provides less than 3,000 purpose built units within the Central Area of Northampton. There might also be additional proposals coming through the pipeline within the Central Area but this is not confirmed at this stage. Therefore, there will be a shortfall in student accommodation and the likelihood is that this will be met through the provision of houses in multiple occupation.
**Evidence from Private Sector Housing**
Evidence base was obtained by Northampton Borough Council’s Private Sector Housing (PSH) section in a number of ways and through various sources. These include anecdotal evidence from local residents, councillors, police, fire authorities, local letting agents and local authority officers, as well as more formal responses.
Research undertaken by PSH Officers included:
- Physical street visits to ascertain identifiers indicating if a property is used as a house of multiple occupancy, such as multiple door bells, excessive rubbish or multiple refuse bins, multiple vehicles, local Intel from neighbours and door knocking on suspected properties.
- Police officers regularly attend properties for various reasons and have the opportunity to view properties internally. An agreement was made with local officers, that in the event of a callout, they would identify if the property is being used as a HMO and provide PSH with the address only.
- Council Tax & Housing Benefit data, which identifies registered HMO dwellings, under either student accommodation with tax exemptions mandatory and fully licenced properties.
- The Fire Authority as well as the police visit many properties, as part of their service. Therefore information pertaining to tenure of the properties can be used from the Fire Authority.
- Desk-based review of properties advertised online through sites specialising in single let rooms and house sharing, such as Spareroom.com, Easyroommate.com. These sites allow property owners or sub-letters, to let their spare or vacant rooms of their property.
- Universities and student unions have previously made commitments to working in partnership with local stakeholders to tackle the challenges arising from high concentrations of student population. PSH have undertaken this partnership approach in gaining information of students in houses of multiple occupations.
- Northampton Partnership Homes (NPH) has undertaken the management of the council’s housing stock as an Arm’s Length Management Organisation (ALMO). As a consequence NPH are in a suitable position to provide information on whether a property is being used as a HMO, particularly with estate inspections and anti-social behaviour cases. • Local lettings & Estate Agents, manage properties throughout the county. Therefore they are expected to manage HMO’s, as well as single household dwellings.
• Street refuse – Enterprise currently undertake the refuse collection for the county and will hold information to which household has ordered additional refuse bins, which is an identifier of a possible HMO.
• Environmental Health Officers
• Local Councillors are elected to the local council to represent their local community, being an effective councillor requires both commitment and hard work. Councillors have to balance the needs and interests of residents, the political party they represent (if any) and the council. As councillors operate surgeries, visit local people and businesses, with this exposure to the public, councillors will gain useful information. Local Councillors have been active in providing information for this area.
To ensure the integrity of the evidence gathered, PSH Officers must establish beyond reasonable doubt that the properties are operating as houses of multiple occupation. PSH Officers consider that as they are in the default position to provide the evidence and bear the burden of proof, there are strict qualifiers to meet the burden, such as:
• Police • Fire brigade • Local Authority Environmental Health • Local Authority Private Sector Housing • Housing Officers • ASB Officers • Council Tax & Housing benefit Data • Eye witness accounts from multiple source exclusively • Eye witness accounts from visiting officers including councillors
PSH Officers highlighted the following issues which may have arisen as part of their investigation:
• Incorrect eye witness accounts from single sources • Incorrect & misleading information from occupants
i. Information provided
| Authority/Agency | Information Provided | |----------------------------------------|----------------------| | Northants Police | Yes | | NPH Fire Officer | None | | Northants Fire Authority | No response | | NBC Private Sector Housing | Yes | | Name | Response | Comments | |-----------------------------|----------|---------------------------| | Ashby Lowery | No | | | Carter Jonas | No | | | Chelton Brown | yes | do not manage HMO's | | Connells | yes | do not manage HMO's | | Focal Point Estates | No | | | Galbraith estates | No | | | Haart | No | | | Harrison Murray | No | | | Horts | Yes | do not manage HMO's | | Howkins and Harrison | No | | | Ilet properties | No | | | Jackson Grundy | No | | | Jackson Stops | Yes | do not manage HMO's | | James Anthony Estate agents | No | | | JP Lettings | No | | | Key Home Ltd | No | | | Martin & Co | yes | do not manage HMO's | | Northwood | No | | | O’Riordain Bond | No | confirmed HMO | | Simpson & partnership | No | | | Whites Lettings | Yes | do not manage HMO's |
**Online:** PSH Officers registered with Spareroom.com and easyroommate.com and were able to confirm 4 HMO’s.
**Further Investigation:** There are a total of 35 Unconfirmed and/ or suspected HMO’s pending further investigation. The full information of the findings will be forwarded to the Environmental Health department for further action.
**ii. Public Sector Housing Conclusions**
PSH Officers confirmed the following findings:
| Total HMOs | 159 | |------------|-----| | Total Confirmed HMOs | 124 | Of which:
| Category | Count | |-----------------------------------------------|-------| | Approved Planning Applications | 2 | | Licenced (Mandatory) | 10 | | Council Tax Data | 8 | | Student Exemption | 38 | | Housing & Wellbeing (EH & KK) | 57 | | Councillors | 4 | | Online Advert (spare room) | 4 | | Local Lettings Agency | 1 |
**Evidence from Development Management and Council Tax**
Details of planning approvals and Council tax records were collected and updated records were mapped. Although there were only a few properties with permissions, (since an Article 4 is not in place), there are a few properties which have been recorded by Council tax as HMOs. Most of the recorded Council tax HMOs are located in the northern part of the Far Cotton area, namely those within the Victorian units close to the Far Cotton Local Centre.
**Character Overview**
i. **Far Cotton and Delapre**
Far Cotton and Delapre accommodates a Local Centre (Far Cotton) which provides retail and services (such as banking) to the local catchment area. The area also accommodates a library, a pharmacy, a Church, children’s nursery, primary schools, local neighbourhood level centres and a recreational space (comprising open spaces and children’s play areas). The ward is easily accessible from the new University site, either by walking/ cycling or by bus as it is well served by buses especially along Towester Road and Rothersthorpe Road. The whole area can be reached from the location of the new University of Northampton campus within 10 – 30 minutes, depending on whether it is to the north or to the south of the area.
Delapre and Briar Hill ward is located to the south of the town centre, with London Road seemingly splitting the residential areas of Far Cotton, Delapre and Briar Hill to the west; and leisure/ commercial leisure such the historic Delapre Park and Delapre Abbey as well as a hotel to the east. To the north of the Delapre Abbey site (and the old railway line) is an area which is occupied by Avon Cosmetics and an area which will be occupied by the University of Northampton.
The ward accommodates a mixture of predominantly Victorian terraced and post war semi-detached dwellings, which are deemed suitable for conversion into HMOs. These include:
- St Leonard’s Road: Victorian houses (also incorporates a Local Centre as designated in the West Northamptonshire Joint Core Strategy, adopted 2014)
- Euston Road/ Abbey Road: Victorian, 2 storey terrace
- Gloucester Avenue/ Queen Eleanor Road: post war 2 storey mainly semi detached ii. Cliftonville
Cliftonville is located within Rushmills ward, to the east of the town centre and Northampton General Hospital, and is characterised mainly by 1960s – 1970s semi-detached and detached properties. The area also has some offices and a primary school. There are regular buses along Billing Road and the area is within 5 – 10 minutes walk to the new University campus and the town centre. This makes the area quite attractive to students who would like easy and immediate access to the town centre and the social life it offers, including the evening economy.
The physical environment of these areas included in the proposed Article 4 Directions could potentially change, and not necessarily improve, if the growth of HMOs continue without effective management of their concentrations. An Article 4 Direction will contribute towards ensuring that their growth is balanced against the need to provide HMOs and the need to protect the area, the occupants and the local residents.
6 Managing the concentration of HMOs
The Council is intending to introduce an Article 4 direction in areas within Far Cotton, Delapre and Cliftonville. This means that those who wish to convert their dwellings into HMOs for 3 – 6 unrelated people will need to apply for planning permission before doing so.
To manage both the demand and concentration of HMOs, it is considered appropriate to issue an Article 4 direction on the areas that are likely to be affected, meaning that a planning application will need to be submitted. This does not mean that planning permission will be refused. It means that the Council is able to ensure that demand is met but at the same time make sure that this is balanced against the wider needs of the existing communities. Once an Article 4 direction is in place, planning applications submitted will be determined in accordance with the development plan (which is the West Northamptonshire Joint Core Strategy) as well as the Interim Planning Policy Statement on Houses in Multiple Occupation which was adopted in 2014, and any subsequent update to the documents. The Council is also preparing a new Local Plan for Northampton Borough, and a decision will be made in due course as to whether a policy on houses in multiple occupation will be included in the Plan.
The existing evidence shows that there is a greater concentration of HMOs along the northern end of Far Cotton/ Delapre whilst the remaining areas have pockets of HMOs. The maps attached to the Cabinet report show the extent of the identified HMOs to date, which subsequently informed the proposed boundary for the Article 4 Direction area. Details of the HMOs were obtained from the following sources:
- Planning approvals from Development Management
- Council tax records showing where students were exempt
- Council tax records which codes where properties are HMOs
- Officer on-site investigations undertaken by Private Sector Housing
- Information from residents as to where they think the HMOs are located, which were investigated by Private Sector Housing Officers • Planning approvals from Development Management • Mandatory Licensing from Private Sector Housing • Information from the Policy following meetings with Private Sector Housing
The maps shows that there are a small number of Mandatory Licensed HMOs and HMOs with planning approvals including West Cotton Close, Euston Road and Rothersthorpe Road. There are also properties along London Road, the streets between Delapre Crescent and St Leonard’s Road, streets south of Delapre Crescent Road, Rothersthorpe Crescent, Thirlestane Crescent and Abbey Road which recorded by Council Tax as HMOs and/ or have student exemption records. There are also 121 confirmed HMOs recorded following site visits and interviews with residents.
Since the findings show that there is a higher concentration of HMOs within the properties located north of Rothersthorpe Road and Forest Road, it is proposed that 2 article 4 directions are imposed. An immediate Article 4 direction (which takes immediate effect) is recommended for the area hatched on the plan attached and a non-immediate Article 4 direction (which could take at least 12 months to take effect) is recommended for the remaining area within the proposed boundary. The benefits of issuing both Directions are:
• Currently, planning approval is not required for the change of use from dwellinghouses to HMOs. An Article 4 Direction will change this. It does not mean an application will be refused. It means that an application will be determined in accordance with policy guidance and amenity space standards. For the area with an immediate Direction, the Council is able to manage the growth of HMOs with immediate effect
• Concentrations of HMOs can be managed, (particularly where an immediate Article 4 Direction is made) in an area which will have increasing pressure for HMOs particularly once the new University of Northampton has moved. Character of the streets can be protected. Well-being of residents and adjoining occupiers will be considered as part of the planning application process
There are 107 streets included in the proposed Article 4 Direction areas, with a total of 4114 properties:
The streets within the proposed immediate Article 4 Direction are:
| No | Street | Number of properties | |----|-------------------------|----------------------| | 1. | Abbey Road | 115 | | 2. | Baulmsholme Close | 13 | | 3. | Claughton Road | 19 | | 4. | Clinton Road | 57 | | 5. | Cotton End | 12 | | 6. | Delapre Crescent | 7 | | 7. | Delapre Crescent Road | 94 | | 8. | Delapre Street | 44 | | 9. | Eastfield Road | 28 | | | Street Name | Number | |---|------------------------------|--------| | 10.| Euston Road | 152 | | 11.| Forest Road | 27 | | 12.| Haines Road | 6 | | 13.| London Road | 52 | | 14.| Marvills Mill Road | 12 | | 15.| Old Towester Road | 49 | | 16.| Oxford Street | 32 | | 17.| Penrhyn Road | 143 | | 18.| Playdell Road | 13 | | 19.| Pomfret Arms Close | 10 | | 20.| Ransome Road | 36 | | 21.| River View | 89 | | 22.| Rothersthorpe Road | 80 | | 23.| Southfield Avenue | 36 | | 24.| St Leonards Court | 41 | | 25.| St Leonards Road | 204 | | 26.| Thirlestane Crescent | 38 | | 27.| Thirlestane Road | 56 | | 28.| Thorpe Road | 17 | | 29.| Towcester Road | 58 | | 30.| West Cotton Close | 167 | | | | 1884 |
The streets within the proposed non-immediate Article 4 Direction are:
| | Street Name | Number | |---|------------------------------|--------| | 31.| Berkeley Close | 43 | | 32.| Blenheim Road | 66 | | 33.| Briar Hill Road | 45 | | 34.| Briar Hill Walk | 36 | | 35.| Buchanan Close | 24 | | 36.| Camborne Close | 92 | | 37.| Chelmsford Close | 15 | | 38.| Cleveland Place | 16 | | 39.| Cliftonville Court | 58 | | 40.| Cliftonville Road | 19 | | 41.| Coverack Close | 66 | | 42.| Delamere Road | 45 | | 43.| Fawsley Road | 18 | | 44.| Forest Road | 19 | | 45.| Friars Avenue | 107 | | 46.| Friars Close | 14 | | 47.| Friars Court | 24 | | 48.| Friars Crescent | 66 | | 49.| George Nutt Court | 34 | | 50.| Glastonbury Road | 5 | | 51.| Gloucester Avenue | 132 | | 52.| Gloucester Close | 16 | | 53.| Gloucester Crescent | 78 | | | Street Name | Number | |---|------------------------------|--------| | 54. | Hereward Road | 10 | | 55. | Lauderdale Avenue | 41 | | 56. | Leah Bank | 60 | | 57. | London Road | 127 | | 58. | Parkfield Avenue | 108 | | 59. | Parkfield Crescent | 16 | | 60. | Pilgrim’s Place | 16 | | 61. | Pleydell Gardens | 84 | | 62. | Pleydell Road | 40 | | 63. | Queen Eleanor Road | 86 | | 64. | Queen Eleanor Terrace | 34 | | 65. | Radleigh Close | 18 | | 66. | Redruth Close | 62 | | 67. | Ripon Close | 16 | | 68. | Rockingham Road | 24 | | 69. | Rothersthorpe Lane | 4 | | 70. | Rothersthorpe Road | 30 | | 71. | Salcey Street | 36 | | 72. | Stevenson Street | 28 | | 73. | The Avenue | 102 | | 74. | The Nurseries | 45 | | 75. | Towcester Road | 90 | | 76. | Winchester Close | 14 | | 77. | Winchester Road | 101 |
8 Background documents
- Northamptonshire Parking Standards (Northamptonshire County Council, September 2016)
- Schedule 3 of the Town and Country Planning (General Permitted Development) (England) Order 2015
- Houses in multiple occupation: review and evidence gathering (Welsh Government, April 2015)
- West Northamptonshire Joint Core Strategy (West Northamptonshire Joint Planning Unit, Dec 2014)
- Interim Planning Policy Statement on Houses in Multiple Occupation (Northampton Borough Council, Nov 2014)
- National Planning Practice Guidance (CLG, March 2014)
- The Town and Country Planning (Compensation) (No 3) (England) Regulations 2010
- Evidence Gathering – Houses in Multiple Occupation and possible planning responses (ECOTEC 2008)
- Town and Country Planning (General Permitted Development) Order 1995 (as amended)
- Town and Country Planning (Use Classes) Order 1987 (as amended) Boundary of existing Article 4 Direction
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0dcd6e851b14ff05127b90b565b2393214086d1d | Northampton Borough Council Capital Strategy 2016-21 Northampton Borough Council
Capital Strategy 2016 to 2021
Contents
1 Introduction and Context 2 Overarching Strategy 3 Sources of Capital Finance 4 Capital Funding Strategy 5 Programme Build 6 Governance Arrangements 7 Capital Monitoring 8 Risk Management 9 Asset Management
1 INTRODUCTION AND CONTEXT
Capital expenditure represents major investment in new and improved assets such as land, buildings, infrastructure, equipment and information technology. It therefore plays a key part in the provision and development of the Council’s services.
The aim of the capital strategy is to provide a clear framework for capital funding and expenditure decisions. This is in the context of the Council's vision, values, objectives and priorities, financial resources, and spending plans. The Capital Programme is designed to support the delivery of the Council’s priorities as set out in the Corporate Plan.
The strategy supports the development of an approved capital programme that shows the Council’s commitment to maintaining and improving its capital stock and infrastructure. This in turn underpins the delivery of high quality and value for money services and helps to secure a better environment for the people of Northampton.
2 OVERARCHING STRATEGY
The Council’s capital strategy is to deliver a capital programme that:
- Contributes to the Corporate Plan, and the Council’s vision, values, strategic objectives and priorities
- Is closely aligned with the Council’s Asset Management Plan
- Supports service-specific and other NBC plans and strategies • Is affordable, financially prudent and sustainable, and contributes to achieving value for money
In prioritising the Capital Programme, particular emphasis will be given to schemes that:
• Achieve the Council’s priorities • Improve the town and its environment and facilities • Improve performance against national and local targets • Improve efficiency and effectiveness in service delivery, including through partnership working • Generate or increase income streams • Promote effective Asset Management, including DDA and Health & Safety issues
3 SOURCES OF CAPITAL FINANCE
Overview Decisions on capital investment are made against the background of constrained resources, and the Council is heavily dependent upon capital receipts and grants from central government to support its capital programme. Other available funding sources include prudential borrowing, third party contributions, and revenue contributions. These are all actively pursued to support capital investment.
Capital Receipts Capital receipts are derived from both General Fund (GF) and Housing Revenue Account (HRA) asset sales. These could include income to the Council as lessor from finance leases.
NBC do not always receive the full value of these asset sales as some of them are subject to “clawback” arrangements whereby a proportion of the capital receipt must be paid over to the Homes and Communities Agency (HCA).
GF asset sales come from a variety of sources. Generally speaking, 100% of GF asset sales (after any ‘clawback’) can be used to support capital expenditure. Sometimes the asset sale is linked directly to a capital project, for example in a relocation scheme. More often, GF asset sales relate to surplus assets that are held corporately and are not specific to a scheme. Property assets for disposal are subject to the approval of the Capital Assets Board.
The Council generated a substantial capital receipt in 2014/15 from the sale of the Sekhemka statue. This will be used exclusively to fund the redevelopment of the Central Museum.
HRA asset sales come from the sale of council houses under ‘right to buy’ legislation, and from the sale of shared ownership properties. ‘Right to buy’ receipts are subject to pooling arrangements. Since April 2012 this means that a proportion is paid over to central government for redistribution, a proportion is retained by the Council to fund the HRA capital programme and the remainder is retained for the funding of one-for-one replacement properties through new-build or purchase. The latter may be in partnership with other registered providers.
**Prudential Borrowing**
Under the Local Government Act 2003 councils operate within the rules contained in the ‘Prudential Code’. These allow local authorities to set their own limits with regard to borrowing undertaken to support capital expenditure. Borrowing may be undertaken, provided that it is, and can be shown to be, prudent, affordable and sustainable. This method of financing capital expenditure is called “prudential borrowing”.
In order for borrowing to be prudent, affordable and sustainable, there must be an identifiable, long-term source of revenue funding for the associated revenue (debt financing) costs. Ideally this will come from revenue savings or additional income arising directly from the capital scheme. For example, refurbishment of a building may generate maintenance and/or energy savings, or the building of a car park could generate income through charges. The cost of this “self-funded” borrowing should be borne by the service that uses the asset.
Where there is no additional income or cost saving, i.e. the capital scheme is to meet corporate priorities and support the growth and improvement of the Borough, then the cost of borrowing will be recognised as a cost to the General Fund.
In some circumstances the Council will provide loans to other organisations, such as to the University of Northampton to part-fund the new campus development. This is treated as capital expenditure and funded through borrowing.
**Minimum Revenue Provision (MRP)**
The Council is required to make provision for the principal repayment of borrowing. Prior to 2007-08 the Council was required by statute to provide for the repayment of a minimum amount of 4% of General Fund debt principal each year. This debt repayment is known as the Minimum Revenue Provision (MRP).
The Local Authorities (Capital Finance & Accounting) (England) (Amendment) Regulations 2008, which came into force in February 2008, require the Council to make instead ‘prudent provision’ for the repayment of debt. A number of options for prudent provision are set out in the regulations. The underlying principle is that the repayment of debt should be aligned to the useful life of the asset or assets to which it relates.
The authority is required, under the new regulations, to prepare an annual statement of their policy on making MRP for submission to Council. The Council’s policy statement on MRP is set out in the annual Treasury Strategy, which is agreed by Council during Feb/March each year.
The Housing Revenue Account is currently not subject to an MRP charge.
**Business Rates Uplift**
Capital improvements within the Enterprise Zone may be funded by borrowing which will eventually be repaid through the increase in business rate income flowing from new or expanded businesses. The borrowing is undertaken via the South East Midlands Local Enterprise Partnership (SEMLEP) through the Growing Places Fund or Local Infrastructure Fund. This is to manage the timing difference between the investment in the Enterprise Zone and the consequent increase in business rates.
Where necessary the gap will be managed by NBC undertaking borrowing from the Public Works Loan Board (PWLB).
**Government Grants**
The conditions attached to government grants vary according to the particular grant. Some will fund the full cost of the scheme, others just a percentage, with the local authority having to fund the balance. Most, but not all, grants are time-limited. Government grants tend to be focussed towards central government priorities.
**Third Party Contributions**
As with government grants the conditions attached to third party contributions vary. This category of funding is becoming of increasing importance to the Council in a climate of stretched local government resources. Included here are:
- Planning obligations funding from Section 106 agreements (developer contributions)
- National Lottery grants
- Contributions from local bodies.
- Contributions from national bodies.
**Revenue and Capital Reserves**
The Council has, as part of its overall financial strategy, set aside reserves in order to provide additional capital funding. These include an element of the New Homes Bonus and the Strategic Investment Reserve, used to fund the purchase of properties that may in the future provide a good return on investment.
**Revenue Contributions**
In the past revenue contributions have been a fairly minor source of capital financing for the Council due to pressures on the revenue budget. They are, however, sometimes used to top up small shortfalls in the funding required for a particular scheme.
HRA revenue contributions form a significant element of the funding of the HRA capital programme. Since April 2012 the HRA is self-financing and capital improvements to the stock are funded largely from the Major Repairs Reserve and direct revenue contributions.
**Leasing (Council as Lessee)**
Leases are classified in accounting terms as either finance or operating leases. This distinction is important because it dictates whether the lease must be classified as capital (finance leases) or revenue (operating leases), and different accounting treatment is required for each.
The LGSS Treasury Team are responsible for advising on and arranging all leases for the Council in conjunction with the Procurement Team. They ensure that the leases comply with all the relevant accounting conditions and requirements. All lease arrangements entered into on behalf of the Council are authorised and signed by the Council’s Section 151 Officer.
In order to demonstrate and achieve value for money, the Council’s leasing advisors carry out a full evaluation of any lease proposals on behalf of the Council. This involves an analysis of the quality of the proposed lease and a comparison of the whole life costs of, for example, an operating lease, a finance lease or capital purchase funded by prudential borrowing.
It is generally more cost effective to arrange operating leases through sale and leaseback arrangements with a third party rather than through a direct lease from the supplier. Items financed through an operating lease are coded to and financed as part of the Council’s revenue budget. It is the responsibility of the budget holder to ensure that there is sufficient capacity in the revenue budget to fund the annual operating lease costs.
The Council’s preference is not to enter into finance leases unless there are exceptional reasons for doing so. Where an operating lease is either not available or not suitable, a capital purchase funded by prudential borrowing generally offers greater benefits than a finance lease. The introduction of IFRS from April 2010 reduced the number of instances where operating leases can be used to finance expenditure, particularly in the case of short life assets such as IT hardware, equipment and vehicles. Where this applies it is likely that such items will be purchased through the capital programme and financed by prudential borrowing, with the revenue cost of the borrowing met from the existing service budget.
4 CAPITAL FUNDING STRATEGY
General Fund Capital
Under the Council’s capital funding strategy, funding streams are allocated in the following order. Cabinet may make changes to the funding strategy where necessary to deliver capital schemes that are key to delivering the Council’s agreed priorities:
- Hypothecated funding – i.e. funding linked directly to a specific scheme, such as grants, third party contributions and revenue contributions – is allocated 100% to the relevant scheme. Schemes funded by external grants and contributions will not commence until such funding is definitely secured.
- General capital grants – these are not currently available, but if they become a source of funding in the future they will be fully utilised ahead of other funding sources.
- Self-funded borrowing - where the capital investment itself will produce revenue savings or additional income, which is sufficient to cover the cost of borrowing to fund the investment.
- General Fund capital receipts are not allocated or committed prior to receipt or certainty that they will be received, unless inextricably linked to a specific project. General fund capital receipts received during the year will be taken into account as a potential funding source for new schemes or variations in the relevant financial year or the following financial year, subject to revenue budget considerations e.g. debt financing budget implications. • Prudential Borrowing will be used to fund capital investment if the cost of the borrowing is affordable within the overall General Fund revenue projections. This will be funding source of last resort.
In Year Changes
Underspends on GF schemes may not be automatically diverted to other schemes. This will be considered against the demands of the programme as a whole. The only call on capital receipts during the year would be for unforeseen high priority emergency capital works that cannot be financed from alternative sources. Agreement will be through the normal channels – that is the submission of a project appraisal or variation to Capital Programme Board and, if required, Cabinet.
The funding strategy is used to determine the allocation of funding to the programme at the start of the year and throughout the year. Depending on the timing and restrictions of the funding streams, the most appropriate funding will be used at the year end. The Capital Team, under the direction of the Chief Finance Officer, will apply the available funding to the outturn expenditure in line with the best interests of the Council.
HRA Capital Funding
The balance of funding of capital investment in the Council’s housing stock and associated assets is determined through the HRA business plan. This provides a 30-year forecast of the management, maintenance and capital investment needs and resources available.
• Usable capital receipts from the sale of council housing stock under right to buy, as well as sale of other HRA assets, are directed at the HRA capital programme in order to meet and maintain the Northampton Standard.
• Major Repairs Reserve - In line with the statutory requirement, the Major Repairs Reserve is entirely earmarked for HRA capital expenditure on the Council’s housing stock.
• Revenue – under the self-financing regime the HRA is forecast to have an amount of revenue available each year to part-fund the capital programme.
• Borrowing – there is some limited scope for prudential borrowing within the HRA, although this is subject to a cap as determined by central government.
Revenue Implications of Capital Projects
The revenue implications of capital projects are identified through medium term planning and the capital appraisal process, and fed into the Council’s medium term revenue budget to ensure that all revenue implications are taken into account.
Through the Asset Management Plan and the HRA Business Plan an appropriate balance of funding is determined between capital investment and repairs and maintenance. This is kept under regular review. 5 PROGRAMME BUILD
The Council agrees its capital programme on an annual basis in February immediately preceding the start of each financial year. The agreed programme consists of:
- A firm and fully funded programme for the following year. This includes continuations from previous years as well as new starts in year
- Continuation schemes and forecasts for the subsequent 4 years
Within the available funding envelope, projects are prioritised for inclusion in the capital programme based on the extent to which they contribute to the achievement of corporate priorities. Bids for inclusion are supported by capital appraisals – these must demonstrate that the project provides an effective and value for money solution, and that all possible sources of external funding have been sought.
In addition to specific capital schemes the programme includes a number of “Block Programmes”. Specific projects within these blocks are agreed during the year by Capital Programme Board following the receipt of capital appraisals.
A draft capital programme is prepared for Cabinet in December and is then subject to public consultation alongside revenue budgets. Final decisions are made by Full Council in February.
6 GOVERNANCE ARRANGEMENTS
In Year Appraisals and Variations
All new in-year capital schemes must be supported by a capital appraisal and any changes to existing schemes will require completion of a variation form. The funding for the project must be identified at this stage. Where there is no additional funding to support the bid, resources must be identified from within the existing programme.
Project Managers should consult the Capital Team in Finance to ensure forms are completed correctly and expenditure meets the definition of capital. Finance will also need to check that any VAT or other tax implications are properly taken into account.
Delegation Levels for Appraisals and Variations
Fully Funded Schemes
Capital schemes of any value can be approved by the Chief Finance Officer (CFO) if they are fully funded by section 106, external grants or other contributions, or fully funded by additional income or revenue savings. This delegated approval is subject to consultation with Cabinet Members if more than £100k.
Other Schemes
These limits apply to both General Fund and HRA schemes.
Below £100k – Approval by CFO £100k to £250k – Approval by CFO, after consultation with the Cabinet Member for Finance and relevant Cabinet Member(s)
Over £250k – Approval by Cabinet Required
All appraisals and variations approved under delegation will be reported to Cabinet via the Finance and Performance report.
In signing the appraisal form the relevant Director is confirming that the Cabinet Member (Portfolio holder) has been consulted.
**Role of the Capital Programme Board (CPB)**
Appraisals and Variations will require approval by the Capital Programme Board before final approval by Cabinet (or the CFO if under delegation). The project manager and/or Head of Service will be invited to attend CPB if required to explain the scheme.
The CPB will meet monthly, therefore project managers need to ensure that appraisals and variations are produced in a timely manner.
**Block Programmes**
The Capital Programme for 2014/15 onwards includes block programmes for Improvements to Regeneration areas, Parks/Allotments, Operational Buildings and Commercial Landlord responsibilities.
CPB will approve individual schemes within these blocks following the submission of a capital appraisal by the relevant project manager.
**Urgent Approvals**
Due to their long-term nature, capital investment decisions should be carefully considered. The Capital Team in Finance should be consulted as soon as a scheme is under consideration and a capital appraisal form completed. In the vast majority of cases this will allow CPB to consider and approve the scheme within its monthly cycle.
In the rare circumstance where urgent approval is required, this can be secured via e-mail from Steve Boyes as Chair of CPB. The capital appraisal form will still require signatures including the CFO. If the scheme is more than £250k then Cabinet approval will still be required unless an absolute emergency. 7 MONITORING THE CAPITAL PROGRAMME
Project management & monitoring
Project managers are responsible for the proper and effective control and monitoring of their projects, including financial monitoring.
This includes ensuring that:
- Only capital expenditure is charged to the capital project
- Only expenditure properly attributable to the scheme is coded to the scheme
- The scheme expenditure is contained within the agreed budget, and that any ‘unavoidable’ variations are dealt with appropriately
- Realistic expenditure profiles are determined
- A realistic forecast outturn for the financial year and the project as a whole are calculated and kept under regular review. Changes must be input into Agresso Planner on a monthly basis, along with clear explanations for any variation.
- Any proposed carry forward from current to future years is identified and input to Agresso Planner.
- Any grants or third party funding is applied for and all grant conditions met
- The source of any revenue funding is identified
Project managers are also responsible for carrying out project reviews following scheme completion. This is an area of work that the Council is developing, The Finance Team request information on completed projects as part of their ongoing monitoring role.
Directorate Management Teams
Each Directorate Management Team is responsible for ensuring they receive & review reports on the capital expenditure position for their directorate and that any appropriate corrective action needed to address any monitoring issues is agreed and implemented.
LGSS Finance
Nominated accountants within the Finance Team are responsible for providing support and advice to assist project managers in managing and monitoring their capital budgets. The team also has a key role in consolidating and co-ordinating the monitoring information that is required for reporting purposes. This involves reporting to Directorate Management Teams, Capital Programme Board, Management Board and Cabinet. The Capital team is responsible for ensuring that the agreed programme is fully and appropriately financed at all times.
Capital Programme Monitoring
The capital programme position is reported to Capital Programme Board and Management Board on a monthly basis throughout the year, commencing from period 2 (end of May). Quarterly reporting to Cabinet forms part of the overall Finance and Performance report and covers the latest programme and any amendments to be notified or approved, expenditure to date, and the forecast outturn. It also outlines the financing position and any steps needed to deal with potential financing difficulties.
At year-end, an outturn report and carry-forward report are taken to Cabinet. These will include an analysis of proposed carry forward to the following year, including the reasons for that carry forward and how it is to be financed.
8 RISK MANAGEMENT
Any significant risks associated with specific projects are identified in the capital appraisal form. General risks in relation to the overall capital programme are managed through the Capital Programme Board:
| Risk | Mitigation | |-----------------------------|-----------------------------------------------------------------------------| | Project Overspend | Project managers update financial forecasts on a monthly basis. Any forecast overspend must be dealt with immediately – identifying savings elsewhere within the programme or alternative sources of funding. | | Project Slippage | Any forecast carry forwards are also identified on a monthly basis. The impact of these carry forwards on the associated funding is reflected in the overall monitoring reported to Capital Programme Board. | | Capital receipts – delay or non-receipt | As part of the funding capital receipts are not allocated or committed prior to receipt or certainty that they will be received |
9 ASSET MANAGEMENT
Council Assets
The Council owned Property, plant and equipment assets with a total net book value of £509m at March 2015. Council assets included around 11,900 Council dwellings, and 925 hectares of Parks and Open Spaces.
The Council also owns a large number of commercial properties and agricultural land used to generate income. These “investment properties” are kept under review to ensure that they continue to generate a good return – if not they will be considered for disposal. The Council will also seek opportunities to invest in additional property assets.
The Corporate Assets Board will identify any property assets that are surplus, i.e. no longer required for the delivery of Council services, and make recommendations to Cabinet for disposals in order to generate capital receipts.
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d97a0fbccc67fa17751450714cc8ff08c2610366 | Appendix 2: Barnet Council Workforce Equalities Data
Data Sources Staff data LBB Human Resources HR Core April 2019 Barnet Citizen Data Census 2011 (and updated by the GLA’s 2015 Round Population Projections (Borough Preferred))
The following tables summarise the data updated in May 2019 on the make-up of Barnet staff in relation to the protected characteristics. This is broken down by Directorate where possible, and placed alongside comparative data for the borough of Barnet overall – taken as percentage of working age population (16-64 years old). It compares the percentage of each group represented in the Council with the information we hold about the make-up of Barnet residents from the Census 2011 (and updated by the GLA’s 2015 Round Population Projections (Borough Preferred)). The findings, and a comparison of the data are presented below.
1. Gender make up of staff Table One shows that women are the majority of Council staff at 58.89% in comparison with 51.20% in the Barnet Population. There has been a very slight decrease in the number of males from 41.67% in 2018, to 40.19% in 2019. The most significant change can be seen in Street Scene, where the number of women employed has increased from 22.22% in 2018, to 24.27% in 2019; a percentage increase of 10.84%.
Table One: Gender make up of staff
| Directorate | Female | Male | Unknown | |------------------------------|--------|-------|---------| | Adults & Communities | 76.00% | 22.00%| 2.00% | | Assurance | 52.54% | 47.46%| 0.00% | | Education & Skills | 57.14% | 42.86%| 0.00% | | Environment | 30.00% | 70.00%| 0.00% | | Family Services | 79.41% | 19.34%| 1.25% | | Finance | 51.02% | 48.98%| 0.00% | | Growth & Corporate Services | 55.13% | 43.59%| 1.28% | | Street Scene | 24.27% | 75.73%| 0.00% | | Total Council | 58.89% | 40.19%| 0.93% | | Schools | 92.70% | 7.30% | 0.00% | | Barnet Population | 51.20% | 48.80%| 0.00% | 2. Gender Pay Gap
As reported in March 2018, women employed by Barnet Council earn £1.29 for every £1 that men earn when comparing median hourly wages. Their median hourly wage is 28.7% higher than men’s.
Women occupy 71.4% of the highest paid jobs and 35.3% of the lowest paid jobs in the organisation.
3. Ethnicity of staff
Table Two shows in alphabetical order the ethnic groups employed in Barnet, compared with their overall representation in the Barnet population. There are fewer white employees in comparison with their overall representation in the borough (51.59% compared to 64.10%). This is also true for Chinese (0.46%), Indian (5.91%), Pakistani (0.87%), and Other Asian (1.10%). However, further analyses is needed to describe ethnicity distribution by pay grades.
Table Two: Ethnicity of staff
| Ethnic Group | % in Council employment | % in Barnet Population | |----------------|-------------------------|------------------------| | Bangladeshi | 1.33% | 0.6% | | Black African | 7.87% | 5.4% | | Black Caribbean| 8.80% | 1.3% | | Black Other | 1.56% | 2.7% | | Chinese | 0.46% | 2.3% | | Indian | 5.91% | 7.8% | | Other Asian | 1.10% | 7.9% | | Other | 4.01% | 6.3% | | Pakistani | 0.87% | 1.5% | | Prefer not to say | 16.50% | 2.1% | 4. Sexual orientation of staff
The lack of reliable data on sexual orientation of the UK population makes it difficult to make meaningful comparisons with staff data. Almost third (28.95%) of Barnet staff preferred not to disclose their sexual orientation, a significantly higher proportion than the London average figure of 8.4%. Due to the fact that this large minority have chosen not to disclose their sexual orientation, there are very few conclusions that can be drawn.
Table Three: Sexual orientation of Staff
| Grouping | Heterosexual | Bisexual | Gay | Lesbian | Prefer not to say | |----------------|--------------|----------|------|---------|------------------| | London Average | 89.0% | 0.7% | 1.9% | 1.9% | 8.4% | | Total Council | 68.7% | 0.75% | 0.93%| 0.93% | 28.95% | 5. Age of staff
Average age of our workforce in 2018 was 46. This is higher than UK average age of 39 that is predicted to raise to 43 by 2030. Table Four below shows there are fewer staff aged 29 and below than in comparison with their overall representation in the borough. Staff aged 50-64 make up 39.26% of employees, compared with just 20.55% of the Barnet population. Also, there are significantly fewer staff aged over 65 compared to the resident population as a whole, so this is to be expected.
Table Four Age of staff 6. Staff with disabilities
Table Five below suggests that the disability profile of Barnet employees is less than the representation of People with Disabilities living in Barnet. However, this difference is small, and does represent an improvement on last year's figure of 4.8% of staff.
Table Five: Staff with Disabilities
| Delivery Unit | Percentage Declared Disability | |---------------------------------------------------|-------------------------------| | Barnet Population % People whose Day-to-day activities are limited a lot | 6.0% | | Total Council Staff | 5.27% | 7. Religion/Belief of staff
Table Six below shows that there are significantly fewer Jewish, and Muslim employees than in comparison with their overall representation in the borough. However, there are more staff with no religion than in the wider population.
Table Six: Religion/Belief of Staff
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ff5190a204c99bbfd2d53286cc0e6bdfe3f333f5 | Supporting Innovators, Entrepreneurs and Social Enterprise
Northampton will support entrepreneurs, innovators and social enterprises and will develop programmes and projects that ensure that our economy offers the conditions for businesses to thrive.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will support local businesses by signposting business to SEMLEP’s Growth Hub and other partners such as the Northamptonshire Chamber of Commerce. | We will signpost 100 businesses to the Growth Hub for support. | We will signpost 200 businesses to the Growth Hub for support | Over 500 Northampton businesses will have received growth advice. | NBC EG&R team | | 2. | We will support spaces and initiatives that incubate small creative businesses | The Vulcan Works will be open in 2020. | The Vulcan Works will be 60% occupied. With 25 businesses located in the Hub providing 35 jobs. | The Hub will be recognised as a regional centre for Creative businesses and will be 75% occupied. With 45 businesses operating from the Hub providing 90 jobs. | NBC EG&R team and Vulcan Operator Growth Hub | | 3. | We will review the amount of commercial workspace there is within the Borough and identify where we have shortage of good quality facilities | We will conduct a review of the current property market and identify where Northampton lacks commercial space and where there is currently unmet demand from businesses. | We will use the review to identify priorities and where appropriate develop business cases and funding applications which will assist in meeting business demands. | We will have received financial support and delivered the first new workspace premises to meet the local economic demands. | NBC EG&R | | 4. | We will work with the University of Northampton and other key partners to | We will develop a Social Enterprise Strategy with our partners | We will have delivered priorities set out within the Strategy and be | We will review the Social Enterprise Strategy and assess the impact our work | NBC EG&R, UoN | | develop a Social Enterprise Strategy to underpin further growth for the sector | working closely with the Social Enterprise Sector. | has had on the sector. | Creating a 21st Century Town Centre
Northampton Town Centre faces a number of challenges resulting from national retail trends. Tackling these challenges is an important priority for the Borough Council. Working closely with partners such as Northampton Town Centre BID and the private sector we will address these challenges.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will transform the heart of the town by regenerating the current Market Square into a high-quality space that reflects the ambition and pride within the town. | We will have come up with a final design for the Market Square and we will be implementing the Town Centre Masterplan. | The Market Square will be a high-quality and flexible space. We will have made significant progress with delivering the Masterplan. | We will have delivered a number of improvements to the Town Centre. | NBC EG&R team | | 2. | Our approach will be proactive and will support the ethos of the Town Centre Masterplan and Enterprise Zone by seeking to bring high quality investments in retail, culture and housing to a number of sites, including: Four Waterside Horizon House Greyfriars Freeschool Street Railway Station Phase 2 Vulcan Works | We will have acquired key sites and premises to begin implementation of the Masterplan. | We will have attracted funding from both the public and private sector to deliver our key projects. | We will have begun to increase the amount of housing available within the Town Centre and built on the profile of the Cultural Quarter. | NBC EG&R team | | 3. | We will actively | We will continue to | We will be | We will have begun | NBC EG&R |
| | encourage and re-purpose vacant retail units and the space above retail into new residential, office and leisure opportunities. | progress key sites including: Market Square Four Waterside Horizon House Grey Friars | progressing the build of Four Waterside and Horizon House. While other key schemes such as Greyfriars will be progressing through planning and securing funds to support implementation. | the development of Four Waterside, Greyfriars, Horizon House and Railway Station Phase 2. | |---|---|---|---|---| | 4. | Working alongside SEMLEP we will continue to focus on delivering the Waterside Enterprise Zone. Place marketing Move from 21st Century TC into raising Nptons profile | We will continue to deliver the Enterprise Zone, repositioning the Zone through a new marketing campaign and website. We will then bring forward new sites that can attract new occupiers and inward investment. | Our marketing campaign will have raised the profile of the Enterprise Zone and lead to a 50% increase in investment enquiries and relocation of 10 additional businesses on to the Enterprise Zone. | The Enterprise Zone will have attracted businesses onto a further 8ha of the zone with a net new 500 jobs available. | NBC EG&R | Maximising the Economic Benefits of Culture and Heritage
Northampton has outstanding Cultural and Heritage assets. We will work with our partners to ensure that the sector is visible and attracts both residents and visitors into the Borough.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|------------------------------------------------------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------|---------------------------| | 1. | We will work with our local partners to ensure that we are promoting the sector and it’s offer to the widest audience. | We will review current activity and design a new cultural and heritage programme. | A coordinated programme will be implemented which increases visitors’ numbers to our cultural and heritage assets | All local assets report increased numbers year on year | NBC EG&R team | | 2. | We will deliver a new Museum and Art Gallery following a £6.7m refurbishment during 2020. | The new Museum and Art Gallery will be open to the public in 2020. | The Museum and Art Gallery will be attracting XXX visitors per annum | The Museum and Art Gallery will be attracting XXX visitors per annum | | | 3. | The Vulcan Works will be operational in 2020 and provide a focal point and stimulus for start-up businesses in the Creative sector. | Vulcan Works will be open as a new facility for creative businesses. | The Vulcan Works will be 60% occupied and home to 25 creative businesses. | The Vulcan Works will be 75% occupied and home to 45 creative businesses. | NBC EG&R | | | We will develop the Cultural Quarter working with partners such as the Royal & Derngate, NN Contemporary and the local arts community to enhance the reputation and visibility of the Quarter and seek to attract inward investment in to the area. | We will work with our partners to explore how we can further develop Northampton as a cultural and heritage centre for both residents and visitors. | We will deliver a programme to increase the visibility of the Creative Quarter attracting new business investment and attracting new jobs. | We will have attracted 25 new creative businesses into the Creative Quarter and have an additional 50 new creative jobs operating within the Quarter. | NBC EG&R | Raising Northampton’s Profile
We will work to improve the profile of Northampton, to market Northampton as an attractive environment for business and tourism, which in turn will boost inward investment.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will develop a comprehensive Inward Investment Strategy and proposition, including strengthening links with London | We will start to implement our new inward investment marketing campaign | We will have attracted 50 new businesses into the Borough delivering 150 new jobs. | We will have attracted 75 new business and 225 new jobs. | NBC EG&R team | | 2. | We will continue to deliver the Waterside Enterprise Zone and develop a place marketing campaign to underpin this. | We will have started to implement our place marketing campaign which will market the Enterprise Zone as an attractive place to invest and do business. | We will have established an Enterprise Zone strategy, website and marketing material to gain investment into the area. | We will have seen a large amount of businesses locate in the Enterprise Zone with high value job growth. | NBC EG&R team | | 3. | Alongside our partners, such as Northamptonshire: Britain’s Best surprise we will develop a strong Tourism proposition that will drive visitors to the Borough. We will draw upon our strengths, such as Culture and Heritage and Food and Drink. | We will work with partners to develop a strong Tourism programme. | We will have seen a 10% increase in the number of visitors to Northampton and a 10% increase in the amount of Tourism spend within the Borough. | We will have seen a 15% increase in the number of visitors to Northampton and a 15% increase in the amount of Tourism spend within the Borough. | NBC EG&R team | | 4. | We will work with | We will develop a | We will see an | We will see an | NBC EG&R team | | partners such as the University of Northampton and key employers to explore how we can attract and retain talented people within the Borough. | programme of activity with our partners which identifies how we can attract and retain talent within the Borough. | increase in the number graduates remaining in Northampton increase by 10% | increase in the number of graduates remaining in Northampton increase by 15% | **Employers at the Heart of the Skills System**
We want to ensure that businesses demand for skills are understood and acted upon within the education system.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will work with the business community, schools, colleges, university and training providers to shape a Skills Strategy and action plan which sets out a system that meets the needs of our economy. | We will work with our partners to devise a strategy and programme that connects businesses with educational institutions. | Our programme will be working with schools (primary and secondary), colleges, the university and training providers all across Northampton. | By 2025, we will have a robust skills hub and network. | NBC EG&R team | | 2. | We will work closely with partners such as SEMLEP, the University of Northampton and Northampton College to develop programmes which bring employers and education providers together to develop and commission education and training providers to meet employer’s needs and economic priorities. | Programmes will be developed which support our current and future workforce to be resilient to economic change, attract and retain talented people and tackle the skills gap at all levels. | The skills profile in Northampton will be above the national average and a smaller number of businesses will cite skills shortages as a barrier to their business. | NBC EG&R team SEMLEP UoN Northampton College | | 3. | We will work with partners such as the University of Northampton and key employers to explore how we can attract | We will develop a programme of activity with our partners which identifies how we can attract and retain | We will see an increase in the number of graduates remaining in Northampton by 10% | We will see an increase in the number of graduates remaining in Northampton by 15% | NBC EG&R team UoN | | and retain talented people within the Borough. | talent within the Borough. | | | **Northampton as a Digital Town**
We want to ensure that Northampton has a high-quality digital infrastructure that supports both business and resident ambitions.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We want Northampton to be a smart city and be at the forefront of technological change. We will work with City Fibre to develop a full fibre network across the Borough. | Fibre Cover within the Borough will be XXX% | Fibre Cover within the Borough will be XXX% | Fibre Cover within the Borough will be XXX% | City Fibre | | 2. | We will push for Northampton to be a testbed for 5G, in order to provide faster mobile connectivity for businesses and residents. | We will develop partnerships with the private sector in order to develop proposals which will use Northampton as a test bed. | We will have developed a programme to establish the Borough as a test bed. | We will have delivered a programme and be evaluating the impact and promoting Northampton as location to invest in for further testing. | NBC EG&R team | | 3. | We will explore the applications for new technology as it becomes available including Blockchain, artificial intelligence and machine learning | We will work with partners to assess the opportunities that exist for Northampton to benefit from new technology. | We will review options and where an opportunity presents, we will design a programme with our partners. | We will have developed a programme which has utilised new technology and benefitted local residents and | NBC EG&R team | to see how Northampton and the local economy can benefit from new technology. Effective and Efficient Infrastructure
We will work with our partners to identify where improvements need to be made to our roads, where we can influence our rail services and where we can utilise technology effectively to address current blockages.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will work with Northamptonshire County Council to develop a Transport Strategy to address congestion in the Town Centre and tackle existing pinch points which hinder journeys across the Borough. | Working with partners we will develop out the business cases required to secure funding to make the identified improvements. | We will have addressed the key pinch points in line with progress we are making with the Town Centre Masterplan. | We will have addressed all pinch points within the Town Centre and be delivering improvements that support alternative means of transport. | | | 2. | We will work with partners to bring forward the following priority improvements; Brackmills & Castle Station Corridor, the North West Bypass, the Northern Orbital Road, the Northampton Growth Management Scheme affecting the A45 and the dualling of the A43 from Northampton to Kettering. | Working with partners we will design the business cases required to secure funding to make the improvements | We will have secured funds for a number of schemes and be commencing delivery of the schemes | We will be delivering improvements to a number of priority schemes | | Supporting Our Key Sectors
We will develop a detailed approach to engaging with our businesses to encourage growth and resolve issues that may be impacting upon growth opportunities.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|------------------------------------------------------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------|-------------------------------------------------------------------------------|----------------------------------------------------------------------| | 1. | We will work with existing local networks and clusters to provide support to local businesses. | We will work our partners to identify how NBC can work with local networks to assist in tackling existing issues and blockages that impact on business operation across Northampton. We will identify gaps in networking and aim to fill these. | We will be supporting local networks which meet regularly to discuss issues and opportunities facing local businesses. | Our work with local networks will have secured additional funds for local initiatives and have supported 25 businesses to secure funds for new innovative products. | | | 2. | We will review the availability of employment space and work with the developer community to establish the demand space across the Borough. | We will conduct a review to assess current demand and the condition of existing vacant premises. | We will have used the outcome of the review to deliver a programme which delivers new employment space and facilities with the Borough. | We will have developed new facilities with support from external funds to meet the needs of businesses. | | | 3. | Working with SEMLEP and the Growth Hub we will identify opportunities to support local sectors through the Government’s Sector Deals as they are announced. | We will work closely with the Growth Hub to understand the opportunities available to local businesses through Government support, including the current Sector Deals which are available. | We will have secured support through the Growth Deal for our key sectors. | We will be working closely with our local sectors to support their growth, with key outcomes relating to 250 new jobs and 20 businesses moving to new expanded facilities within the Borough. | | | | To ensure that measures are in place to address future economic shocks | We will develop an Economic Recovery Strategy in partnership with our stakeholders. | An agreed Economic Growth Strategy and Action Plan will be agreed and implemented. | The strategy will be held in reserve to enhance economic resilience should it be required. | **Tackling the Climate Emergency**
The Council have declared a Climate Emergency and has agreed that by 2030 Northampton will become a zero carbon, zero waste and climate resilient town, playing its part in limiting the impacts of climate change, both locally and globally, where residents, businesses and partners all benefit from the improved environment.
| No. | Key Actions | Year 1 Impact | Year 3 Impact | Impact by 2025 | Lead | |-----|-------------|---------------|---------------|---------------|------| | 1. | We will work with our business community to educate them on climate change and encourage green infrastructure. | We will devise a programme of activity to work with businesses and residents to develop low carbon awareness. | We will have encouraged low carbon businesses to invest and grow in the Borough. | We will have seen the economic benefits that cutting carbon presents for Northampton and we would have encouraged innovative clean growth. | NBC EG&R Team and Planning | | 2. | We will contribute and work with our partners to develop a Climate Emergency Action Plan. | We will have identified a plan that develops our long-term approach to tackling the Climate Emergency and address the need to reduce carbon emissions effectively. | We will have started to implement our action plan and developed approaches to address Transport, Buildings, Waste, Energy, Procurement and Green Infrastructure. | We will have noticed a significant reduction in carbon emissions and will be able to see progress in becoming a net zero emission economy. | NBC EG&R Team and Planning | | 3. | We will ensure that any interventions support improvements to air quality and health across Northampton. | We will review the work being undertaken as part of the Town Centre Masterplan and Enterprise Zone to ensure that all work meets the sustainability requirements. | We will continue to deliver our priority sites in line with the climate emergency policy and work with businesses to support large scale energy efficiency programmes such as insulating homes and renewable energy, | We will have supported local initiatives that mitigate climate change and demonstrate Northampton’s commitment to carbon reduction and adaption. | NBC EG&R Team and Planning |
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b1667564002d2e02f5f0e0d4560519536b299a75 | School Organisation Strategy What is a school organisation strategy?
- Strategic plan outlining how school places are organised across the borough, including school roll projections.
- The School Organisation Strategy isn’t statutory or compulsory – it’s a sensible and practical way to make sure that we have the right amount of school places now and for the future.
- Ensure there is a school place for every child that needs one - means regardless of residence we have a duty to provide a primary or secondary school place as required.
- Linking Growth and Development and changes in demography to needs. GLA, SRP and surplus places
- Greater London Authority (GLA) datasets include - population: households: ethnicity: economic activity: sets are updated annually, incorporating the latest data from Office for National Statistics (ONS) and other sources as it becomes available.
- We subscribe to GLA Demography – to generate our School Roll Projections (SRP).
- The replacement method is used to forecast the number of children anticipated in each age (year) group over time. 4 year olds are Reception class, 5 year olds Y1 and so on at primary. 11 year olds will be Y7 at secondary.
### Replacement method
| Year | 4 | 5 | 6 | 7 | 8 | 9 | 10 | |------|-----|-----|-----|-----|-----|-----|-----| | 2005 | 2.146 | 2.036 | 2.085 | 2.054 | 2.057 | 2.114 | 2.076 | | 2006 | 2.408 | 2.146 | 2.054 | 2.096 | 2.043 | 2.055 | 2.110 | | 2007 | 2.531 | 2.432 | 2.141 | 2.061 | 2.097 | 2.054 | 2.100 | | 2008 | 2.367 | 2.517 | 2.415 | 2.155 | 2.071 | 2.054 | 2.076 |
### Zero Development Population
| Year | 4 | 5 | 6 | 7 | 8 | 9 | 10 | |------|-----|-----|-----|-----|-----|-----|-----| | 2005 | 2.478 | 2.447 | 2.391 | 2.490 | 2.494 | 2.421 | 2.382 | | 2006 | 2.633 | 2.453 | 2.423 | 2.369 | 2.458 | 2.465 | 2.391 | | 2007 | 2.731 | 2.605 | 2.442 | 2.404 | 2.352 | 2.438 | 2.439 | | 2008 | 2.732 | 2.680 | 2.567 | 2.408 | 2.363 | 2.319 | 2.394 |
### New catchment ratios
| Year | 4 | 5 | 6 | 7 | 8 | 9 | 10 | |------|-----|-----|-----|-----|-----|-----|-----| | 2005 | 0.866 | 0.832 | 0.872 | 0.872 | 0.872 | 0.873 | 0.871 | | 2006 | 0.915 | 0.875 | 0.848 | 0.885 | 0.891 | 0.843 | 0.861 | | 2007 | 0.927 | 0.934 | 0.877 | 0.857 | 0.891 | 0.843 | 0.861 | | 2008 | 0.867 | 0.939 | 0.941 | 0.895 | 0.861 | 0.893 | 0.858 |
### Applying new catchment ratios to population
| Year | 4 | 5 | 6 | 7 | 8 | 9 | 10 | |------|-----|-----|-----|-----|-----|-----|-----| | 2005 | 2.146 | 2.036 | 2.085 | 2.054 | 2.057 | 2.114 | 2.076 | | 2006 | 2.408 | 2.146 | 2.054 | 2.096 | 2.043 | 2.055 | 2.110 | | 2007 | 2.531 | 2.432 | 2.141 | 2.061 | 2.097 | 2.054 | 2.100 | | 2008 | 2.367 | 2.517 | 2.415 | 2.155 | 2.071 | 2.054 | 2.076 |
**Zero Development Populations assumes that there are no new housing developments added.**
**2006 Catchment Ratio**
[ \\frac{2146}{2453} = 0.875 ]
**2006 Population Projection**
87.5% of 2453 School roll projections
• About 18 months ago the GLA noticed irregularities with their projection model for SRP.
• A miscalculation in the ONS mid year estimates for internal migration (population movement across London boroughs) meant their internal migration model was counting inward internal migration but not counting outward internal migration.
• This miscalculation skewed the GLA projections which were passed on to us in our SRP. Primary school roll projections
| Year | School Places | SRP | Difference PAN minus SRP | |------|---------------|------|--------------------------| | 2019 | 3,915 | 3,347| 568 (17.0% surplus) | | 2020 | 4,035 | 3,379| 656 (19.4% surplus) | | 2021 | 4,125 | 3,435| 690 (20.1% surplus) | | 2022 | 4,215 | 3,473| 742 (21.4% surplus) | | 2023 | 4,245 | 3,543| 702 (19.8% surplus) |
| Year | School Places | SRP | Difference PAN minus SRP | |------|---------------|------|--------------------------| | 2019 | 7,876 | 6,324| 1,552 (24.5% surplus) | | 2020 | 7,951 | 6,254| 1,697 (27.1% surplus) | | 2021 | 7,966 | 6,187| 1,779 (28.8% surplus) | | 2022 | 7,966 | 6,142| 1,824 (29.7% surplus) | | 2023 | 7,966 | 6,119| 1,827 (30.2% surplus) | Secondary school roll projections
| Year | School Places | SRP | Difference School Places minus SRP | |------|---------------|------|-----------------------------------| | 2019 | 8,019 | 7,173| 846 (11.8% surplus) | | 2020 | 8,022 | 7,270| 752 (10.3% surplus) | | 2021 | 8,025 | 7,356| 669 (9.1% surplus) | | 2022 | 8,025 | 7,476| 549 (7.3% surplus) | | 2023 | 8,025 | 7,546| 479 (6.3% surplus) | School Financial Viability
LBHF School Budget and Funding 3-year Falling Roll Scenario
Hammersmith & Fulham Council Emerging themes and recommendations
1. Address primary surplus, reduce PAN, collaborative approaches.
2. Secondary provision nurtures and develops education based relationships - Industrial Strategy.
3. Revive and restore the unique appeal of local schools.
4. Federation and collaboration approaches.
5. Use school organisation strategy evidence base to respond to planning proposals.
6. Further work on Special Educational Need and Disabilities (SEND) and Alternative Provision (AP) place planning linked to need.
7. Balance between provision in specialist schools, special units within mainstream schools and mainstream institutions.
8. Use future Community Infrastructure Levy (CIL) to invest in school buildings and regeneration of school estate through development.
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c8435aa8150eeeb62afcddee7869cedd950b1c40 | ## Appendix 2: Responses to Consultation (Neighbourhood Area)
### 1.1 Summary of responses - Neighbourhood Area
| Respondent ID | Organisation | Comment | Officer Response | |---------------|-------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|----------------------------------------------------------------------------------| | SB/01 | The University of Northampton | Spring Boroughs is geographically well defined by Grafton Street, Horse Market, Marefair and St Andrews Road. Understand and support the need to add in the medieval historic area between St. Peters Way and Freeschool Lane and the café and Lorry Park at Super Sausage. Seeks the inclusion of the Sol Central leisure complex as part of the Neighbourhood Area because it is source of local employment and as a key element of the environment of Spring Boroughs. | Noted. | | | | | | | SB/02 | Natural England | No objections to the designation of a Neighbourhood Area. No designated sites in close standing advice note with regard to consultee status. This information will be passed to the forum at the appropriate time. | Standing advice note with regard to consultee status. This information will be passed to the forum at the appropriate time. | proximity of the area, but all plans should consider potential impacts on such sites.
| SB/03 | Friends of Northampton Castle | Strongly support the creating of a neighbourhood planning area that includes the significant areas of medieval and earlier Saxon archaeological evidence. Boundary ensures that the Castle remains will be part of the overall plan for the area. | Comments noted. | | SB/04 | Spring Lane Children’s Centre | Support the request to designate the area. Seek extension to the boundary to include Sol Central to enable the inclusion of a business community that has a significant impact on the residential area of Spring Boroughs. | Noted. The request to include Sol Central is noted, and an option for its inclusion is detailed within the Cabinet Paper for consideration. | | SB/05 | Northampton Borough Council (Regeneration and Enterprise) | Support the approach for Neighbourhood Planning. Boundary is logical and sits | Noted. | | SB/06 | The Environment Agency | No Comments on the designation of the area. | N/A | |-------|------------------------|---------------------------------------------|-----| | SB/07 | Northamptonshire County Council Archaeology | Seeks inclusion of the area to the south and east of Spring Boroughs to Horseshoe street to allow for the identification of the historic potential and character of the area. This would lead to a more proactive approach including appropriate opportunities for enhancement of the character either as an indirect result of development or as a purely community led approach. | The area bounded by Freeschool Street/Horseshoe street is identified as a separate policy area within the CAAP. At this stage, it is not considered desirable to extend the area across into a neighbouring CAAP policy area as this may dilute focus away from the initial reasons for producing a Neighbourhood Plan to guide the regeneration of Spring Boroughs. However, we recognise the importance of the archaeological potential across the whole of the area and, as the community develop the plan, we will seek to ensure that the context of the area is reflected in any emerging policy that relates to the archaeology or historical interest, particularly in relation to St Peters Church and the area to the south. NCC Archaeology will be a key consultee during this process. |
### 1.2 Summary of Responses - Other matters:
| Respondent ID | Organisation | Comment | Officer Response | |---------------|-------------------------------------|-------------------------------------------------------------------------|--------------------------------------------------------------------------------------------------------------------------------------------------| | SB/01 | The University of Northampton | Neighbourhood forum should embody a number of principles including local residents, equality, wider engagement, long-term sustainable change and partnership with key service providers. | Northampton BC believe that the inclusion of local residents in the forum is paramount to its success and agrees with the other principles which it will try to ensure are embedded within the final constitution of the forum through its powers of designation. The success of the forum will be reliant on the initial commitment and enthusiasm of residents within the area. | | SB/02 | Natural England | Various advice in preparing a plan relating to wildlife and nature conservation etc | The links and guidance are helpful and will be passed to the Neighbourhood Forum as a valuable tool in gathering together evidence for the plan. | | SB/03 | Friends of Northampton Castle | FoNC looks forward to being part of the consultation and future work on the plan. Use St Peters and the URC church to advertise and exhibit any plan for the area as they are close than the Guildhall, Central and St James Library. | The contact details will be passed to the forum to ensure that FoNC continue to be consulted as part of the planning process for the area. As a community organisation operating within/ in close proximity of the area, FoNC are considered a statutory consultee for those regulations that Northampton Borough must fulfil. These facilities will be utilised as locations for formal consultations as part of the regulations that the Borough Council must fulfil (forum and the submission plan) but must be in addition to the usual inspection locations of the libraries and the Guildhall to ensure consistency of approach with usual planning procedure. | | SB/04 | Spring Lane Children’s Centre | No additional comments | We will strongly support the use of local facilities by the Neighbourhood Forum (when constituted) for advertising their plans and other consultations. | |-------|-------------------------------|------------------------|----------------------------------------------------------------------------------------------------------------------------------| | SB/05 | Northampton Borough Council (Regeneration and Enterprise) | Meetings of 21 people may be difficult to achieve. It is importance that the Governance/ management and engagement arrangements are clarified and agreed at the earliest opportunity and set these out now. Development proposals are being looked into for some of the land owned by NBC within the proposed area. | The Localism Act requires a minimum of 21 people to be members of a Forum, and this group can not be formally constituted until the area is designated. Work is presently being undertaken to try to identify the organisations that could help start the forum and assist in gathering momentum for the process. The bid to DCLG identified this as one of the key challenges for this particular plan. Noted. It will be important that Regeneration & Enterprise keep the community informed and properly engaged with their proposals and respect the Neighbourhood Planning process- including the community’s aspirations for particular sites and areas. Planning Policy will be happy to advise until such a time that the forum is properly constituted. | | SB/06 | The Environment Agency | The letter contains various advice and guidance with regard to the 5 key areas of Environment Agency responsibility. | The guidance provided is helpful and will be passed to the Neighbourhood Forum as a valuable tool in gathering together evidence for the plan. | This is particularly important in ensuring that any plan for the area is truly sustainable. The Environment Agency will be a key stakeholder, particularly in terms of water quality and resources as it is noted that there is a high potential to improve on the current drainage arrangements in this area.
| SB/07 | Northamptonshire County Council Archaeology | N/A | N/A |
### 1.3 Informal Requests for Information/ Additional comments
| Information Request | Private Individual | Notices don't tell you what a Neighbourhood Plan is and don't show the area. | |---------------------|--------------------|--------------------------------------------------------------------------------| | | | Thinks that we should have had a plan already (before doing the CESP works) so that we could see how it all works. | | | | Isn't sure that the community should be doing the plan as it's the council's job! | | | | Noted- evaluation chapter questions appropriateness of notices and the additional information these give. If using in the future, a map will be included. | | | | The Neighbourhood Plan is a community led process under the regulations. The timescale for this plan is not the Borough Council, but that submitted with the council’s support to DCLG. In developing the forum, it is hoped that organisations working in the community will undertake consultation and explain the process. | | | | Noted- included within this report as feedback to DCLG. | | Information Request | Private Individual | Came in to ask about the Regeneration Plans. | | | | Explained Neighbourhood Area application and what it does and referred back to Castle Partnership meeting | | | | Apparent there is some confusion with regard to the ownership of the process. Will need to ensure that there is greater awareness raising in the area. | | | | Individual subsequently attended the event held by Planning Aid England and has offered to support advertisement of future events. | | Information Request | Private Individual | Concerned about what the letter was about as buying a flat. | | | | Explained process, why, | | | | Will need to ensure that there is greater awareness raising in the area- will produce publicity of FAQs for future Regulation 6 consultations. | | CAAP policy, gave her Jennie's phone number and encouraged her to be part of neighbourhood plan making. | | Much relieved to have talked it through |
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84e752c6829fb3e6dea62e9b95a00ab4c462cf97 | Managing digital records without an electronic record management system
© Crown copyright 2012
You may re-use this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence or email [email protected].
Where we have identified any third-party copyright information, you will need to obtain permission from the copyright holders concerned.
This publication is available for download at nationalarchives.gov.uk.
## Contents
| Section | Page | |------------------------------------------------------------------------|------| | Introduction | 4 | | Purpose | 4 | | Audience | 5 | | Scope | 6 | | Definitions | 7 | | Records management policy | 10 | | What is a records management policy | 10 | | How does the policy aid records management? | 11 | | Where can I learn more? | 13 | | Filing structures | 14 | | What is a filing structure | 14 | | How does the filing structure aid records management? | 16 | | Constructing the filing structure | 17 | | Where can I learn more? | 21 | | Management rules | 22 | | What are management rules | 22 | | Monitoring and maintenance of management rules | 24 | | How do they aid records management? | 25 | | Management of metadata | 25 | | Types of management rules | 28 | | Naming conventions | 28 | | Version control for records | 32 | | Format of dates | 33 | | Where can I learn more? | 34 | | Access control management | 35 | | What are access controls? | 35 | Setting up access controls ........................................................................................................37 How do access controls aid records management? .................................................................38 Complex access control models .............................................................................................39 Monitoring access control allocations ....................................................................................39 Other access controls .............................................................................................................40 Operational limitations ............................................................................................................40 Where can I learn more? ..........................................................................................................40 Disposal policy and management ............................................................................................41 What is a disposal policy? .........................................................................................................41 What is disposal management? ...............................................................................................41 How does disposal management aid records management? ....................................................42 Where can I learn more? ..........................................................................................................44 Email management ..................................................................................................................44 What is email management? ....................................................................................................44 How does email management aid records management? .........................................................45 Management for rules for email ..............................................................................................46 Guidance for email management .............................................................................................47 Email formats ..........................................................................................................................47 Retaining emails within the email client ..................................................................................49 Alternative email storage .........................................................................................................52 Bulk email archive storage ....................................................................................................52 Bulk email archive file format ...............................................................................................53 Where can I learn more? .......................................................................................................53 Integrating management of paper records ..............................................................................54 Where can I learn more? .......................................................................................................55 Further reading .......................................................................................................................57 Introduction
Managing electronic records presents a significant challenge for an organisation of any size or sector. For those that store their records in file systems (including shared drives), which have no formal controls in place, the risk of alteration or deletion makes this challenge even greater.
Organisations may have a well maintained paper records system but this is not necessarily appropriate as a template for managing electronic records. This is because of the volume of electronic records, and variety of file formats, combined with the ease of creation.
Electronic records management needs to be very carefully considered and structured to ensure the integrity of the records is not compromised upon capture and they remain retrievable for as long as they are required.
Purpose
The purpose of this guidance is to demonstrate how an organisation can improve the management of records within their file systems by:
- establishing a records management policy
- creating management rules and using them
- developing a classification structure
- introducing email management rules and version control
- establishing user compliance or buy-in
Without these an organisation is at risk of failing to manage records exposing them to risks including reduced business efficiency or potential legal action.
An organisation in control of its records can begin to realise significant benefits including:
- improved business efficiency and effective use of IT resources
- structured management of records retained for legal and regulatory purposes
- support of accurate capture and management of electronic records (irrespective of format) into the file system
- access to records to enable informed and effective decision making Managing digital records without an electronic record management system
- retention of a corporate memory of transactions, decisions and actions taken by, or on behalf of, the organisation
- protection of the rights and interests of the organisation (and others) who the organisation retains records about
- protection of the characteristics of records as defined by ISO 15489, particularly their reliability, integrity and usability
- identification of records required for permanent preservation and archive
Throughout this guidance there are examples using Microsoft Windows XP and Office 2007 (with Outlook). However this guidance is not limited to users of this platform and software applications and should be equally relevant to users of any desk based operating systems and office software applications.
This guidance replaces records management guidance previously published by the Historical Manuscripts Commission, and guidance on managing records in Office 97 published by the Public Record Office.
**Audience**
This guidance is intended for anyone who controls the management of records within any organisation or part of an organisation. This may be a formally adopted records management role, but it also includes those who manage records as part of their role such as medical or legal secretaries.
Smaller organisations, which do not have formal records management, can use this guidance to create a full programme for improving records management.
Larger organisations, which already have some form of records management, can use this document to develop records management where there needs to be significant consultation and development work.
______________________________________________________________________
1 Digital Continuity advice and Guidance from The National Archives is available where long term maintenance is a requirement. This guidance is principally provided for public authorities and addresses the equivalent long term issues of loss of completeness, availability and usability. This guidance is not restricted to any particular sector or industry. References to specific guidance are given as indicators of best practice in records management. Each organisation needs to consider its regulatory and legal environment which may dictate specific decisions regarding access and disposal of records.
Public authorities should read this guidance in conjunction with the Records Management Code of Practice revised and reissued under s 46 Freedom of Information Act, 2000. Useful references to sections of The Records Management Code have been included in ‘Where can I learn more?’ where appropriate.
Scope
The focus of this guidance is the management of records stored within a file system using existing infrastructures and resources. It will discuss the process of defining an organisation’s need for records management based on the development of a policy and supporting guidelines for users.
Other types of ‘basic content services’ that offer some form of collaboration and informal document management might be used, such as Microsoft Office Sharepoint or Alfresco. They are not referred to in detail in this guidance. Such applications may support a subset of record management activities but an organisation still needs to develop and implement clear policies and management rules that will build an identifiable records management culture.
These products are rarely coded to implement records management rules without significant customisation and organisations should develop appropriate rules. They should evaluate solutions to support their implementation, managing the risk of records management failures. It may be that the procedures described in this guidance are preferable or alternatively that there is a clear case for deploying a records management application (or ERMS).
This guidance is not intended to be used as a technical manual, nor does it provide an organisation with a full set of policies and management rules. Use the guidance as a basis for best practice in the most suitable manner for their organisation. Inevitably there will be some technical discussion. This will be restricted to a level of understanding that enables the reader to discuss technical issues with IT or records management specialists where required.
The examples will use Microsoft Windows application suite (including Microsoft Outlook), and are for illustrative purposes only.
The guidance will not discuss use of content management systems nor website management tools.
In practice, organisations will be managing both paper and electronic records concurrently for a significant period of time. This guidance contains information on how the relationship between the two types of record may be managed.
It offers guidance on the management of physical records within an integrated environment but it does not extend to examining systems or applications (specifically for managing physical records such as a library system or tracking system which do not allow for accurate management of electronic records). There is further advice on this topic in a related piece of guidance Identifying and specifying requirements for offsite storage of physical records.
**Definitions**
This guidance uses some terms in a specific way:
**Aggregation**
Record assemblies existing within a filing structure (groups of folders) or a folder containing records. In a file system aggregation is limited to folders that contain folders and folders that contain records.
**Business classification scheme**
An intellectual structure categorising business functions/activities or subjects to preserve the context of records relative to others. It is useful for aiding activities such as retrieval, storage and disposal scheduling of records. Disposal
A formal decision taken on the final status of a record (or set of records) to either destroy the records, transfer to another organisation for permanent preservation or retain within the organisation’s file system for further review at a later date.
Electronic records management system (ERMS)
An electronic records management system (ERMS) is a computer program (or set of programs) used to manage electronic records stored in an associated database. It provides a variety of functions including access controls, auditing and also disposal using a combination of system and user generated metadata.
Depending on the system it can also be used to manage paper records held by an organisation.
Filing structure
A hierarchical structure of folders within a file system which provides a coherent location for capturing records.
The term ‘filing structure’ is synonymous with the term fileplan. However, this term is not used here as it is typically used to characterise the business classification scheme of an ERMS.
File system
A method for storing and organizing computer files and the data they contain to make it easy to find and access them. File systems may use a data storage device such as a hard disk or CD-ROM and involve maintaining the physical location of the files.
Folder
A type of aggregation or container within a file system used to store records (and other folders). It is the principal building block of a filing structure.
Management rules
Management rules are set of explicit instructions to users on the organisation’s preferred means of managing records. These include direction on appropriate capture, access management and disposal of all records irrespective of format or media. The term ‘management rule’ is synonymous with the term ‘business rule’. Within this guidance ‘management rule’ is preferred explicitly for records management within a file system. However either term is acceptable and can be used when producing a rule set for managing records.
**Metadata**
Data describing the context, content and structure of all records and folders within a file system. In a file system this is essentially user-generated and ‘passive’ in that it can rarely be used for active management of the records. By contrast, metadata in an ERMS is more functional, often system-generated, extensive and linked tightly to system processes.
**Operating system**
An interface between computer hardware and a user that manages and coordinates use of computer applications using the available resources provided by a computer’s processor.
**Record**
Information created, received and maintained as evidence and information by an organisation or person, in fulfilment of legal obligations or in the transaction of business.²
**Records management**
The practice of formally managing records within a file system (electronic and or paper) including classifying, capturing, storing and disposal.
**Shared drive**
A specialisation of an operating system file system, comprising a shared device (for example, hard disk or server space) used by multiple users and accessed over either a local area network or a wider area network connection.
______________________________________________________________________
² See International Standards Organisation ISO 15489 Information and documentation: Records management, two volumes 2001 Records management policy
What is a records management policy
A records management policy can be described as an authoritative statement of intent to manage records in an appropriate and suitable manner for as long as they are required for business purposes. It is intended to form the initial framework or principles which express how records should be managed within the organisation. Where the records management policy comprises part of a broader information management or knowledge management policy, it should still be easily identifiable and available to users.
The international standard for records management ISO 15489(^3) states:
> ‘The policy should be derived from an analysis of business activities. It should define areas where legislation, regulations, other standards and best practices have the greatest application in the creation of records connected to business activities.’
The records management policy should not be so vague that no ownership or authority can be attributed to it. It must be signed off at the highest level possible (board level) and it should provide, as a minimum:
- a description of what a record is and the reason for capturing and managing it
- a statement of commitment by the organisation to manage records appropriately and accurately for as long as the records are required
- identification of records management roles and responsibilities for all staff at every level of the organisation
- an explanation of the objectives of the records management policy and how it aids compliance with specific standards and legal responsibilities applicable to the organisation
- detail of the relationship between the records management policy and other policies within the organisation (the email management or data security policies)
(^3) ISO 15489-1:2001 Information and documentation Records Management Part 1: General; 2001 Creating a records management policy should be the first priority for an organisation looking to improve or consolidate its records management. Do this in consultation with the business, with senior management endorsement and support.
It should encompass paper and electronic records created and managed by the organisation. Management rules for creation and management of electronic and paper records should be explicit and should support the principles laid out in the policy.
There should also be a regular review of the records management policy. The timeframe for review should be at least every five years, but with flexibility to review it if significant changes in the business of the organisation require it (a new business activity or introduction of a new business system).
**How does the policy aid records management?**
A records management policy provides an authoritative mandate for implementation across the organisation. It exists to reinforce the importance of records management at a senior level and determine its direction within the organisation.
This framework can guide the development of file systems and records management processes. This should lead to overall better understanding and delivery of records management across the organisation.
Within smaller organisations the records management policy may be the single resource for records management. As the principal statement it provides new and existing users with a direction on records management to ensure it is taking place correctly. In this way the policy is directly responsible for guiding the development of records management within an organisation.
In larger organisations it is more likely that the records management policy will provide a broad instruction that record managers can refer to as their authority for promoting records management.
If difficulties with records management activities cannot be resolved at a procedural level with business managers, reference to the records management policy can help in resolving them. Case study:
An organisation’s records management policy clearly articulates a responsibility to comply with legal or statutory regulations indicating that records must be managed to fulfil these responsibilities (for example, response to subject access requests under the Data Protection Act).
Using incremental implementation of the records management policy, users are made aware of these responsibilities and work to ensure accurate records are captured and well managed. This enables the organisation to respond to requests for information efficiently and effectively without loss of productivity.
This case study explains how the successful implementation of a records management policy relies on how well it is implemented. If users are given the opportunity to view and understand the policy, it will help to ensure they adhere to it on a day to day basis.
Case study:
An organisation has not produced a defined records management policy. As a result users do not have a clear understanding of what records should be created and retained.
Following an investigation by a regulatory body the organisation is found to have failed to retain specific key records. As a result they are found guilty of corporate negligence through poor records management, fined and reprimanded by the auditing authority leaving them with significant financial and reputational damage.
This case study explains how the successful implementation of a records management policy relies on how well it is implemented. If users are given the opportunity to view and understand the policy, it will help to ensure they adhere to it on a day to day basis. Limitations of a policy
A records management policy cannot guarantee that users will actively manage records. In order to realise the benefits of the records management policy an organisation will need to undertake other activities and changes to ensure active records management takes place.
The process of implementation required to support the records management policy in improving records management will need:
- creation of accessible guidance on records management such as naming conventions, capturing of emails, and disposal methodology
- development of management rules for the use and management of the file systems
- establishment of a process for monitoring the file systems to ensure records are being effectively managed as intended by the records management policy
These supporting features are a practical application of the records management policy and together provide the actual process of records management as a business function.
Where can I learn more?
Implementation guidance
Guide 2: Organisational arrangements to support records management
A brief implementation guide developed to help public authorities achieve compliance with the Code of Practice issued under s 46 of the Freedom of Information Act 2000. Intended for the Public Sector its principles are applicable to anyone establishing a records management policy.
Examples of policies
The following are examples of records management policies; we do not recommend wholesale adoption of another organisation’s records management policy.
- JISC records management policy
www.jiscinfonet.ac.uk/InfoKits/records-management Filing structures
What is a filing structure
The filing structure reflects the relationship of business activities through careful structuring of folders (with meaningful titles) ‘containing’ the records. This structure illustrates what the organisation’s business is, and it provides a means of managing its records.
A filing structure provides an environment for presenting a common understanding of how records should be stored and retrieved. This is particularly important not just for users working in a team, but also when working across the organisation by improving the retrieval of content and making it understandable to every user.
If the filing structure is well designed it will allow the organisation to control access more effectively, ensuring that unauthorised users are not inadvertently granted access.
A filing structure may be modelled on the functions of an organisation. Alternatively it may also use subject themes for parts of the structure. In either circumstance avoid using names of business units (or individual users) as this can cause problems such as:
- inhibition of sharing content and information across the organisation
- unnecessary duplication of records causing problems with routine disposal policies Managing digital records without an electronic record management system
- separate (or silo) work areas within a corporate filing structure making it difficult to shape records management at a strategic level
- legacy filing areas for discontinued work groups and obsolete business units remain in place and unresolved
- reduced efficiency in terms of compliance with the Data Protection Act or Freedom of Information Act
These problems can be aggravated if users move within the organisation, or leave.
There are many approaches to creating a filing structure and even a number of commercially available tools available to aid organisations when designing, or re-designing, one.
Irrespective of the method used to create a filing structure, it must at the very least contain the following attributes:
- a structure that is easily interpreted and which discourages users from placing records in inappropriate locations
- simple names that identify the logical element of the filing structure
- established responsibilities for folder management, to ensure the filing structure is well maintained
- typically a ‘functional’ filing structure will have three levels (or layers) of folders that act as segregations for information. These levels represent the functions, activities and transactions of an organisation
- the fourth, and usually final, layer sits beneath these. It is defined by the business where the records are to be captured and stored. This prevents users from creating idiosyncratic, locally defined, sub-folder structures below this level, within a particular part of the filing structure, which does not conform to the corporate rules Example:
This example shows a basic layout of a filing structure in the MS Windows environment. Other systems will use different icons and might display the filing structure slightly differently.
The upper folders or ‘Classification Folders’ should never contain records. If the expertise is available, identify the upper folders by an icon different to that of a normal folder. This provides a visual distinction for the user. Records are normally only expected to be captured in the fourth (or lowest) level of the filing structure.
This method allows an organisation to implement and manage both access controls and disposal scheduling across aggregations of records in a clear and defined layout. This reduces record management overheads and ensures consistency across the filing structure.
**How does the filing structure aid records management?**
From the organisation’s perspective, there is rarely sufficient standard functionality within a file system that can be used to control the creation, deletion or movement of folders. Most file systems options are limited to a simple on/off option depending on the user’s access rights. This provides further complications as folders and records have to be moved (and archived) manually with no audit control. If a mistake is made there will be no report or audit trail that could be examined easily to confirm where a folder (or record) has been moved to.
From the user’s perspective, a filing structure helps mitigate this by providing a logical structure which makes it easy to see where a specific record (or new folder) should be located.
Organised filing structures support records management by providing an understandable and accessible location for all records which encourages users to work within it. This helps an organisation reduce the risk of business critical information being lost within an uncontrolled file system. It also helps motivate users to move records out of personal drives or email accounts where it may be deleted without anyone knowing it existed.
**Constructing the filing structure**
Designing a filing structure is often a time consuming task, particularly where there has never previously been any formal order or agreed layout for records and folders. There are products that can help with reducing the time it takes to design the filing structure. In all cases it must be thorough and with a focus on usability.
There are proprietary software tools for developing the structures needed to manage documents and records. Such tools can be used to create and maintain a comprehensive range of business classification schemes, taxonomies, thesauri, glossaries, records retention and disposition schedules. However using them will incur additional costs.
More information on these business classification software tools is provided at ‘Where can I learn more?’ at the end of this section.
**Example:**
This is an example of a clearly designed and managed filing structure organised in a hierarchy of folders. The names of the folders use a simple structure and basic semantics so that all users can interpret it. Example:
This is an example of a poorly designed and managed filing structure with no control over the hierarchy of folders. It leaves users confused about where to capture records for any given function. For example a new or temporary member of staff may not know where to locate a draft policy.
The visual representation of the folders within a Windows operating system is only for display purposes - the folders portray the file system metadata used to configure related objects on-screen. Users often think (incorrectly) that they are capturing records into an actual folder when in fact they are stored randomly. The records are not located within the designated folder. It is the operating system which displays them in a logical order using the folders as a prompt.
Creation, movement and deletion of classification folders must be carefully controlled and restricted to a sub-set of users, or in smaller organisations, restricted to the records manager. This ensures that any development of the structure is consistent and that there is no inappropriate access or disposal. It will also enable the organisation to prevent uncontrolled proliferation of folders (and potentially sub-folders) by any user who has access to the filing structure.
Much of this will require management rules owing to the limitations of the file system functionality. This is particularly difficult where users have rights to create both folders and records in an area of the filing structure. Without complex coding it is difficult to develop a type of folder that allows only records to be captured into it by a user with access rights. As a result users could place records and folders at the same level of the filing structure. Example:
This example illustrates how the filing structure can be disrupted by allowing records (outlined by the red box) and folders to exist at the same level.
The relationship between the records, folders and parent folder are unclear with no understanding on how they should be managed. This introduces a further complication; it is often unclear whether the record should be disposed under different rules to the folders and their contents.
The management rules need to be supported by frequent monitoring of the filing structure, correcting any errors. With significant IT configuration, custom scripting may allow a greater level of functionality within the filing structure to prevent end users from adding records at inappropriate levels of the structure.
This guidance does not cover these options as customisation is likely to be expensive.
**Shortcuts and relating folders**
In an ERMS it is possible to create a record or container (folder) in one location but have it appear in multiple areas of the filing structure using a system of ‘pointers’.
These pointers are an interactive shortcut to an object that replaces the need for duplicate copies of a record and are coded to resolve any conflicts in access control and disposal management.
Whilst this functionality does not exist in a file system, it is possible to achieve some of the end-user benefits of pointers by using the ‘Shortcut’ option in systems such as MS Windows. Example:
In this example two folders (outlined by the red box) were needed in two parts of the filing structure. Having decided the primary location for the folders shortcuts were created and placed in the secondary location. This technique can significantly reduce the amount of duplication present in a filing structure. It will also support organisations trying to respond to requests for information by ensuring only one copy of a record, or location for record exists.
Use shortcuts with caution. They are merely a link to a record. They do not have any content themselves and pose the following risks:
- if the original record is deleted the shortcut will remain, but no longer pointing to anything
- inconsistent disposal processing is possible as the record manager will not necessarily be able to locate all shortcuts
- there is a significant risk of retaining implied personal data (through the title of the shortcut) or other sensitive information
Limitations of a filing structure
The limitations of a filing structure are largely based on those of the file system that supports it. The limitations can be summarised as:
- the functionality of a file system presents a significant limitation in the control of creation, deletion and movement of records and folders where a user has access
- a file system’s functionality does not prevent users placing records in the wrong folder if they have access to it
- a filing structure will only be effective if users are able to engage with it
- a poorly constructed filing structure will only discourage users from engaging with it and exacerbate any records management issues that arise These limitations can only be mitigated by strict management rules and a policy of reviewing the filing structure periodically to ensure it is being used appropriately. Additional ongoing training for users and active management by those responsible for records management (either corporately or locally) can help ensure records management activities are being carried out appropriately. This will also help identify departures from recommended practice.
**Where can I learn more?**
**Designing a filing structure/business classification scheme**
There is a range of guidance available on designing a filing structure and various groups have created some sector specific guidance.
- Business classification scheme [File plan] design
**Example business classification schemes**
These examples of business classification schemes are included for illustrative purposes only.
- Local Government classification scheme V2.03:\
[www.rms-gb.org.uk/resources/92](http://www.rms-gb.org.uk/resources/92)
- JISC Infonet HEI business classification scheme, 2007:\
[www.jiscinfonet.ac.uk/partnerships/records-retention-he/hei-bcs-user-guide](http://www.jiscinfonet.ac.uk/partnerships/records-retention-he/hei-bcs-user-guide)
**Business classification tools**
This is not an endorsed list of software. These examples can be used to aid an assessment of a file system(s) to help build a filing structure, and address redundancy and duplication. Other products may be available and each organisation must assess whether they need such a service at all.
- a.k.a.® available direct from the Australian developers or in the UK via In-Form Consult Ltd:\
[www.a-k-a.com.au](http://www.a-k-a.com.au) or [inform-consult.co.uk](http://inform-consult.co.uk)
- One-2-One Classification software for records management:\
[www.acs121.com/html/one2one.html](http://www.acs121.com/html/one2one.html)
- Active Navigation:\
[www.activenav.com](http://www.activenav.com) Keyword AAA: www.naa.gov.au/Images/Keyword%20AAA_tcm16-47292.pdf
Keyword AAA is a thesaurus of general terms designed for use in classifying, titling and indexing most types of records in most technological environments. To provide a comprehensive controlled vocabulary, use Keyword AAA in conjunction with a thesaurus of functional terms relating to the organisation’s specific or core business functions.
Record Management Code of Practice reference
- Keeping records to meet corporate requirements
- Guide 6: Storage and maintenance of records
- www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm
Management rules
What are management rules
Management rules are set of explicit instructions that direct users in the organisation’s preferred means of managing records. These directions specify a variety of activities and should also explain why the rule has been created. Whilst the style and detail of management rules may vary between organisations they should include instructions on:
- appropriate means of capturing electronic records into the filing structure
- clear definitions on what records should be captured into the filing structure and what may be held in a personal drive (such as users’ staff appraisals)
- specific criteria for the application and management of access controls
- specific criteria for the disposal of all records and folders with explicit reference to the organisation’s disposal policy
Management rules should always be expressed as an instruction and should not be ambiguous in their interpretation. Their purpose is to provide a mandate and authority that helps ensure a level of consistency is applied across an organisation in terms of records management.
Without management rules implementation of the records management policy will be very difficult. Finding a balance between use of software that may automate certain activities and ensuring users still engage in records management is a difficult balancing act, only managed by implementing effective management rules.
Within a file system, records might be moved and edited without the actions being auditable. Management rules are one of the most practical ways of ensuring that activities within the file system such as capture, classification and disposal of records are carried out with a degree of logic and accuracy by all users.
Management rules provide direction on a range of records management activities and include, but are not limited to:
- naming conventions for folders and records
- management of the filing structure
- allocation of access controls
- management and execution of disposal
There is no standard profile for management rules and organisations may decide how they should be written and made available to users. However there are some basic principles that should be included in the development of management rules. Specifically they should:
- reflect and reference the good practice presented in the records management policy
- be written in natural language (non-technical or Plain English)
- be made available to all users (via an intranet or central guidance library, for instance)
- indicate where specific records (such as vital records for disaster recovery) need to be managed to comply with regulations or other external review processes
The management rules should be framed in terms of their benefit to the organisation and its records management capability. This must necessarily outweigh individual preferences for managing records. To avoid a conflict between these two needs, the management rules should be developed in consultation with the users.
This helps ensure that the rules do not prevent the efficient conduct of business, but also that users are not disenfranchised by an enforced set or rules that does not allow them to do their job. Case study:
An organisation, having conducted a review of the file system, decides to implement management rules to improve the way users capture records into the system. During the consultation on the management rules, those responsible for records management discover that the proposed filing structure doesn’t support the way users need to capture records and as a consequence the proposed management rules would impede business activities.
This case study demonstrates the need to develop the filing structure and management rules in consultation with users so that the organisation develops a good records management culture. This encourages users to feel that the management rules have not been imposed, and they are happy to participate in good records management.
Monitoring and maintenance of management rules
Training and advice on management rules is essential. There must also be a process of monitoring to ensure that users work within the rules.
This requires roles to be created at both a local and strategic level to form a watching brief on use of the filing structure and email clients and to correct and guide where rules are breached or misinterpreted. These monitoring roles should be empowered to report persistent and/or deliberate breaches of the management rules to a senior record management authority.
Occasionally a management rule may become an impediment to business conduct or no longer reflect the environment in which records are stored. The monitoring role can be engaged to evaluate whether a persistent breach of a management rule results from the rule no longer being appropriate or that it hampers users doing their job.
Management rules should be re-evaluated regularly and particularly where changes occur to either the file system, filing structure and the record management policy. How do they aid records management?
Management rules help mitigate the limited nature of system generated metadata by providing structure and support to users enabling them to proactively manage their records. When combined with routine monitoring, management rules assist in building a culture of records management.
The other benefits of management rules include:
- assistance to users in the conduct of day to day business by providing a common and easily understood framework
- improvements to business efficiency by ensuring all users capture and manage records in a similar manner allowing the organisation to locate information quickly and accurately
- encouragement of awareness of the importance of records management to individuals by highlighting the business reasons/benefits within the management rules
- support for the records management policy by demonstrating a commitment to records management across the organisation
- empowerment of the records managers to challenge poor records management within the organisation
- provision of evidence to external authorities that deliberate and controlled management of file systems is encouraged by use of management rules
- translation of the record management policy into standardised procedures for staff to follow
This is not an exhaustive list of benefits, but gives an idea of how significant management rules are to the use of file systems for records management.
Management of metadata
Within the context of a formal ERMS, metadata is used to provide data about records and folders (details on how long a record should be kept, or determine who may access the record). This metadata is often used by the ERMS to drive functions such as access controls and disposal rules. In contrast most of the metadata presented within a standard operating system is only informative and cannot be used for active records management.
It is possible to configure the system so that when a user captures a record they are presented with the ‘Properties’ view for the record. This is a visual prompt for the user to enter some meaningful metadata that can be used to manage the records. In practice this process cannot be mandated and user can still enter meaningless information in if they so choose.
Example:
This example illustrates the limitations of metadata as displayed in a MS Windows file systems. Within MS Windows explorer the ‘General’ properties tab (circled) displays the following metadata. This metadata is only providing a view of metadata generated by the operating system. In practice metadata presented in a file system is not completely robust for the following reasons:
- a change such as renaming the record or relocating it is recorded in the ‘Accessed’ date time field, but not in the ‘Modified’ date time field
- the field ‘Modified’ only records a change in the content of the Word document
- if the operating system is incorrectly configured or corrupt (if the server clock is inaccurate) any of the metadata regarding date and time will have no value
- if a record, or group of records, is moved to a new location, there is no audit of this action or any place to indicate a reason for a move if it is deliberate (unless a custom text field is developed)
- very little automated control to reduce human error because there is only a limited set of metadata (user access controls) linked to or enforced by the operating system
**Limitations of management rules**
Management rules do not provide a replacement for functional metadata. Even the most well defined and structured management rules have limitations. There are a number of reasons why they could cause problems and deter users from engaging in records management activities such as:
- not reflecting how the organisation’s business is conducted and preventing ongoing conduct of transactions
- requiring too much effort on managing records to the extent that the business of the organisation cannot be conducted
- not written or defined in a way that all users can understand them
- too prescriptive or rigid to engage users
- cannot be enforced in most standard file systems
These are just a few examples. Ultimately the rules rely on the goodwill of users to engage with them. This can be enhanced with a monitoring process by the records manager or selected individuals in local business units. If suitably empowered by the organisation they can help users to understand best practice and provide an immediate response to queries and problems. Write the management rules in consultation with users and in accessible language (Plain English). The rules must also be available through the most practical means so that users can quickly find them for reference (via an intranet or central record management resource, for example).
Users must be prepared to engage and work with the management rules and the file system to achieve records management. Once the rules have been established and agreed they must be enforced and followed if their benefits are to be realised. This will require some form of monitoring and process for reporting where the rules have not been followed so that the problem can be rectified and the user provided with information or training.
**Types of management rules**
There are likely to be a range of management rules that are specific to the organisation, particularly in respect of compliance with specific legislation. The following conventions are areas where management rules will be required for all organisations using file systems.
**Naming conventions**
Naming conventions help identify records and folders using common terms and titles. They also enable users to distinguish between similar records to determine a specific record when searching the file system.
Naming conventions need not be overly prescriptive or formalised but they must be clear and well defined. Names for records must be meaningful, and convey an idea of the content. Records and folders with a meaningful title based on naming conventions also allow efficient records management judgements to be made without having to explore the content of each individual record.
Without naming conventions there is a significant risk of records being destroyed or lost within the file system. Without standard approaches to naming folders the context of the records becomes meaningless to anyone other than the creator.
Organisations should ensure that sensitive information is never used in the name of a record or folder even where access to the area of the file system is strictly managed. This is to ensure that personal or sensitive data cannot be inferred by casual viewing of a record or folder title. The use of pertinent security or protective marking information should also not be included in the title of an object. Use of terms such as ‘Confidential’ could imply a level of sensitivity that would compromise the content of the record or folder by advertising this in the object’s name.
In practice certain records and folders have to include sensitive information. Considered application of appropriate access controls should mitigate accidental disclosure of sensitive information to anyone other than an authorised user.
**Naming conventions for emails**
There must be specific guidance on naming conventions for emails. When emails are captured from the email client (such as MS Outlook) into a file system they are automatically named using the text in the ‘Subject’ field of the email. As a result, the prefixes ‘RE:’ for replies and ‘FW:’ for forwarded emails may be retained. Remove these to ensure that the title of the record is clear about the purpose and content of the captured email.
In practice email capture is likely to require more detailed guidance as several emails might be captured as part of a longer communication. If all these emails are captured and given the same name, the context and reason for capturing will remain unclear.
**Example:**
| Name | Size | Type | Date Modified | |----------------------------------------------------------------------|------|------------|-----------------| | Copy of New Record Management Policy sent to CEC.msg | 31 KB| Outlook Item| 24/08/2009 13:21| | New Record Management Policy for Comment.msg | 31 KB| Outlook Item| 24/08/2009 13:21| | Advice on where to publicise new Records Management Policy.msg | 31 KB| Outlook Item| 24/08/2009 13:09|
This example demonstrates the benefit of providing a meaningful title for each email.
Whilst requiring an investment from the user, they form a coherent set of records with discernable content and relationship to other records within the file system. Example:
This example illustrates the problem when users do not actively rename captured emails. There is neither understanding of what each email was created for, nor why it may have been captured.
**Naming conventions for folders**
The capture and management of all types of records into a file system requires careful planning and structure.
The reasons for providing naming conventions for folders are:
- to ensure consistency of approach in terminology and format for specific activities, such as casework
- to provide all information within a file system with a coherent context and logical frame of reference
- to provide users with a practical means of identifying where records should be captured within any given part of the file system
As with the naming conventions for records (including emails) there must be management rules for users to follow when naming folders.
The rules need not be excessively prescriptive, but ensure that the length of the folder name is not too long. It can become difficult to search and retrieve accurately for folders lower down the filing structure. Example:
This example illustrates some of the benefits of providing meaningful titles within the filing structure:
- the hierarchy of the structure is clearly identifiable by the titles of the folders
- peer relationships between folders are clearly identifiable indicating a range of preferred locations for different types of record on a related activity
- at the lowest level of folders (outlined in the box) it is clear what is expected to be captured into each folder
Example:
This example shows a file system where there are no management rules applied to folders. The hierarchy gives some idea of the filing structure, but lack of consistency in naming the folders makes it very difficult to understand the whole structure and where to find specific records.
The folders for records (outlined in the box) provide no means of identifying their content or what should be captured into them. In such a filing structure records management would be impossible and places an organisation at a significant risk of information loss. Version control for records
The means of indicating a current version of a record in any system is difficult. Management rules can aid this and allow users to name the record indicating the current (and previous) version.
Example:
This diagram illustrates the simple addition of ‘1.0’ to indicate the draft status of a record. If an organisation adopts this simple approach and uses small decimal increments to indicate minor revisions and whole numbers for a major revision, all users can quickly identify which is the current draft or final version.
Example:
This example illustrates the addition of a simple decimal system for indicating minor and major changes in the version. In this case ‘whole’ versions of the document are named using 1.0 or 2.0. Interim drafts are named 1.1, 1.2 and so on.
This is considered best practice, but organisations might use other version numbering for records such as technical drawings. Irrespective of the naming conventions used they must still be explained clearly within the management rules. Example:
This example illustrates a further suffix added as a one word statement - ‘draft’ - reinforcing the version numbering and clearly identifying the record’s status. Where used, control and monitor these terms for consistently. Any lists of controlled terms must be reviewed, and updated, at regular intervals.
Used correctly these ways of indicating a record version will provide a clear idea of the drafting process and which record is the current one.
Example:
This example shows the consequence of having no management rules for version control. There is little coherent information identifying versions and their relation to the others. This could have a significant impact on records management activities such as disposal, and will also limit the ability to locate and retrieve the current record efficiently.
To remain effective either a records manager or a local authorised user should monitor the use of naming conventions. The introduction of rules on the creation of version controls really only works where the business recognises a real need for these conventions. If not, they are rarely used and become redundant.
Format of dates
It is very likely that users will want to manage some records, and the folders they are located within by date. Given the range of ways of writing the date, the organisation must choose a standard format for all users to follow. This will aid structuring of folders and improve the ability to retrieve information when searching.
The most practical way of using dates is in the format Year-Month-Day or 2009-08-21. This is a standard format which allows for easier searching. This is because when searching for older records a user is more likely to know the year, and possibly the month, when a record was created than the exact date.
**Where can I learn more?**
These examples are included because they reflect best practice as a list of rules. Not all will be suitable for every organisation; management rules should be developed in consultation with users and appropriate to the size, sector, culture and resources of the organisation.
- The Financial Services Authority records management policy and standards – RMPS: [www.fsa.gov.uk/pages/information/pdf/records_policy.pdf](http://www.fsa.gov.uk/pages/information/pdf/records_policy.pdf)
- Record Management Society RM toolkit for schools: Creating information management systems: [www.rms-gb.org.uk/resources/848](http://www.rms-gb.org.uk/resources/848).
**Record Management Code of Practice reference**
- [www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm](http://www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm) Access control management
What are access controls?
Access controls determine who can access/capture records and access/create new folders. The allocation of access controls allows an organisation to delegate responsibility for records and folders to their creators and managers. This accountability helps to ensure that records remain authentic and reliable, retaining their integrity and usability.
In a modern records management environment access controls within a filing structure are set to as wide (or open) a state as possible. This means that unless a specific reason can be applied, records and folders should be accessible to all parts of an organisation as a default. This reduces the overhead of managing access controls and it also improves the effectiveness and efficiency in information sharing.
Some organisations may provide users with personal drives to store records such as copies of staff appraisals or annual leave requests. Where used these should be restricted in size to prevent users turning them into personal storage areas for business records.
Personal drives have to be restricted to genuinely personal information. They must not be used for storing business records which may be sensitive and require access controls while still sitting in the filing structure (with appropriated limited access controls).
These personal drives are not recommended for storing business records; the rest of this chapter is directed at access management within open shared drives and the filing structure.
Most organisations will already have user profiles that give all authorised staff an email account and access to the file system. Typically this profile also gives access to a personal drive (individual space on the file system) and one or more areas of the file system (sometimes referred to as ‘Shared Drives’). Example:
This example illustrates the ‘Security’ window for a folder in a MS Windows file system. The list of ‘Groups’ and ‘Users’ indicate who can access the folder. Those listed have the power to add or remove other users to control access as required. Additionally the administrators can refine the ‘Permissions’ further to indicate what a user can do within this folder, such as capture new records or create a new folder.
Organisations may wish to create a number of profiles to reflect the level of functionality available to certain users. A typical end-user’s profile will look similar to the above example but some of the ‘Permissions’ might be set to ‘Deny’ to limit what they can or can’t do in particular parts of the filing structure.
Using these basic controls an organisation can begin to form access controls across the filing structure. These can be used to keep as much information as open as possible and appropriate, whilst also ensuring sensitive information is kept secure. Setting up access controls
Access controls can be set at three levels within a file system - at drive, folder, or record level.
Allocating access controls by individual user requires substantial effort and it would be difficult to monitor or track. Development of access groups reduces this overhead substantially and it can improve the controls placed on any part of the filing structure.
This can be a very useful means of applying quick access (or denying it) to a part of the filing structure by an administrator. However it is potentially limited if an organisation is located over several sites using individual Local Area Networks (LAN). Whilst the filing structure may be represented in all locations, they will not all be updated if access controls are updated. This would require every individual network to be updated to ensure a consistent application. Organisations that use a Wider Area Network (WAN) will not have this problem.
Example:
This example illustrates how access groups can be used to granulate access to the filing structure. In particular, the ‘Finance’ folder and lower folders need specific access controls. An access group called ‘Group A’ is created and granted sole access within ‘Finance’. This Group contains all users who are permitted to see and access the ‘Finance’ area.
Below ‘Finance’, the ‘Contracts’ folder requires an even greater level of access control and a sub-set of ‘Group A’ users is selected to form ‘Group B’. Using this process an administrator can vary and allocate access controls more efficiently than if they had to select each individual user. By maintaining memberships of access groups instead of individual access to every record and folder the overhead of managing access controls can be reduced significantly. Whilst file systems work better when configured at the highest permissible level for both folders and records, it is possible to restrict access to individual records and folders. This should not be considered in normal access control allocation. There is the risk that the information will become lost and inaccessible to the organisation if that user leaves (temporarily or permanently), or moves to another business unit.
Successful application of access controls does not rely solely on the creation of appropriate groups. If the filing structure itself has not been constructed in a coherent way it could become very difficult for an administrator to ensure that correct access is being applied across the file system.
**How do access controls aid records management?**
As a file system lacks much of the automated functionality of an electronic records management system, access controls are one of the few means of formally regulating changes to the filing structure and records.
Access controls help control how and where information is created and accessed. Such controls can help to:
- restrict the number of users who can change or edit records and folders
- reduce the number of users who could inappropriately delete, alter, or relocate sensitive information
- identify and allocate responsibility for records and folders within sensitive areas of the filing structure
Locally appointed record managers, where available, can be given a local administrator profile for a relevant part of the filing structure. This still limits the number of users who can edit access controls, but improves the efficiency with which changes can be requested, made and monitored at a local level.
Any local administrator should work with and be managed by a records manager to ensure consistent governance is applied across the filing structure. Limitations of access controls
There are a number of factors that should be considered when implementing access controls within a file system. A file system does not offer the granularity or ease of use with access controls as a dedicated electronic records management system might.
Complex access control models
It’s easy for access controls to become complicated and difficult to track. To prevent this developing into a significant management overhead keep access controls as open as is practical (so that all users can see but not edit records and folders). This means keeping as small a number of access groups as is required and actively managing them, reviewing and updating them regularly.
Documenting this process is likely to be difficult. Although the server will retain a log of access groups, this may not be presented for easy review. Where an organisation develops access groups they will need to ensure that this is documented externally from the file system to allow review by records management staff.
In complex organisations with a pre-existing access model for paper files, the organisation may view this as a useful referral tool when allocating access to related electronic records in the filing structure. This will not be an exact match but may help with consistent allocation of access.
Monitoring access control allocations
The monitoring and regulation of access controls can be a time consuming process. This is exacerbated by the fact that a record manager cannot always independently decide whether appropriate access has been given. A management rule must be used to ensure that users are added (and removed) to access groups by a records manager (or network administrator) only upon request from another authorised user.
Any user who has full access to a folder or record (to edit or delete content) can also change the access controls if they know how. This could result in other users being ‘locked out’ of folders or records inappropriately. This type of behaviour must be monitored carefully. For this reason avoid individual access controls as far as is possible. Changes to the structure of the organisation may also affect specific access controls where users move from one part of the business to another. The organisation will need to ensure these changes are logged so that an authorised user can update access controls appropriately.
The same action would also be required when a user leaves the organisation. Their IT profile must be deleted to prevent anyone from accessing the file system using the account.
**Other access controls**
A feature of MS Windows file systems is the ability to protect both records and folders with a password. This prevents anyone other than the user from accessing the object, and circumvents the organisation’s access controls. Either switch off this functionality or actively discourage it. Passwords are either too simple to offer any real security or they are forgotten. In either case the security of the document is reduced and the organisation risks losing control of its information.
Similarly if a user leaves without disclosing relevant passwords there is a risk the organisation will not be able to change the passwords. Immediate access becomes an issue and it presents a challenge for digital preservation. Scaled preservation operations that convert records to another format can be hampered significantly.
For these reasons we advise that any reliance on password controlled access should be replaced with alternative access mechanisms.
**Operational limitations**
A related issue is the creation and maintenance of user profiles on the file system. Usually this is only carried out by the IT function within an organisation (or an external IT provider). When changes are made (a new user is added, for example) there must be clear communication between the IT staff and those responsible for records management to ensure the user is able to access the filing structure as appropriate.
**Where can I learn more?**
The implementation of access controls and configuration of folders within the filing structure to support them will require significant IT support. We recommend that the experience and knowledge of the IT function is used to help create a usable and secure environment. If no such function exists then the organisation will need to consider seeking external advice on this subject.
**Record Management Code of Practice reference**
- Guide 7: Security and access
- [www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm](http://www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm)
**Disposal policy and management**
All organisations irrespective of sector or size need a disposal policy and process to prevent retention of records no longer required for business purposes.
**What is a disposal policy?**
A disposal policy is a formal statement by an organisation on the appropriate means of disposing of records to agreed disposal schedules(^4). It should indicate how long records should be kept and whether they should be destroyed or transferred to another organisation once they are no longer required for business purposes. The policy may form part of the overall records management policy, or it may be a separate document that forms part of the suite of supporting guidance along with management rules for example.
Additionally the policy will need to be supported by disposal schedules that identify types of records and provide the detail on how long they should be kept for and whether they should be destroyed or transferred to an archive(^5). The process of disposal supports legal obligations, such as destroying collected personal data when it is no longer required.
**What is disposal management?**
Disposal management is the formalised process of assessing records to determine how long they should be retained and how they should be removed from the file system. The removal
______________________________________________________________________
(^4) Sometimes referred to as retention schedules
(^5) Transfer to an archive is likely to be an issue for only a small proportion of an organisation’s records Managing digital records without an electronic record management system
should be based on the established disposal schedules and follow an agreed process for either destruction or transfer.
In normal circumstances records are disposed of by aggregation or collections of records in folders. Disposal of individual records is normally to be avoided because of the overheads in selecting and deleting individual records. Disposing of aggregations of records is far more efficient and ensures a greater security that related records have been disposed of correctly. This is important in a file system where there are no formal disposal management tools (which are available in an ERMS).
The disposal process should include appraisal of records to understand their current context and content to decide whether they can be removed from the file system. This is important as some records, while due for disposal under an allocated disposal schedule must be kept for another purpose such as a legal investigation.
For this reason disposal management should never be a fully automated process. Even if a record manager is confident that types of records routinely created (such as meeting minutes) could be disposed of, there should still be a means of checking whether they must be retained for a reason other than their original purpose.
Records should never be disposed of on an ad hoc basis or at the discretion of individual users unless there is a specific reason such as:
- it is a duplicate record not required to support the business
- it wasn’t needed to be captured as part of the corporate record (such as a casual email correspondence)
- it is an early draft that no longer reflects or aids the development of a final record
This process must be supported by clear management rules and be monitored by the records manager.
**How does disposal management aid records management?**
In essence, without a controlled disposal management process defined by a policy and supported by disposal schedules, the organisation risks losing control over how many records are held indefinitely, taking up valuable storage space. The disposal management process helps reduce this risk by:
- reducing the volume of out of date records no longer required for business purposes
- ensuring that personal data is not retained beyond its intended purpose
- improving the efficiency of a file system by freeing up space on servers
It will be difficult to support this process in a file system, but it can be aided significantly by:
- grouping activities together to reduce the overhead in searching and reviewing types of record due for disposal (for example, financial transactions)
- closing folders with a clear time limit where it suits the business process and opening new ones (at the end of a financial year or project, for example)
- using naming conventions to help readily identify types of records
- introducing a custom metadata field ‘Properties’ in the folder or record that allows users to allocate the correct disposal schedule
**Limitations of disposal management**
Disposal management as a process is not supported by a file system without specific records management software. This makes disposal management a very difficult process to control within the file system for the following reasons:
- disposal activities have to be done manually including allocation of a disposal schedule, executing it and recording the event
- users might not provide disposal information consistently in a custom metadata field (where available)
- audit data is not readily available because actions occurring in the file system are recorded in one long list in server logs
- a typical server log does not provide specific reports of record deletion without a bespoke PERL script and it will not be accessible to record managers without IT support Some organisations may wish to configure the filing structure so that only authorised users can delete or remove records and folders. Take great care with this approach as it can become unmanageable.
However an organisation decides to control disposal it should be designed in consultation with users. If the file system (and filing structure) is configured too rigorously users may disengage from it altogether leaving the organisation exposed to considerable loss or mismanagement of information.
**Where can I learn more?**
- The National Archives advice on retention and disposal: [nationalarchives.gov.uk/recordsmanagement/advice/schedules.htm](http://nationalarchives.gov.uk/recordsmanagement/advice/schedules.htm)
- Andrew C Hamer, The ICSA guide to document retention: [www.icsabookshop.co.uk/disp.php?ID=633](http://www.icsabookshop.co.uk/disp.php?ID=633)
**Record Management Code of Practice reference**
- [Guide 8: Disposal of records](http://www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm)
- [www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm](http://www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm)
**Email management**
**What is email management?**
Email is the primary correspondence tool of communicating information within an organisation, between businesses and with members of the public. For any organisation, a failure to manage emails indicates a failing in records management generally.
The scope of this guidance does not extend to all aspects of email management such as establishing protocols for responding to emails, sharing mailboxes or other functionality provided by email clients such as MS Outlook. This section covers the management of emails as records and the means of ensuring they are captured and managed so that they are accessible and usable to all relevant parts of the organisation. Unless stated this guidance refers to the use of all types of mailboxes; specifically those used by multiple users (shared mailboxes) and individually managed mailboxes. The issues arising from the use of either type of mailbox are comparable. An email is often perceived differently from other formats of electronic record (such as a spreadsheet or text file). As a result users do not always manage emails with the same consistency as they might other records. In practice an email is no different to any other electronic record containing content and metadata and is as unique as a text document or spreadsheet produced with any proprietary software application.
Organisations must train users in how to distinguish between the emails they need to capture for business purposes and the ephemeral communications. The difficulty of this task will vary depending on the volume, content and type of email an organisation or individual receives and produces.
**How does email management aid records management?**
The ease of composition and transmission of email means that a large number of emails can be created very quickly. This volume can become unmanageable and create a significant risk for the organisation. Capturing emails from an email client into a filing structure helps to place this information in context with other related records. It also ensures that all records, irrespective of format, receive the same level of management in terms of disposal scheduling.
**Example:**
| Name | Date Modified | Type | |------|---------------|------| | Copy of Record Management Policy to CEO for approval | 24/03/2009 13:21 | Outlook Item | | Invitation to comment on Draft Record Management Policy | 24/03/2009 13:21 | Outlook Item | | Records Management policy - 1.2 - Draft.doc | 24/03/2009 09:52 | Microsoft Office Word 97 - 2003 Document | | Records Management policy - 1.3 Draft.doc | 24/03/2009 09:51 | Microsoft Office Word 97 - 2003 Document | | Records Management policy - 2.0 Consultation Draft.doc | 24/03/2009 11:17 | Microsoft Office Word 97 - 2003 Document |
This example illustrates the value of capturing emails into the filing structure. Not only can a user see the full process of draft developments but they can also see related communications and build the full picture of this particular activity. To help users understand this and to ensure important emails are not kept in mailboxes, an organisation will need to develop the following:
- management rules that provide clear direction on which emails should be captured out of mailboxes into the filing structure
- training for users to recognise emails as records that need to be captured and managed like all other types (or format) of record
- functional limits to mailboxes to control the amount of emails that a user can keep for any period
**Management for rules for email**
Management rules for emails depend on other factors outside of records management. These are related to the business process behind responding to and creating emails and include:
- email etiquette, appropriate language
- management of email strings (separate emails for separate subjects)
- titling of the email ‘Subject’ field to ensure the reason for communication is clear and re-titling it if the string changes subject
- acceptable circulation methods of emails (only include those who need to know, for example)
- circulation of links or references, rather than proliferating uncontrolled copies of documents of unclear status
Emails left in mailboxes are of limited use to the wider organisation, not only in terms of conducting business operations, but because they remain inaccessible and cannot be managed corporately.
Training and technical responses to this problem are a necessity but an organisation must also document a preferred formal process for email management. This does not have to be a lengthy detailed document, it could be a short list of ‘do’s and ‘don’t’s for capturing and managing emails. Rules will depend on organisational need and the content of the email itself. The management rules should include:
- what type of email should be captured from a mailbox (for example, a decision or a formal request for information or assistance)
- which user is responsible for capturing a record (such as the sender who circulated meeting minutes)
- when an email should not be captured (as in the case of personal correspondence or general circulars or organisation wide memos)
- how emails should be titled when captured into the file system (renaming emails that contain ‘RE:’ in the title to indicate the content/purpose the response was captured) how to manage any attachments
which file format for capturing emails, such as an .MSG not .PST (this can relate to managing attachments)
responsibility for a shared mailbox, where used. This will depend largely on the number and use of shared mailboxes within an organisation
This is not an exhaustive list and other rules relating to management of casework processing or specific types of transaction management may also be needed.
It is not necessary to develop these management rules in isolation from those for other types of record. If the rules highlight any unique problems with email management (such which emails should be captured from a long exchange and by whom) they can be incorporated into the broader set of rules developed. This approach would help provide continuity for users in their understanding that records can be produced in many formats and are not restricted to a particular type of electronic record.
Guidance for email management
The rules for email management must be supported with guidance and training. The training should include:
- an explanation on the importance of capturing emails
- instructions on how to capture emails from the email client into the filing structure, including preferred file format for capture
- how to decide which emails should be kept and who should capture them
- an instruction on regular review of mailboxes to delete, unnecessary emails
- how to manage emails in a shared mailbox to ensure emails are captured into the filing structure
Email formats
Capturing emails from proprietary email clients into a file system requires some attention to the file format the email will be captured in. Depending on the email client the email may be presented in its own unique format to support the style and functionality of the email client. Example:
In this example there are six possible formats which the file system will allow the email to be ‘saved as’ or captured. Not all of these formats will preserve the email in a way to ensure it retains its characteristics as an email and an authentic record.
For example ‘.html’ will create a significantly smaller file of a captured email (as much as 50% in size). This reduces the storage used on servers but the usability, attachments (only a text header indicating their existence remains) and some metadata within the email are completely lost. The result is a version of an email record being captured that is unusable by the organisation and a potential loss of business critical information. Conversely the Outlook Message Format (\*.msg), not only remains usable but the presentation of the format would demonstrate an accurate and authentic representation of the email as a record.
The organisation must also take into account potential file format obsolescence if the email client were to be changed or updated significantly. Older or bespoke email formats are less likely to be supported by a newer email client. This could render the email unusable, or only viewable through a bespoke software application.
Where organisations use other email clients (other than MS Outlook), it cannot be assumed that emails can simply be captured within file systems without loss of information and functionality. The issue is ensuring the logical integrity of emails following their capture so that they remain accessible and fully usable within the designated location.
A very real concern is maintaining access to attachments. The most common are MS Outlook but Novell GroupWise and IBM LotusMail have a broad consumer base. There are many other email clients in use including CC Mail and Eudora. Generally, apart from MS Outlook, these other email clients do not support capture of an email, with its attachments, into a file system without some information loss. There is a risk that emails will be kept in a format which is either wholly unusable or partially unusable. It is essential to undertake research at an early stage to determine the most appropriate method and storage format for maintaining emails within the filing system, while ensuring the emails remain usable and attachments accessible. For example, a decision is made to capture emails originating from an email client such as IBM’s Lotus Mail in a text format (.txt). This particular product cannot provide a file format that retains the email with attachments present outside the email client. As a result the emails are readable but any attachments are lost. With emails used as carriers for single or multiple attachments, the adoption of such a format could result in the loss of information important to the organisation; the attachments are often of greater significance than the text of the email.
It is critically important that any decision to adopt an alternate format should be taken in full knowledge of the consequences. This decision should be preceded by appropriate tests, using emails both with and without attachments to confirm the functionality of the chosen format.
**Retaining emails within the email client**
Where there is not a suitable technical solution (or alternative file format) organisations should consider creating a mirror of the filing structure within the email client. This structure would consist of a set of shared folders and would be subject to the same naming conventions and access permissions applied to the main filing structure. Emails required for capture would be relocated into the appropriate mirrored folder within the email client. Users would need training to search both the filing structure and email folder to ensure they have found all the relevant records relating to a specific subject or activity.
**Example:**
| Filing Structure | Email Mailbox Structure | |------------------|-------------------------| |  |  |
This example shows the filing structure and the mailbox structure designed in tandem providing a means of relating emails, graphically in shared mailboxes, to other records in the file system. whilst held in the email client. Duplicating the filing structure in this manner constitutes an additional overhead as both structures will have to be maintained in tandem, but in some circumstances this may be the only viable option. Further sources on email management are provided in ‘Where can I learn more?’ at the end of this section.
**Limitations of email management**
There are a number of limitations to capturing emails into a filing structure. These limitations can be categorised under three broader issues. Each issue is expanded below, but all three are often tightly interlinked and dependent on one another.
**Volume**
Perhaps the most significant limitation caused by email is the ever increasing volume generated and received by an organisation. Depending on the organisation, and a given user’s role, a mailbox could be subject to a significant amount of traffic. In such circumstances the decision of what to capture and what is simply ongoing correspondence becomes a difficult judgement to make.
Users might leave emails in a mailbox until it is either full to capacity (thus forcing them to address the issue in order to be able to receive and send emails again) or wait until they have time to resolve the problem. In either circumstance the result can be that email records are not captured into the filing structure with related records and are consequently unavailable to anyone searching the filing structure for all the information they require.
**Time**
The second limitation is time. The process of creating a draft record using a word processing application requires the action of ‘saving’ it. This is not a required process in creating an email so users can create and send emails with little time taken, unlike creating and saving other standard records on the file system. Capture of emails into the filing structure requires users to take time out to do this as a perceived extra action.
**User convenience vs organisational risk**
Storing emails in a personalised structure of an email client as opposed to capturing them within the filing structure provides users with an appealing level of autonomy; they can keep business emails within their own mailbox where only they can see them. This can result in emails being treated as an individually owned asset within the user’s mailbox rather than a corporate asset (which should be captured into a relevant location in the filing structure with record management controls applied and access shared).
The simplicity of automated functionality in email clients (automatically storing a sent copy of an email, for instance) removes the user’s responsibility for ensuring an email is kept and is retrievable; the email client is seen as being responsible. Users tend to prefer to retain emails in the email client rather than invest in the effort of capturing emails into a filing structure.
A well designed filing structure, training and management rules can mitigate this attitude but each organisation must accept that a significant proportion of emails are likely to remain in a user’s mailbox until the business has been concluded.
Some basic functionality can also help drive compliance and the capture of email. Many email clients allow limits to be placed on the size of a user’s mailbox(^6), forcing users to address the problem or be unable to use their email until the backlog is cleared.
This could have a significant impact on daily work (such as processing transactions) and an alternative solution such as ‘auto-deletion’ after a set date (three months, for example) might be preferable. This approach makes users consider capturing emails into the filing structure more frequently. It also contributes to providing an organisation with a level of compliance with the fifth Data Protection Principle by ensuring that personal data is not retained unnecessarily (names, email address, or personal details listed in the email content).
Both of these approaches are not without limitations. Users may simply choose to drag and drop a large number of emails from a mailbox into a folder within the filing structure to circumnavigate storage limits or auto-deletion. This can only be controlled by management rules unless significant technical expertise is available to customise the file system that prevents such an action. In the event that either method is chosen, the organisation should conduct a risk assessment and develop a policy to support why it is doing this. This may form part of the records management policy or support it as a separate email management policy.
(^6) For MS Outlook the limits are actually controlled on the Exchange Server where each user’s email profile is defined and stored The policy should allow sufficient time to pass before the ‘auto-deletion’ removes the email. This gives users enough time to assess emails for capture before they are permanently deleted.
**Alternative email storage**
There are a range of means for storing email outside the filing structure. This section considers the bulk storage of emails in a near or offline email archive including their potential benefits and risks.
**Bulk email archive storage**
An attractive proposition for storing large volumes of email is to bulk archive them in a near-line or offline server with a search interface for retrieval using a commercial email archiving solution. These products provide organisations with a means of storing large volumes of email in a compressed form increasing the capacity available on a server. The benefits of bulk archiving options are:
- a reduction in IT support overheads trying to maintain a large volume of emails on a live email server
- a reduced cost for server storage (bulk archives are cheaper than expanding live email server)
- a single interface for searching all emails archived, accessible to all authorised users
Most commercially available email archive solutions used coded management rules within the applications that do not represent good records management as practised in the UK.
In particular the method of classifying emails within the archive is based on criteria such as automatically assigned keywords or date of last retrieval. Whilst potentially useful this information does not present the context or purpose of the email to a user when they are trying to retrieve specific emails from the archive. Further risks are:
- storing high email volumes which mean poor search returns from the search interface (insufficient search criteria are available from the archive solution)
- not enough detail known about the email to create an advanced search to narrow the possible returns when investigating the email archive
- record management rules cannot be applied within the archive solution
- access controls dependent on the design of the application which may not reflect the access controls as established within the filing structure, resulting in a potential security breach
- disposal management dependent on the design of the application which will not usually reflect that of the filing structure or organisations disposal policy
- complete aggregations of records cannot be confirmed until the archive has been thoroughly searched
A further issue with these types of archive is that the emails are usually bundled into a large compressed file which removes any relational context of that email to both other emails and records stored within the filing structure.
**Bulk email archive file format**
A further risk of bulk email archiving using MS Outlook email client is that the emails are often stored in .PST files. These are, effectively, a randomly bundled collection of the emails which is then compressed for storage savings. Other email clients will support a similar process. These bundled files are not stable even when stored in a designed email archive solution. Corruption of an email stored as a .PST file is significantly exaggerated as it is in a compressed form. This could cause irreversible loss of data, possibly without the knowledge of the organisation.
Organisations wishing to bulk archive emails must ensure that the system is sufficiently robust and coordinated so that these risks are either eliminated, or at a level they find acceptable. Irrespective of this decision, the organisation should still produce and endorse a policy of storing critical emails within the filing structure to ensure it is available.
**Where can I learn more?**
**Email Management**
- Guidelines on developing a policy for managing email: [nationalarchives.gov.uk/documents/information-management/managing-emails.pdf](nationalarchives.gov.uk/documents/information-management/managing-emails.pdf)
**Record Management Code of Practice reference**
- [Guide 4: Keeping records to meet corporate requirements](#) Integrating management of paper records
Most organisations using this guidance will probably have an existing paper records system. There is a temptation to replicate this system within a file system as it is familiar to the users, can be implemented quickly, and is potentially cheaper than starting from nothing. For some smaller organisations or discreet business units this can be a cost effective and efficient means of building all or part of a filing structure.
It is not always appropriate or meaningful to organise electronic records in the same way as paper records so consider any such initiative carefully. Before looking to replicate any part of a paper filing system in a filing structure the organisation must assess if it is fit for purpose in its current state.
Case Study:
The paper filing system is well maintained and has been developed over time to provide users with easy access to records by function or activity. The supporting finding aids are readily available and up to date. As a result any user could search for and retrieve paper records with minimal impact on efficiency.
Owing to the success of this approach it is deemed helpful that in outline the filing structure in a file system is designed along similar lines with a view to keeping as much information open as is both practical and sensible.
This case study identifies how a paper system could be used as a template for the filing structure in principle. Case Study:
The paper filing system in an organisation has developed organically with little or no controls, users and business units are left to devise their own preferred ways of filing paper records with no corporate approach or requirement for current finding aids. As a result only users from within that part of the organisation could search for and retrieve paper records.
In a bid to reduce costs each part of the organisation ‘copies’ their paper filing structure into a filing structure on the file system. This leads to an impossible system whereby users are unable to locate or retrieve any electronic records where they do not have specific knowledge of that part of the filing structure.
This case study identifies how poor planning and management of paper records, copied into an electronic environment, will frustrate users trying to identify where to capture or retrieve records from. It will also lead to a failure in the filing structure as a whole.
In some circumstances an organisation may choose to use the filing structure to record details about related physical records using a simple text file as a place marker. Alternatively where a physical record tracking system is in place it may be beneficial for the organisation to align this with the filing structure (to mirror it) to present a consistent view of the organisations records irrespective of format.
Where can I learn more?
Storage of paper records
In addition to managing the alignment of paper and electronic records an organisation needs to consider how it stores the paper records. Specifically it should consider:
- identifying and categorising the records to ascertain their use, content and volume
- developing and managing a disposal policy concurrent with that of the electronic records held in the file system • specifying and managing access to the paper records, including any offsite locations • identifying the usage of the paper records to establish frequently accessed records which may need to be stored more centrally • tracking and management of the custody of paper records when held in a file store or at a user’s workstation • assessing the most suitable means of storing the records to ensure they are accessible and not at risk from environmental or accidental damage • development of auditing and reporting on the use, access and disposal of the paper records
These activities will help the organisation ensure its paper records are well maintained and managed to the same level as the electronic records within the file system. More information is available in guidance produced by The National Archives:
• Identifying and specifying requirements for offsite storage of physical records: nationalarchives.gov.uk/recordsmanagement/requirements-offsite-store.htm
Record Management Code of Practice reference
• Guide 4: Keeping records to meet corporate requirements • Guide 6: Storage and maintenance of records • Guide 7: Security and access • Guide 8: Disposal of records • www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm Further reading
General Records Management Guidance
- The National Archives Guidance on records management: nationalarchives.gov.uk/recordsmanagement/advice/default.htm
- The National Archives Guidance on electronic records management: nationalarchives.gov.uk/information-management/guidance/e.htm
- The National Archive Guidance on digital continuity: nationalarchives.gov.uk/information-management/our-services/digital-continuity.htm
- Records Management Society guidance: www.rms-gb.org.uk/resources
- Information Commissioner’s guidance: www.ico.gov.uk/tools_and_resources/document_library.aspx
- JISC guidance on records management: www.jisc.ac.uk/publications/documents/pub_rmibp.aspx
- JISC Infonet infokit on records management: www.jiscinfonet.ac.uk/InfoKits/records-management
Useful Publications
- Managing digital continuity: nationalarchives.gov.uk/documents/information-management/managing-digital-continuity.pdf
- Jay Kennedy and Cheryl Schauder, Records management, a guide to corporate record keeping (second edition, 1998)
- Elizabeth Shepherd and Geoffrey Yeo, Managing records a handbook of principles and practice (2003)
- Effective records management. A management guide to the value of BS ISO 15489 (British Standards Institute, 2002) This is a four part guide www.bsigroup.com/ Standards and Codes
- Revised Records Management Code of Practice (2009): www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm
- ISO 15489-1: 2001 Information and documentation – Records management: www.iso.org/iso/catalogue_detail?csnumber=31908
- ISO 23081-1: 2006 Information and documentation - Records management processes - Metadata for records: www.iso.org/iso/catalogue_detail.htm?csnumber=40832
Legislation
- Data Protection Act 1998, Chapter 29: www.ico.gov.uk/for_organisations/data_protection_guide.aspx
- Freedom of Information Act 2000, Chapter 36: www.legislation.gov.uk/ukpga/2000/36/contents The Environmental Information Regulations 2004, SI No. 339: www.legislation.gov.uk/uksi/2004/3391/contents/made
- Public Records Act 1958 Chapter 51: nationalarchives.gov.uk/policy/act/default.htm
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b5375632dc2e0819c2c863f5af59b201fc12481c | Managing digital records without an electronic record management system
© Crown copyright 2012
You may re-use this information (excluding logos) free of charge in any format or medium, under the terms of the Open Government Licence. To view this licence, visit nationalarchives.gov.uk/doc/open-government-licence or email [email protected].
Where we have identified any third-party copyright information, you will need to obtain permission from the copyright holders concerned.
This publication is available for download at nationalarchives.gov.uk.
## Contents
| Section | Page | |------------------------------------------------------------------------|------| | Introduction | 4 | | Purpose | 4 | | Audience | 5 | | Scope | 6 | | Definitions | 7 | | Records management policy | 10 | | What is a records management policy | 10 | | How does the policy aid records management? | 11 | | Where can I learn more? | 13 | | Filing structures | 14 | | What is a filing structure | 14 | | How does the filing structure aid records management? | 16 | | Constructing the filing structure | 17 | | Where can I learn more? | 21 | | Management rules | 22 | | What are management rules | 22 | | Monitoring and maintenance of management rules | 24 | | How do they aid records management? | 25 | | Management of metadata | 25 | | Types of management rules | 28 | | Naming conventions | 28 | | Version control for records | 32 | | Format of dates | 33 | | Where can I learn more? | 34 | | Access control management | 35 | | What are access controls? | 35 | Setting up access controls ........................................................................................................... 37 How do access controls aid records management? .................................................................. 38 Complex access control models ................................................................................................. 39 Monitoring access control allocations ....................................................................................... 39 Other access controls .................................................................................................................. 40 Operational limitations ................................................................................................................ 40 Where can I learn more? .............................................................................................................. 40 Disposal policy and management ............................................................................................... 41 What is a disposal policy? ............................................................................................................ 41 What is disposal management? .................................................................................................... 41 How does disposal management aid records management? ....................................................... 42 Where can I learn more? .............................................................................................................. 44 Email management ...................................................................................................................... 44 What is email management? ....................................................................................................... 44 How does email management aid records management? .......................................................... 45 Management for rules for email .................................................................................................. 46 Guidance for email management ............................................................................................... 47 Email formats ............................................................................................................................... 47 Retaining emails within the email client ...................................................................................... 49 Alternative email storage ............................................................................................................ 52 Bulk email archive storage ....................................................................................................... 52 Bulk email archive file format .................................................................................................. 53 Where can I learn more? .............................................................................................................. 53 Integrating management of paper records .................................................................................. 54 Where can I learn more? .......................................................................................................... 55 Further reading ............................................................................................................................ 57 Introduction
Managing electronic records presents a significant challenge for an organisation of any size or sector. For those that store their records in file systems (including shared drives), which have no formal controls in place, the risk of alteration or deletion makes this challenge even greater.
Organisations may have a well maintained paper records system but this is not necessarily appropriate as a template for managing electronic records. This is because of the volume of electronic records, and variety of file formats, combined with the ease of creation.
Electronic records management needs to be very carefully considered and structured to ensure the integrity of the records is not compromised upon capture and they remain retrievable for as long as they are required.
Purpose
The purpose of this guidance is to demonstrate how an organisation can improve the management of records within their file systems by:
- establishing a records management policy
- creating management rules and using them
- developing a classification structure
- introducing email management rules and version control
- establishing user compliance or buy-in
Without these an organisation is at risk of failing to manage records exposing them to risks including reduced business efficiency or potential legal action.
An organisation in control of its records can begin to realise significant benefits including:
- improved business efficiency and effective use of IT resources
- structured management of records retained for legal and regulatory purposes
- support of accurate capture and management of electronic records (irrespective of format) into the file system
- access to records to enable informed and effective decision making Managing digital records without an electronic record management system
- retention of a corporate memory of transactions, decisions and actions taken by, or on behalf of, the organisation
- protection of the rights and interests of the organisation (and others) who the organisation retains records about
- protection of the characteristics of records as defined by ISO 15489, particularly their reliability, integrity and usability
- identification of records required for permanent preservation and archive
Throughout this guidance there are examples using Microsoft Windows XP and Office 2007 (with Outlook). However this guidance is not limited to users of this platform and software applications and should be equally relevant to users of any desk based operating systems and office software applications.
This guidance replaces records management guidance previously published by the Historical Manuscripts Commission, and guidance on managing records in Office 97 published by the Public Record Office.
**Audience**
This guidance is intended for anyone who controls the management of records within any organisation or part of an organisation. This may be a formally adopted records management role, but it also includes those who manage records as part of their role such as medical or legal secretaries.
Smaller organisations, which do not have formal records management, can use this guidance to create a full programme for improving records management.
Larger organisations, which already have some form of records management, can use this document to develop records management where there needs to be significant consultation and development work.
______________________________________________________________________
1 Digital Continuity advice and Guidance from The National Archives is available where long term maintenance is a requirement. This guidance is principally provided for public authorities and addresses the equivalent long term issues of loss of completeness, availability and usability. This guidance is not restricted to any particular sector or industry. References to specific guidance are given as indicators of best practice in records management. Each organisation needs to consider its regulatory and legal environment which may dictate specific decisions regarding access and disposal of records.
Public authorities should read this guidance in conjunction with the Records Management Code of Practice revised and reissued under s 46 Freedom of Information Act, 2000. Useful references to sections of The Records Management Code have been included in ‘Where can I learn more?’ where appropriate.
Scope
The focus of this guidance is the management of records stored within a file system using existing infrastructures and resources. It will discuss the process of defining an organisation’s need for records management based on the development of a policy and supporting guidelines for users.
Other types of ‘basic content services’ that offer some form of collaboration and informal document management might be used, such as Microsoft Office Sharepoint or Alfresco. They are not referred to in detail in this guidance. Such applications may support a subset of record management activities but an organisation still needs to develop and implement clear policies and management rules that will build an identifiable records management culture.
These products are rarely coded to implement records management rules without significant customisation and organisations should develop appropriate rules. They should evaluate solutions to support their implementation, managing the risk of records management failures. It may be that the procedures described in this guidance are preferable or alternatively that there is a clear case for deploying a records management application (or ERMS).
This guidance is not intended to be used as a technical manual, nor does it provide an organisation with a full set of policies and management rules. Use the guidance as a basis for best practice in the most suitable manner for their organisation. Inevitably there will be some technical discussion. This will be restricted to a level of understanding that enables the reader to discuss technical issues with IT or records management specialists where required.
The examples will use Microsoft Windows application suite (including Microsoft Outlook), and are for illustrative purposes only.
The guidance will not discuss use of content management systems nor website management tools.
In practice, organisations will be managing both paper and electronic records concurrently for a significant period of time. This guidance contains information on how the relationship between the two types of record may be managed.
It offers guidance on the management of physical records within an integrated environment but it does not extend to examining systems or applications (specifically for managing physical records such as a library system or tracking system which do not allow for accurate management of electronic records). There is further advice on this topic in a related piece of guidance Identifying and specifying requirements for offsite storage of physical records.
**Definitions**
This guidance uses some terms in a specific way:
**Aggregation**
Record assemblies existing within a filing structure (groups of folders) or a folder containing records. In a file system aggregation is limited to folders that contain folders and folders that contain records.
**Business classification scheme**
An intellectual structure categorising business functions/activities or subjects to preserve the context of records relative to others. It is useful for aiding activities such as retrieval, storage and disposal scheduling of records. Disposal
A formal decision taken on the final status of a record (or set of records) to either destroy the records, transfer to another organisation for permanent preservation or retain within the organisation’s file system for further review at a later date.
Electronic records management system (ERMS)
An electronic records management system (ERMS) is a computer program (or set of programs) used to manage electronic records stored in an associated database. It provides a variety of functions including access controls, auditing and also disposal using a combination of system and user generated metadata.
Depending on the system it can also be used to manage paper records held by an organisation.
Filing structure
A hierarchical structure of folders within a file system which provides a coherent location for capturing records.
The term ‘filing structure’ is synonymous with the term fileplan. However, this term is not used here as it is typically used to characterise the business classification scheme of an ERMS.
File system
A method for storing and organizing computer files and the data they contain to make it easy to find and access them. File systems may use a data storage device such as a hard disk or CD-ROM and involve maintaining the physical location of the files.
Folder
A type of aggregation or container within a file system used to store records (and other folders). It is the principal building block of a filing structure.
Management rules
Management rules are set of explicit instructions to users on the organisation’s preferred means of managing records. These include direction on appropriate capture, access management and disposal of all records irrespective of format or media. The term ‘management rule’ is synonymous with the term ‘business rule’. Within this guidance ‘management rule’ is preferred explicitly for records management within a file system. However either term is acceptable and can be used when producing a rule set for managing records.
**Metadata**
Data describing the context, content and structure of all records and folders within a file system. In a file system this is essentially user-generated and ‘passive’ in that it can rarely be used for active management of the records. By contrast, metadata in an ERMS is more functional, often system-generated, extensive and linked tightly to system processes.
**Operating system**
An interface between computer hardware and a user that manages and coordinates use of computer applications using the available resources provided by a computer’s processor.
**Record**
Information created, received and maintained as evidence and information by an organisation or person, in fulfilment of legal obligations or in the transaction of business.²
**Records management**
The practice of formally managing records within a file system (electronic and or paper) including classifying, capturing, storing and disposal.
**Shared drive**
A specialisation of an operating system file system, comprising a shared device (for example, hard disk or server space) used by multiple users and accessed over either a local area network or a wider area network connection.
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² See International Standards Organisation ISO 15489 Information and documentation: Records management, two volumes 2001 Records management policy
What is a records management policy
A records management policy can be described as an authoritative statement of intent to manage records in an appropriate and suitable manner for as long as they are required for business purposes. It is intended to form the initial framework or principles which express how records should be managed within the organisation. Where the records management policy comprises part of a broader information management or knowledge management policy, it should still be easily identifiable and available to users.
The international standard for records management ISO 15489(^3) states:
> ‘The policy should be derived from an analysis of business activities. It should define areas where legislation, regulations, other standards and best practices have the greatest application in the creation of records connected to business activities.’
The records management policy should not be so vague that no ownership or authority can be attributed to it. It must be signed off at the highest level possible (board level) and it should provide, as a minimum:
- a description of what a record is and the reason for capturing and managing it
- a statement of commitment by the organisation to manage records appropriately and accurately for as long as the records are required
- identification of records management roles and responsibilities for all staff at every level of the organisation
- an explanation of the objectives of the records management policy and how it aids compliance with specific standards and legal responsibilities applicable to the organisation
- detail of the relationship between the records management policy and other policies within the organisation (the email management or data security policies)
(^3) ISO 15489-1:2001 Information and documentation Records Management Part 1: General; 2001 Creating a records management policy should be the first priority for an organisation looking to improve or consolidate its records management. Do this in consultation with the business, with senior management endorsement and support.
It should encompass paper and electronic records created and managed by the organisation. Management rules for creation and management of electronic and paper records should be explicit and should support the principles laid out in the policy.
There should also be a regular review of the records management policy. The timeframe for review should be at least every five years, but with flexibility to review it if significant changes in the business of the organisation require it (a new business activity or introduction of a new business system).
**How does the policy aid records management?**
A records management policy provides an authoritative mandate for implementation across the organisation. It exists to reinforce the importance of records management at a senior level and determine its direction within the organisation.
This framework can guide the development of file systems and records management processes. This should lead to overall better understanding and delivery of records management across the organisation.
Within smaller organisations the records management policy may be the single resource for records management. As the principal statement it provides new and existing users with a direction on records management to ensure it is taking place correctly. In this way the policy is directly responsible for guiding the development of records management within an organisation.
In larger organisations it is more likely that the records management policy will provide a broad instruction that record managers can refer to as their authority for promoting records management.
If difficulties with records management activities cannot be resolved at a procedural level with business managers, reference to the records management policy can help in resolving them. Case study:
An organisation’s records management policy clearly articulates a responsibility to comply with legal or statutory regulations indicating that records must be managed to fulfil these responsibilities (for example, response to subject access requests under the Data Protection Act).
Using incremental implementation of the records management policy, users are made aware of these responsibilities and work to ensure accurate records are captured and well managed. This enables the organisation to respond to requests for information efficiently and effectively without loss of productivity.
This case study explains how the successful implementation of a records management policy relies on how well it is implemented. If users are given the opportunity to view and understand the records management policy, it will help to ensure they adhere to it on a day to day basis.
Case study:
An organisation has not produced a defined records management policy. As a result users do not have a clear understanding of what records should be created and retained.
Following an investigation by a regulatory body the organisation is found to have failed to retain specific key records. As a result they are found guilty of corporate negligence through poor records management, fined and reprimanded by the auditing authority leaving them with significant financial and reputational damage.
This case study explains how the successful implementation of a records management policy relies on how well it is implemented. If users are given the opportunity to view and understand the policy, it will help to ensure they adhere to it on a day to day basis. Limitations of a policy
A records management policy cannot guarantee that users will actively manage records. In order to realise the benefits of the records management policy an organisation will need to undertake other activities and changes to ensure active records management takes place.
The process of implementation required to support the records management policy in improving records management will need:
- creation of accessible guidance on records management such as naming conventions, capturing of emails, and disposal methodology
- development of management rules for the use and management of the file systems
- establishment of a process for monitoring the file systems to ensure records are being effectively managed as intended by the records management policy
These supporting features are a practical application of the records management policy and together provide the actual process of records management as a business function.
Where can I learn more?
Implementation guidance
Guide 2: Organisational arrangements to support records management
A brief implementation guide developed to help public authorities achieve compliance with the Code of Practice issued under s 46 of the Freedom of Information Act 2000. Intended for the Public Sector its principles are applicable to anyone establishing a records management policy.
Examples of policies
The following are examples of records management policies; we do not recommend wholesale adoption of another organisation’s records management policy.
- JISC records management policy
www.jiscinfonet.ac.uk/InfoKits/records-management Filing structures
What is a filing structure
The filing structure reflects the relationship of business activities through careful structuring of folders (with meaningful titles) ‘containing’ the records. This structure illustrates what the organisation’s business is, and it provides a means of managing its records.
A filing structure provides an environment for presenting a common understanding of how records should be stored and retrieved. This is particularly important not just for users working in a team, but also when working across the organisation by improving the retrieval of content and making it understandable to every user.
If the filing structure is well designed it will allow the organisation to control access more effectively, ensuring that unauthorised users are not inadvertently granted access.
A filing structure may be modelled on the functions of an organisation. Alternatively it may also use subject themes for parts of the structure. In either circumstance avoid using names of business units (or individual users) as this can cause problems such as:
- inhibition of sharing content and information across the organisation
- unnecessary duplication of records causing problems with routine disposal policies Managing digital records without an electronic record management system
- separate (or silo) work areas within a corporate filing structure making it difficult to shape records management at a strategic level
- legacy filing areas for discontinued work groups and obsolete business units remain in place and unresolved
- reduced efficiency in terms of compliance with the Data Protection Act or Freedom of Information Act
These problems can be aggravated if users move within the organisation, or leave.
There are many approaches to creating a filing structure and even a number of commercially available tools available to aid organisations when designing, or re-designing, one.
Irrespective of the method used to create a filing structure, it must at the very least contain the following attributes:
- a structure that is easily interpreted and which discourages users from placing records in inappropriate locations
- simple names that identify the logical element of the filing structure
- established responsibilities for folder management, to ensure the filing structure is well maintained
- typically a ‘functional’ filing structure will have three levels (or layers) of folders that act as segregations for information. These levels represent the functions, activities and transactions of an organisation
- the fourth, and usually final, layer sits beneath these. It is defined by the business where the records are to be captured and stored. This prevents users from creating idiosyncratic, locally defined, sub-folder structures below this level, within a particular part of the filing structure, which does not conform to the corporate rules Example:
This example shows a basic layout of a filing structure in the MS Windows environment. Other systems will use different icons and might display the filing structure slightly differently.
The upper folders or ‘Classification Folders’ should never contain records. If the expertise is available, identify the upper folders by an icon different to that of a normal folder. This provides a visual distinction for the user. Records are normally only expected to be captured in the fourth (or lowest) level of the filing structure.
This method allows an organisation to implement and manage both access controls and disposal scheduling across aggregations of records in a clear and defined layout. This reduces record management overheads and ensures consistency across the filing structure.
**How does the filing structure aid records management?**
From the organisation’s perspective, there is rarely sufficient standard functionality within a file system that can be used to control the creation, deletion or movement of folders. Most file systems options are limited to a simple on/off option depending on the user’s access rights. This provides further complications as folders and records have to be moved (and archived) manually with no audit control. If a mistake is made there will be no report or audit trail that could be examined easily to confirm where a folder (or record) has been moved to.
From the user’s perspective, a filing structure helps mitigate this by providing a logical structure which makes it easy to see where a specific record (or new folder) should be located.
Organised filing structures support records management by providing an understandable and accessible location for all records which encourages users to work within it. This helps an organisation reduce the risk of business critical information being lost within an uncontrolled file system. It also helps motivate users to move records out of personal drives or email accounts where it may be deleted without anyone knowing it existed.
**Constructing the filing structure**
Designing a filing structure is often a time consuming task, particularly where there has never previously been any formal order or agreed layout for records and folders. There are products that can help with reducing the time it takes to design the filing structure. In all cases it must be thorough and with a focus on usability.
There are proprietary software tools for developing the structures needed to manage documents and records. Such tools can be used to create and maintain a comprehensive range of business classification schemes, taxonomies, thesauri, glossaries, records retention and disposition schedules. However using them will incur additional costs.
More information on these business classification software tools is provided at ‘Where can I learn more?’ at the end of this section.
**Example:**
This is an example of a clearly designed and managed filing structure organised in a hierarchy of folders. The names of the folders use a simple structure and basic semantics so that all users can interpret it. Example:
This is an example of a poorly designed and managed filing structure with no control over the hierarchy of folders. It leaves users confused about where to capture records for any given function. For example a new or temporary member of staff may not know where to locate a draft policy.
The visual representation of the folders within a Windows operating system is only for display purposes - the folders portray the file system metadata used to configure related objects on-screen. Users often think (incorrectly) that they are capturing records into an actual folder when in fact they are stored randomly. The records are not located within the designated folder. It is the operating system which displays them in a logical order using the folders as a prompt.
Creation, movement and deletion of classification folders must be carefully controlled and restricted to a sub-set of users, or in smaller organisations, restricted to the records manager. This ensures that any development of the structure is consistent and that there is no inappropriate access or disposal. It will also enable the organisation to prevent uncontrolled proliferation of folders (and potentially sub-folders) by any user who has access to the filing structure.
Much of this will require management rules owing to the limitations of the file system functionality. This is particularly difficult where users have rights to create both folders and records in an area of the filing structure. Without complex coding it is difficult to develop a type of folder that allows only records to be captured into it by a user with access rights. As a result users could place records and folders at the same level of the filing structure. Example:
This example illustrates how the filing structure can be disrupted by allowing records (outlined by the red box) and folders to exist at the same level.
The relationship between the records, folders and parent folder are unclear with no understanding on how they should be managed. This introduces a further complication; it is often unclear whether the record should be disposed under different rules to the folders and their contents.
The management rules need to be supported by frequent monitoring of the filing structure, correcting any errors. With significant IT configuration, custom scripting may allow a greater level of functionality within the filing structure to prevent end users from adding records at inappropriate levels of the structure.
This guidance does not cover these options as customisation is likely to be expensive.
**Shortcuts and relating folders**
In an ERMS it is possible to create a record or container (folder) in one location but have it appear in multiple areas of the filing structure using a system of ‘pointers’.
These pointers are an interactive shortcut to an object that replaces the need for duplicate copies of a record and are coded to resolve any conflicts in access control and disposal management.
Whilst this functionality does not exist in a file system, it is possible to achieve some of the end-user benefits of pointers by using the ‘Shortcut’ option in systems such as MS Windows. Example:
In this example two folders (outlined by the red box) were needed in two parts of the filing structure. Having decided the primary location for the folders shortcuts were created and placed in the secondary location. This technique can significantly reduce the amount of duplication present in a filing structure. It will also support organisations trying to respond to requests for information by ensuring only one copy of a record, or location for record exists.
Use shortcuts with caution. They are merely a link to a record. They do not have any content themselves and pose the following risks:
- if the original record is deleted the shortcut will remain, but no longer pointing to anything
- inconsistent disposal processing is possible as the record manager will not necessarily be able to locate all shortcuts
- there is a significant risk of retaining implied personal data (through the title of the shortcut) or other sensitive information
Limitations of a filing structure
The limitations of a filing structure are largely based on those of the file system that supports it. The limitations can be summarised as:
- the functionality of a file system presents a significant limitation in the control of creation, deletion and movement of records and folders where a user has access
- a file system’s functionality does not prevent users placing records in the wrong folder if they have access to it
- a filing structure will only be effective if users are able to engage with it
- a poorly constructed filing structure will only discourage users from engaging with it and exacerbate any records management issues that arise These limitations can only be mitigated by strict management rules and a policy of reviewing the filing structure periodically to ensure it is being used appropriately. Additional ongoing training for users and active management by those responsible for records management (either corporately or locally) can help ensure records management activities are being carried out appropriately. This will also help identify departures from recommended practice.
**Where can I learn more?**
**Designing a filing structure/business classification scheme**
There is a range of guidance available on designing a filing structure and various groups have created some sector specific guidance.
- Business classification scheme [File plan] design
**Example business classification schemes**
These examples of business classification schemes are included for illustrative purposes only.
- Local Government classification scheme V2.03:\
[www.rms-gb.org.uk/resources/92](http://www.rms-gb.org.uk/resources/92)
- JISC Infonet HEI business classification scheme, 2007:\
[www.jiscinfonet.ac.uk/partnerships/records-retention-he/hei-bcs-user-guide](http://www.jiscinfonet.ac.uk/partnerships/records-retention-he/hei-bcs-user-guide)
**Business classification tools**
This is not an endorsed list of software. These examples can be used to aid an assessment of a file system(s) to help build a filing structure, and address redundancy and duplication. Other products may be available and each organisation must assess whether they need such a service at all.
- a.k.a.® available direct from the Australian developers or in the UK via In-Form Consult Ltd:\
[www.a-k-a.com.au](http://www.a-k-a.com.au) or [inform-consult.co.uk](http://inform-consult.co.uk)
- One-2-One Classification software for records management:\
[www.acs121.com/html/one2one.html](http://www.acs121.com/html/one2one.html)
- Active Navigation:\
[www.activenav.com](http://www.activenav.com) Keyword AAA: www.naa.gov.au/Images/Keyword%20AAA_tcm16-47292.pdf
Keyword AAA is a thesaurus of general terms designed for use in classifying, titling and indexing most types of records in most technological environments. To provide a comprehensive controlled vocabulary, use Keyword AAA in conjunction with a thesaurus of functional terms relating to the organisation’s specific or core business functions.
Record Management Code of Practice reference
- Keeping records to meet corporate requirements
- Guide 6: Storage and maintenance of records
- www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm
Management rules
What are management rules
Management rules are set of explicit instructions that direct users in the organisation’s preferred means of managing records. These directions specify a variety of activities and should also explain why the rule has been created. Whilst the style and detail of management rules may vary between organisations they should include instructions on:
- appropriate means of capturing electronic records into the filing structure
- clear definitions on what records should be captured into the filing structure and what may be held in a personal drive (such as users’ staff appraisals)
- specific criteria for the application and management of access controls
- specific criteria for the disposal of all records and folders with explicit reference to the organisation’s disposal policy
Management rules should always be expressed as an instruction and should not be ambiguous in their interpretation. Their purpose is to provide a mandate and authority that helps ensure a level of consistency is applied across an organisation in terms of records management.
Without management rules implementation of the records management policy will be very difficult. Finding a balance between use of software that may automate certain activities and ensuring users still engage in records management is a difficult balancing act, only managed by implementing effective management rules.
Within a file system, records might be moved and edited without the actions being auditable. Management rules are one of the most practical ways of ensuring that activities within the file system such as capture, classification and disposal of records are carried out with a degree of logic and accuracy by all users.
Management rules provide direction on a range of records management activities and include, but are not limited to:
- naming conventions for folders and records
- management of the filing structure
- allocation of access controls
- management and execution of disposal
There is no standard profile for management rules and organisations may decide how they should be written and made available to users. However there are some basic principles that should be included in the development of management rules. Specifically they should:
- reflect and reference the good practice presented in the records management policy
- be written in natural language (non-technical or Plain English)
- be made available to all users (via an intranet or central guidance library, for instance)
- indicate where specific records (such as vital records for disaster recovery) need to be managed to comply with regulations or other external review processes
The management rules should be framed in terms of their benefit to the organisation and its records management capability. This must necessarily outweigh individual preferences for managing records. To avoid a conflict between these two needs, the management rules should be developed in consultation with the users.
This helps ensure that the rules do not prevent the efficient conduct of business, but also that users are not disenfranchised by an enforced set or rules that does not allow them to do their job. Case study:
An organisation, having conducted a review of the file system, decides to implement management rules to improve the way users capture records into the system. During the consultation on the management rules, those responsible for records management discover that the proposed filing structure doesn’t support the way users need to capture records and as a consequence the proposed management rules would impede business activities.
This case study demonstrates the need to develop the filing structure and management rules in consultation with users so that the organisation develops a good records management culture. This encourages users to feel that the management rules have not been imposed, and they are happy to participate in good records management.
Monitoring and maintenance of management rules
Training and advice on management rules is essential. There must also be a process of monitoring to ensure that users work within the rules.
This requires roles to be created at both a local and strategic level to form a watching brief on use of the filing structure and email clients and to correct and guide where rules are breached or misinterpreted. These monitoring roles should be empowered to report persistent and/or deliberate breaches of the management rules to a senior record management authority.
Occasionally a management rule may become an impediment to business conduct or no longer reflect the environment in which records are stored. The monitoring role can be engaged to evaluate whether a persistent breach of a management rule results from the rule no longer being appropriate or that it hampers users doing their job.
Management rules should be re-evaluated regularly and particularly where changes occur to either the file system, filing structure and the record management policy. How do they aid records management?
Management rules help mitigate the limited nature of system generated metadata by providing structure and support to users enabling them to proactively manage their records. When combined with routine monitoring, management rules assist in building a culture of records management.
The other benefits of management rules include:
- assistance to users in the conduct of day to day business by providing a common and easily understood framework
- improvements to business efficiency by ensuring all users capture and manage records in a similar manner allowing the organisation to locate information quickly and accurately
- encouragement of awareness of the importance of records management to individuals by highlighting the business reasons/benefits within the management rules
- support for the records management policy by demonstrating a commitment to records management across the organisation
- empowerment of the records managers to challenge poor records management within the organisation
- provision of evidence to external authorities that deliberate and controlled management of file systems is encouraged by use of management rules
- translation of the record management policy into standardised procedures for staff to follow
This is not an exhaustive list of benefits, but gives an idea of how significant management rules are to the use of file systems for records management.
Management of metadata
Within the context of a formal ERMS, metadata is used to provide data about records and folders (details on how long a record should be kept, or determine who may access the record). This metadata is often used by the ERMS to drive functions such as access controls and disposal rules. In contrast most of the metadata presented within a standard operating system is only informative and cannot be used for active records management.
It is possible to configure the system so that when a user captures a record they are presented with the ‘Properties’ view for the record. This is a visual prompt for the user to enter some meaningful metadata that can be used to manage the records. In practice this process cannot be mandated and user can still enter meaningless information in if they so choose.
Example:
This example illustrates the limitations of metadata as displayed in a MS Windows file systems. Within MS Windows explorer the ‘General’ properties tab (circled) displays the following metadata. This metadata is only providing a view of metadata generated by the operating system. In practice metadata presented in a file system is not completely robust for the following reasons:
- a change such as renaming the record or relocating it is recorded in the ‘Accessed’ date time field, but not in the ‘Modified’ date time field
- the field ‘Modified’ only records a change in the content of the Word document
- if the operating system is incorrectly configured or corrupt (if the server clock is inaccurate) any of the metadata regarding date and time will have no value
- if a record, or group of records, is moved to a new location, there is no audit of this action or any place to indicate a reason for a move if it is deliberate (unless a custom text field is developed)
- very little automated control to reduce human error because there is only a limited set of metadata (user access controls) linked to or enforced by the operating system
**Limitations of management rules**
Management rules do not provide a replacement for functional metadata. Even the most well defined and structured management rules have limitations. There are a number of reasons why they could cause problems and deter users from engaging in records management activities such as:
- not reflecting how the organisation’s business is conducted and preventing ongoing conduct of transactions
- requiring too much effort on managing records to the extent that the business of the organisation cannot be conducted
- not written or defined in a way that all users can understand them
- too prescriptive or rigid to engage users
- cannot be enforced in most standard file systems
These are just a few examples. Ultimately the rules rely on the goodwill of users to engage with them. This can be enhanced with a monitoring process by the records manager or selected individuals in local business units. If suitably empowered by the organisation they can help users to understand best practice and provide an immediate response to queries and problems. Write the management rules in consultation with users and in accessible language (Plain English). The rules must also be available through the most practical means so that users can quickly find them for reference (via an intranet or central record management resource, for example).
Users must be prepared to engage and work with the management rules and the file system to achieve records management. Once the rules have been established and agreed they must be enforced and followed if their benefits are to be realised. This will require some form of monitoring and process for reporting where the rules have not been followed so that the problem can be rectified and the user provided with information or training.
**Types of management rules**
There are likely to be a range of management rules that are specific to the organisation, particularly in respect of compliance with specific legislation. The following conventions are areas where management rules will be required for all organisations using file systems.
**Naming conventions**
Naming conventions help identify records and folders using common terms and titles. They also enable users to distinguish between similar records to determine a specific record when searching the file system.
Naming conventions need not be overly prescriptive or formalised but they must be clear and well defined. Names for records must be meaningful, and convey an idea of the content. Records and folders with a meaningful title based on naming conventions also allow efficient records management judgements to be made without having to explore the content of each individual record.
Without naming conventions there is a significant risk of records being destroyed or lost within the file system. Without standard approaches to naming folders the context of the records becomes meaningless to anyone other than the creator.
Organisations should ensure that sensitive information is never used in the name of a record or folder even where access to the area of the file system is strictly managed. This is to ensure that personal or sensitive data cannot be inferred by casual viewing of a record or folder title. The use of pertinent security or protective marking information should also not be included in the title of an object. Use of terms such as ‘Confidential’ could imply a level of sensitivity that would compromise the content of the record or folder by advertising this in the object’s name.
In practice certain records and folders have to include sensitive information. Considered application of appropriate access controls should mitigate accidental disclosure of sensitive information to anyone other than an authorised user.
**Naming conventions for emails**
There must be specific guidance on naming conventions for emails. When emails are captured from the email client (such as MS Outlook) into a file system they are automatically named using the text in the ‘Subject’ field of the email. As a result, the prefixes ‘RE:’ for replies and ‘FW:’ for forwarded emails may be retained. Remove these to ensure that the title of the record is clear about the purpose and content of the captured email.
In practice email capture is likely to require more detailed guidance as several emails might be captured as part of a longer communication. If all these emails are captured and given the same name, the context and reason for capturing will remain unclear.
**Example:**
| Name | Size | Type | Date Modified | |----------------------------------------------------------------------|------|---------------|-----------------| | Copy of New Record Management Policy sent to CEC.msg | 31 KB| Outlook Item | 24/08/2009 13:21| | New Record Management Policy for Comment.msg | 31 KB| Outlook Item | 24/08/2009 13:21| | Advice on where to publicise new Records Management Policy.msg | 31 KB| Outlook Item | 24/08/2009 13:09|
This example demonstrates the benefit of providing a meaningful title for each email.
Whilst requiring an investment from the user, they form a coherent set of records with discernable content and relationship to other records within the file system. Example:
This example illustrates the problem when users do not actively rename captured emails. There is neither understanding of what each email was created for, nor why it may have been captured.
**Naming conventions for folders**
The capture and management of all types of records into a file system requires careful planning and structure.
The reasons for providing naming conventions for folders are:
- to ensure consistency of approach in terminology and format for specific activities, such as casework
- to provide all information within a file system with a coherent context and logical frame of reference
- to provide users with a practical means of identifying where records should be captured within any given part of the file system
As with the naming conventions for records (including emails) there must be management rules for users to follow when naming folders.
The rules need not be excessively prescriptive, but ensure that the length of the folder name is not too long. It can become difficult to search and retrieve accurately for folders lower down the filing structure. Example:
This example illustrates some of the benefits of providing meaningful titles within the filing structure:
- the hierarchy of the structure is clearly identifiable by the titles of the folders
- peer relationships between folders are clearly identifiable indicating a range of preferred locations for different types of record on a related activity
- at the lowest level of folders (outlined in the box) it is clear what is expected to be captured into each folder
Example:
This example shows a file system where there are no management rules applied to folders. The hierarchy gives some idea of the filing structure, but lack of consistency in naming the folders makes it very difficult to understand the whole structure and where to find specific records.
The folders for records (outlined in the box) provide no means of identifying their content or what should be captured into them. In such a filing structure records management would be impossible and places an organisation at a significant risk of information loss. Version control for records
The means of indicating a current version of a record in any system is difficult. Management rules can aid this and allow users to name the record indicating the current (and previous) version.
Example:
This diagram illustrates the simple addition of ‘1.0’ to indicate the draft status of a record. If an organisation adopts this simple approach and uses small decimal increments to indicate minor revisions and whole numbers for a major revision, all users can quickly identify which is the current draft or final version.
Example:
This example illustrates the addition of a simple decimal system for indicating minor and major changes in the version. In this case ‘whole’ versions of the document are named using 1.0 or 2.0. Interim drafts are named 1.1, 1.2 and so on.
This is considered best practice, but organisations might use other version numbering for records such as technical drawings. Irrespective of the naming conventions used they must still be explained clearly within the management rules. Example:
This example illustrates a further suffix added as a one word statement - ‘draft’ - reinforcing the version numbering and clearly identifying the record’s status. Where used, control and monitor these terms for consistently. Any lists of controlled terms must be reviewed, and updated, at regular intervals.
Used correctly these ways of indicating a record version will provide a clear idea of the drafting process and which record is the current one.
Example:
This example shows the consequence of having no management rules for version control. There is little coherent information identifying versions and their relation to the others. This could have a significant impact on records management activities such as disposal, and will also limit the ability to locate and retrieve the current record efficiently.
To remain effective either a records manager or a local authorised user should monitor the use of naming conventions. The introduction of rules on the creation of version controls really only works where the business recognises a real need for these conventions. If not, they are rarely used and become redundant.
Format of dates
It is very likely that users will want to manage some records, and the folders they are located within by date. Given the range of ways of writing the date, the organisation must choose a standard format for all users to follow. This will aid structuring of folders and improve the ability to retrieve information when searching.
The most practical way of using dates is in the format Year-Month-Day or 2009-08-21. This is a standard format which allows for easier searching. This is because when searching for older records a user is more likely to know the year, and possibly the month, when a record was created than the exact date.
**Where can I learn more?**
These examples are included because they reflect best practice as a list of rules. Not all will be suitable for every organisation; management rules should be developed in consultation with users and appropriate to the size, sector, culture and resources of the organisation.
- The Financial Services Authority records management policy and standards – RMPS: [www.fsa.gov.uk/pages/information/pdf/records_policy.pdf](http://www.fsa.gov.uk/pages/information/pdf/records_policy.pdf)
- Record Management Society RM toolkit for schools: Creating information management systems: [www.rms-gb.org.uk/resources/848](http://www.rms-gb.org.uk/resources/848).
**Record Management Code of Practice reference**
- [www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm](http://www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm) Access control management
What are access controls?
Access controls determine who can access/capture records and access/create new folders. The allocation of access controls allows an organisation to delegate responsibility for records and folders to their creators and managers. This accountability helps to ensure that records remain authentic and reliable, retaining their integrity and usability.
In a modern records management environment access controls within a filing structure are set to as wide (or open) a state as possible. This means that unless a specific reason can be applied, records and folders should be accessible to all parts of an organisation as a default. This reduces the overhead of managing access controls and it also improves the effectiveness and efficiency in information sharing.
Some organisations may provide users with personal drives to store records such as copies of staff appraisals or annual leave requests. Where used these should be restricted in size to prevent users turning them into personal storage areas for business records.
Personal drives have to be restricted to genuinely personal information. They must not be used for storing business records which may be sensitive and require access controls while still sitting in the filing structure (with appropriated limited access controls).
These personal drives are not recommended for storing business records; the rest of this chapter is directed at access management within open shared drives and the filing structure.
Most organisations will already have user profiles that give all authorised staff an email account and access to the file system. Typically this profile also gives access to a personal drive (individual space on the file system) and one or more areas of the file system (sometimes referred to as ‘Shared Drives’). Example:
This example illustrates the ‘Security’ window for a folder in a MS Windows file system. The list of ‘Groups’ and ‘Users’ indicate who can access the folder. Those listed have the power to add or remove other users to control access as required. Additionally the administrators can refine the ‘Permissions’ further to indicate what a user can do within this folder, such as capture new records or create a new folder.
Organisations may wish to create a number of profiles to reflect the level of functionality available to certain users. A typical end-user’s profile will look similar to the above example but some of the ‘Permissions’ might be set to ‘Deny’ to limit what they can or can’t do in particular parts of the filing structure.
Using these basic controls an organisation can begin to form access controls across the filing structure. These can be used to keep as much information as open as possible and appropriate, whilst also ensuring sensitive information is kept secure. Setting up access controls
Access controls can be set at three levels within a file system - at drive, folder, or record level.
Allocating access controls by individual user requires substantial effort and it would be difficult to monitor or track. Development of access groups reduces this overhead substantially and it can improve the controls placed on any part of the filing structure.
This can be a very useful means of applying quick access (or denying it) to a part of the filing structure by an administrator. However it is potentially limited if an organisation is located over several sites using individual Local Area Networks (LAN). Whilst the filing structure may be represented in all locations, they will not all be updated if access controls are updated. This would require every individual network to be updated to ensure a consistent application. Organisations that use a Wider Area Network (WAN) will not have this problem.
Example:
This example illustrates how access groups can be used to granulate access to the filing structure. In particular, the ‘Finance’ folder and lower folders need specific access controls. An access group called ‘Group A’ is created and granted sole access within ‘Finance’. This Group contains all users who are permitted to see and access the ‘Finance’ area.
Below ‘Finance’, the ‘Contracts’ folder requires an even greater level of access control and a sub-set of ‘Group A’ users is selected to form ‘Group B’. Using this process an administrator can vary and allocate access controls more efficiently than if they had to select each individual user. By maintaining memberships of access groups instead of individual access to every record and folder the overhead of managing access controls can be reduced significantly. Whilst file systems work better when configured at the highest permissible level for both folders and records, it is possible to restrict access to individual records and folders. This should not be considered in normal access control allocation. There is the risk that the information will become lost and inaccessible to the organisation if that user leaves (temporarily or permanently), or moves to another business unit.
Successful application of access controls does not rely solely on the creation of appropriate groups. If the filing structure itself has not been constructed in a coherent way it could become very difficult for an administrator to ensure that correct access is being applied across the file system.
**How do access controls aid records management?**
As a file system lacks much of the automated functionality of an electronic records management system, access controls are one of the few means of formally regulating changes to the filing structure and records.
Access controls help control how and where information is created and accessed. Such controls can help to:
- restrict the number of users who can change or edit records and folders
- reduce the number of users who could inappropriately delete, alter, or relocate sensitive information
- identify and allocate responsibility for records and folders within sensitive areas of the filing structure
Locally appointed record managers, where available, can be given a local administrator profile for a relevant part of the filing structure. This still limits the number of users who can edit access controls, but improves the efficiency with which changes can be requested, made and monitored at a local level.
Any local administrator should work with and be managed by a records manager to ensure consistent governance is applied across the filing structure. Limitations of access controls
There are a number of factors that should be considered when implementing access controls within a file system. A file system does not offer the granularity or ease of use with access controls as a dedicated electronic records management system might.
Complex access control models
It’s easy for access controls to become complicated and difficult to track. To prevent this developing into a significant management overhead keep access controls as open as is practical (so that all users can see but not edit records and folders). This means keeping as small a number of access groups as is required and actively managing them, reviewing and updating them regularly.
Documenting this process is likely to be difficult. Although the server will retain a log of access groups, this may not be presented for easy review. Where an organisation develops access groups they will need to ensure that this is documented externally from the file system to allow review by records management staff.
In complex organisations with a pre-existing access model for paper files, the organisation may view this as a useful referral tool when allocating access to related electronic records in the filing structure. This will not be an exact match but may help with consistent allocation of access.
Monitoring access control allocations
The monitoring and regulation of access controls can be a time consuming process. This is exacerbated by the fact that a record manager cannot always independently decide whether appropriate access has been given. A management rule must be used to ensure that users are added (and removed) to access groups by a records manager (or network administrator) only upon request from another authorised user.
Any user who has full access to a folder or record (to edit or delete content) can also change the access controls if they know how. This could result in other users being ‘locked out’ of folders or records inappropriately. This type of behaviour must be monitored carefully. For this reason avoid individual access controls as far as is possible. Changes to the structure of the organisation may also affect specific access controls where users move from one part of the business to another. The organisation will need to ensure these changes are logged so that an authorised user can update access controls appropriately.
The same action would also be required when a user leaves the organisation. Their IT profile must be deleted to prevent anyone from accessing the file system using the account.
**Other access controls**
A feature of MS Windows file systems is the ability to protect both records and folders with a password. This prevents anyone other than the user from accessing the object, and circumvents the organisation’s access controls. Either switch off this functionality or actively discourage it. Passwords are either too simple to offer any real security or they are forgotten. In either case the security of the document is reduced and the organisation risks losing control of its information.
Similarly if a user leaves without disclosing relevant passwords there is a risk the organisation will not be able to change the passwords. Immediate access becomes an issue and it presents a challenge for digital preservation. Scaled preservation operations that convert records to another format can be hampered significantly.
For these reasons we advise that any reliance on password controlled access should be replaced with alternative access mechanisms.
**Operational limitations**
A related issue is the creation and maintenance of user profiles on the file system. Usually this is only carried out by the IT function within an organisation (or an external IT provider). When changes are made (a new user is added, for example) there must be clear communication between the IT staff and those responsible for records management to ensure the user is able to access the filing structure as appropriate.
**Where can I learn more?**
The implementation of access controls and configuration of folders within the filing structure to support them will require significant IT support. We recommend that the experience and knowledge of the IT function is used to help create a usable and secure environment. If no such function exists then the organisation will need to consider seeking external advice on this subject.
**Record Management Code of Practice reference**
- Guide 7: Security and access
- [www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm](http://www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm)
**Disposal policy and management**
All organisations irrespective of sector or size need a disposal policy and process to prevent retention of records no longer required for business purposes.
**What is a disposal policy?**
A disposal policy is a formal statement by an organisation on the appropriate means of disposing of records to agreed disposal schedules. It should indicate how long records should be kept and whether they should be destroyed or transferred to another organisation once they are no longer required for business purposes. The policy may form part of the overall records management policy, or it may be a separate document that forms part of the suite of supporting guidance along with management rules for example.
Additionally the policy will need to be supported by disposal schedules that identify types of records and provide the detail on how long they should be kept for and whether they should be destroyed or transferred to an archive. The process of disposal supports legal obligations, such as destroying collected personal data when it is no longer required.
**What is disposal management?**
Disposal management is the formalised process of assessing records to determine how long they should be retained and how they should be removed from the file system. The removal
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4 Sometimes referred to as retention schedules 5 Transfer to an archive is likely to be an issue for only a small proportion of an organisation’s records Managing digital records without an electronic record management system
should be based on the established disposal schedules and follow an agreed process for either destruction or transfer.
In normal circumstances records are disposed of by aggregation or collections of records in folders. Disposal of individual records is normally to be avoided because of the overheads in selecting and deleting individual records. Disposing of aggregations of records is far more efficient and ensures a greater security that related records have been disposed of correctly. This is important in a file system where there are no formal disposal management tools (which are available in an ERMS).
The disposal process should include appraisal of records to understand their current context and content to decide whether they can be removed from the file system. This is important as some records, while due for disposal under an allocated disposal schedule must be kept for another purpose such as a legal investigation.
For this reason disposal management should never be a fully automated process. Even if a record manager is confident that types of records routinely created (such as meeting minutes) could be disposed of, there should still be a means of checking whether they must be retained for a reason other than their original purpose.
Records should never be disposed of on an ad hoc basis or at the discretion of individual users unless there is a specific reason such as:
- it is a duplicate record not required to support the business
- it wasn’t needed to be captured as part of the corporate record (such as a casual email correspondence)
- it is an early draft that no longer reflects or aids the development of a final record
This process must be supported by clear management rules and be monitored by the records manager.
**How does disposal management aid records management?**
In essence, without a controlled disposal management process defined by a policy and supported by disposal schedules, the organisation risks losing control over how many records are held indefinitely, taking up valuable storage space. The disposal management process helps reduce this risk by:
- reducing the volume of out of date records no longer required for business purposes
- ensuring that personal data is not retained beyond its intended purpose
- improving the efficiency of a file system by freeing up space on servers
It will be difficult to support this process in a file system, but it can be aided significantly by:
- grouping activities together to reduce the overhead in searching and reviewing types of record due for disposal (for example, financial transactions)
- closing folders with a clear time limit where it suits the business process and opening new ones (at the end of a financial year or project, for example)
- using naming conventions to help readily identify types of records
- introducing a custom metadata field ‘Properties’ in the folder or record that allows users to allocate the correct disposal schedule
**Limitations of disposal management**
Disposal management as a process is not supported by a file system without specific records management software. This makes disposal management a very difficult process to control within the file system for the following reasons:
- disposal activities have to be done manually including allocation of a disposal schedule, executing it and recording the event
- users might not provide disposal information consistently in a custom metadata field (where available)
- audit data is not readily available because actions occurring in the file system are recorded in one long list in server logs
- a typical server log does not provide specific reports of record deletion without a bespoke PERL script and it will not be accessible to record managers without IT support Some organisations may wish to configure the filing structure so that only authorised users can delete or remove records and folders. Take great care with this approach as it can become unmanageable.
However an organisation decides to control disposal it should be designed in consultation with users. If the file system (and filing structure) is configured too rigorously users may disengage from it altogether leaving the organisation exposed to considerable loss or mismanagement of information.
**Where can I learn more?**
- The National Archives advice on retention and disposal: [nationalarchives.gov.uk/recordsmanagement/advice/schedules.htm](http://nationalarchives.gov.uk/recordsmanagement/advice/schedules.htm)
- Andrew C Hamer, The ICSA guide to document retention: [www.icsabookshop.co.uk/disp.php?ID=633](http://www.icsabookshop.co.uk/disp.php?ID=633)
**Record Management Code of Practice reference**
- [Guide 8: Disposal of records](http://www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm)
- [www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm](http://www.justice.gov.uk/guidance/foi-guidance-codes-practice.htm)
**Email management**
**What is email management?**
Email is the primary correspondence tool of communicating information within an organisation, between businesses and with members of the public. For any organisation, a failure to manage emails indicates a failing in records management generally.
The scope of this guidance does not extend to all aspects of email management such as establishing protocols for responding to emails, sharing mailboxes or other functionality provided by email clients such as MS Outlook. This section covers the management of emails as records and the means of ensuring they are captured and managed so that they are accessible and usable to all relevant parts of the organisation. Unless stated this guidance refers to the use of all types of mailboxes; specifically those used by multiple users (shared mailboxes) and individually managed mailboxes. The issues arising from the use of either type of mailbox are comparable. An email is often perceived differently from other formats of electronic record (such as a spreadsheet or text file). As a result users do not always manage emails with the same consistency as they might other records. In practice an email is no different to any other electronic record containing content and metadata and is as unique as a text document or spreadsheet produced with any proprietary software application.
Organisations must train users in how to distinguish between the emails they need to capture for business purposes and the ephemeral communications. The difficulty of this task will vary depending on the volume, content and type of email an organisation or individual receives and produces.
**How does email management aid records management?**
The ease of composition and transmission of email means that a large number of emails can be created very quickly. This volume can become unmanageable and create a significant risk for the organisation. Capturing emails from an email client into a filing structure helps to place this information in context with other related records. It also ensures that all records, irrespective of format, receive the same level of management in terms of disposal scheduling.
**Example:**
| Name | Date Modified | Type | |------|---------------|------| | Copy of Record Management Policy to CEO for approval | 24/03/2009 13:21 | Outlook Item | | Invitation to comment on Draft Record Management Policy | 24/03/2009 13:21 | Outlook Item | | Records Management policy - 1.2 - Draft.doc | 24/03/2009 09:52 | Microsoft Office Word 97 - 2003 Document | | Records Management policy - 1.3 Draft.doc | 24/03/2009 09:51 | Microsoft Office Word 97 - 2003 Document | | Records Management policy - 2.0 Consultation Draft.doc | 24/03/2009 11:17 | Microsoft Office Word 97 - 2003 Document |
This example illustrates the value of capturing emails into the filing structure. Not only can a user see the full process of draft developments but they can also see related communications and build the full picture of this particular activity. To help users understand this and to ensure important emails are not kept in mailboxes, an organisation will need to develop the following:
- management rules that provide clear direction on which emails should be captured out of mailboxes into the filing structure
- training for users to recognise emails as records that need to be captured and managed like all other types (or format) of record
- functional limits to mailboxes to control the amount of emails that a user can keep for any period
**Management for rules for email**
Management rules for emails depend on other factors outside of records management. These are related to the business process behind responding to and creating emails and include:
- email etiquette, appropriate language
- management of email strings (separate emails for separate subjects)
- titling of the email ‘Subject’ field to ensure the reason for communication is clear and re-titling it if the string changes subject
- acceptable circulation methods of emails (only include those who need to know, for example)
- circulation of links or references, rather than proliferating uncontrolled copies of documents of unclear status
Emails left in mailboxes are of limited use to the wider organisation, not only in terms of conducting business operations, but because they remain inaccessible and cannot be managed corporately.
Training and technical responses to this problem are a necessity but an organisation must also document a preferred formal process for email management. This does not have to be a lengthy detailed document, it could be a short list of ‘do’s and ‘don’t’s for capturing and managing emails. Rules will depend on organisational need and the content of the email itself. The management rules should include:
- what type of email should be captured from a mailbox (for example, a decision or a formal request for information or assistance)
- which user is responsible for capturing a record (such as the sender who circulated meeting minutes)
- when an email should not be captured (as in the case of personal correspondence or general circulars or organisation wide memos)
- how emails should be titled when captured into the file system (renaming emails that contain ‘RE:’ in the title to indicate the content/purpose the response was captured) Managing digital records without an electronic record management system
- how to manage any attachments
- which file format for capturing emails, such as an .MSG not .PST (this can relate to managing attachments)
- responsibility for a shared mailbox, where used. This will depend largely on the number and use of shared mailboxes within an organisation
This is not an exhaustive list and other rules relating to management of casework processing or specific types of transaction management may also be needed.
It is not necessary to develop these management rules in isolation from those for other types of record. If the rules highlight any unique problems with email management (such which emails should be captured from a long exchange and by whom) they can be incorporated into the broader set of rules developed. This approach would help provide continuity for users in their understanding that records can be produced in many formats and are not restricted to a particular type of electronic record.
**Guidance for email management**
The rules for email management must be supported with guidance and training. The training should include:
- an explanation on the importance of capturing emails
- instructions on how to capture emails from the email client into the filing structure, including preferred file format for capture
- how to decide which emails should be kept and who should capture them
- an instruction on regular review of mailboxes to delete, unnecessary emails
- how to manage emails in a shared mailbox to ensure emails are captured into the filing structure
**Email formats**
Capturing emails from proprietary email clients into a file system requires some attention to the file format the email will be captured in. Depending on the email client the email may be presented in its own unique format to support the style and functionality of the email client. Example:
In this example there are six possible formats which the file system will allow the email to be ‘saved as’ or captured. Not all of these formats will preserve the email in a way to ensure it retains its characteristics as an email and an authentic record.
For example ‘.html’ will create a significantly smaller file of a captured email (as much as 50% in size). This reduces the storage used on servers but the usability, attachments (only a text header indicating their existence remains) and some metadata within the email are completely lost. The result is a version of an email record being captured that is unusable by the organisation and a potential loss of business critical information. Conversely the Outlook Message Format (\*.msg), not only remains usable but the presentation of the format would demonstrate an accurate and authentic representation of the email as a record.
The organisation must also take in to account potential file format obsolescence if the email client were to be changed or updated significantly. Older or bespoke email formats are less likely to be supported by a newer email client. This could render the email unusable, or only viewable through a bespoke software application.
Where organisations use other email clients (other than MS Outlook), it cannot be assumed that emails can simply be captured within file systems without loss of information and functionality. The issue is ensuring the logical integrity of emails following their capture so that they remain accessible and fully usable within the designated location.
A very real concern is maintaining access to attachments. The most common are MS Outlook but Novell GroupWise and IBM LotusMail have a broad consumer base. There are many other email clients in use including CC Mail and Eudora. Generally, apart from MS Outlook, these other email clients do not support capture of an email, with its attachments, into a file system without some information loss. There is a risk that emails will be kept in a format which is either wholly unusable or partially unusable. It is essential to undertake research at an early stage to determine the most appropriate method and storage format for maintaining emails within the filing system, while ensuring the emails remain usable and attachments accessible. For example, a decision is made to capture emails originating from an email client such as IBM’s Lotus Mail in a text format (.txt). This particular product cannot provide a file format that retains the email with attachments present outside the email client. As a result the emails are readable but any attachments are lost. With emails used as carriers for single or multiple attachments, the adoption of such a format could result in the loss of information important to the organisation; the attachments are often of greater significance than the text of the email.
It is critically important that any decision to adopt an alternate format should be taken in full knowledge of the consequences. This decision should be preceded by appropriate tests, using emails both with and without attachments to confirm the functionality of the chosen format.
**Retaining emails within the email client**
Where there is not a suitable technical solution (or alternative file format) organisations should consider creating a mirror of the filing structure within the email client. This structure would consist of a set of shared folders and would be subject to the same naming conventions and access permissions applied to the main filing structure. Emails required for capture would be relocated into the appropriate mirrored folder within the email client. Users would need training to search both the filing structure and email folder to ensure they have found all the relevant records relating to a specific subject or activity.
**Example:**
| Filing Structure | Email Mailbox Structure | |------------------|-------------------------| |  |  |
This example shows the filing structure and the mailbox structure designed in tandem providing a means of relating emails, graphically in shared mailboxes, to other records in the file system. whilst held in the email client. Duplicating the filing structure in this manner constitutes an additional overhead as both structures will have to be maintained in tandem, but in some circumstances this may be the only viable option. Further sources on email management are provided in ‘Where can I learn more?’ at the end of this section.
**Limitations of email management**
There are a number of limitations to capturing emails into a filing structure. These limitations can be categorised under three broader issues. Each issue is expanded below, but all three are often tightly interlinked and dependent on one another.
**Volume**
Perhaps the most significant limitation caused by email is the ever increasing volume generated and received by an organisation. Depending on the organisation, and a given user’s role, a mailbox could be subject to a significant amount of traffic. In such circumstances the decision of what to capture and what is simply ongoing correspondence becomes a difficult judgement to make.
Users might leave emails in a mailbox until it is either full to capacity (thus forcing them to address the issue in order to be able to receive and send emails again) or wait until they have time to resolve the problem. In either circumstance the result can be that email records are not captured into the filing structure with related records and are consequently unavailable to anyone searching the filing structure for all the information they require.
**Time**
The second limitation is time. The process of creating a draft record using a word processing application requires the action of ‘saving’ it. This is not a required process in creating an email so users can create and send emails with little time taken, unlike creating and saving other standard records on the file system. Capture of emails into the filing structure requires users to take time out to do this as a perceived extra action.
**User convenience vs organisational risk**
Storing emails in a personalised structure of an email client as opposed to capturing them within the filing structure provides users with an appealing level of autonomy; they can keep business emails within their own mailbox where only they can see them. This can result in emails being treated as an individually owned asset within the user’s mailbox rather than a corporate asset (which should be captured into a relevant location in the filing structure with record management controls applied and access shared).
The simplicity of automated functionality in email clients (automatically storing a sent copy of an email, for instance) removes the user’s responsibility for ensuring an email is kept and is retrievable; the email client is seen as being responsible. Users tend to prefer to retain emails in the email client rather than invest in the effort of capturing emails into a filing structure.
A well designed filing structure, training and management rules can mitigate this attitude but each organisation must accept that a significant proportion of emails are likely to remain in a user’s mailbox until the business has been concluded.
Some basic functionality can also help drive compliance and the capture of email. Many email clients allow limits to be placed on the size of a user’s mailbox, forcing users to address the problem or be unable to use their email until the backlog is cleared.
This could have a significant impact on daily work (such as processing transactions) and an alternative solution such as ‘auto-deletion’ after a set date (three months, for example) might be preferable. This approach makes users consider capturing emails into the filing structure more frequently. It also contributes to providing an organisation with a level of compliance with the fifth Data Protection Principle by ensuring that personal data is not retained unnecessarily (names, email address, or personal details listed in the email content).
Both of these approaches are not without limitations. Users may simply choose to drag and drop a large number of emails from a mailbox into a folder within the filing structure to circumnavigate storage limits or auto-deletion. This can only be controlled by management rules unless significant technical expertise is available to customise the file system that prevents such an action. In the event that either method is chosen, the organisation should conduct a risk assessment and develop a policy to support why it is doing this. This may form part of the records management policy or support it as a separate email management policy.
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6 For MS Outlook the limits are actually controlled on the Exchange Server where each user’s email profile is defined and stored The policy should allow sufficient time to pass before the ‘auto-deletion’ removes the email. This gives users enough time to assess emails for capture before they are permanently deleted.
**Alternative email storage**
There are a range of means for storing email outside the filing structure. This section considers the bulk storage of emails in a near or offline email archive including their potential benefits and risks.
**Bulk email archive storage**
An attractive proposition for storing large volumes of email is to bulk archive them in a near-line or offline server with a search interface for retrieval using a commercial email archiving solution. These products provide organisations with a means of storing large volumes of email in a compressed form increasing the capacity available on a server. The benefits of bulk archiving options are:
- a reduction in IT support overheads trying to maintain a large volume of emails on a live email server
- a reduced cost for server storage (bulk archives are cheaper than expanding live email server)
- a single interface for searching all emails archived, accessible to all authorised users
Most commercially available email archive solutions used coded management rules within the applications that do not represent good records management as practised in the UK.
In particular the method of classifying emails within the archive is based on criteria such as automatically assigned keywords or date of last retrieval. Whilst potentially useful this information does not present the context or purpose of the email to a user when they are trying to retrieve specific emails from the archive. Further risks are:
- storing high email volumes which mean poor search returns from the search interface (insufficient search criteria are available from the archive solution)
- not enough detail known about the email to create an advanced search to narrow the possible returns when investigating the email archive
- record management rules cannot be applied within the archive solution
- access controls dependent on the design of the application which may not reflect the access controls as established within the filing structure, resulting in a potential security breach
- disposal management dependent on the design of the application which will not usually reflect that of the filing structure or organisations disposal policy
- complete aggregations of records cannot be confirmed until the archive has been thoroughly searched
A further issue with these types of archive is that the emails are usually bundled into a large compressed file which removes any relational context of that email to both other emails and records stored within the filing structure.
**Bulk email archive file format**
A further risk of bulk email archiving using MS Outlook email client is that the emails are often stored in .PST files. These are, effectively, a randomly bundled collection of the emails which is then compressed for storage savings. Other email clients will support a similar process. These bundled files are not stable even when stored in a designed email archive solution. Corruption of an email stored as a .PST file is significantly exaggerated as it is in a compressed form. This could cause irreversible loss of data, possibly without the knowledge of the organisation.
Organisations wishing to bulk archive emails must ensure that the system is sufficiently robust and coordinated so that these risks are either eliminated, or at a level they find acceptable. Irrespective of this decision, the organisation should still produce and endorse a policy of storing critical emails within the filing structure to ensure it is available.
**Where can I learn more?**
**Email Management**
- Guidelines on developing a policy for managing email: [nationalarchives.gov.uk/documents/information-management/managing-emails.pdf](nationalarchives.gov.uk/documents/information-management/managing-emails.pdf)
**Record Management Code of Practice reference**
- [Guide 4: Keeping records to meet corporate requirements](#) Integrating management of paper records
Most organisations using this guidance will probably have an existing paper records system. There is a temptation to replicate this system within a file system as it is familiar to the users, can be implemented quickly, and is potentially cheaper than starting from nothing. For some smaller organisations or discreet business units this can be a cost effective and efficient means of building all or part of a filing structure.
It is not always appropriate or meaningful to organise electronic records in the same way as paper records so consider any such initiative carefully. Before looking to replicate any part of a paper filing system in a filing structure the organisation must assess if it is fit for purpose in its current state.
Case Study:
The paper filing system is well maintained and has been developed over time to provide users with easy access to records by function or activity. The supporting finding aids are readily available and up to date. As a result any user could search for and retrieve paper records with minimal impact on efficiency.
Owing to the success of this approach it is deemed helpful that in outline the filing structure in a file system is designed along similar lines with a view to keeping as much information open as is both practical and sensible.
This case study identifies how a paper system could be used as a template for the filing structure in principle. Case Study:
The paper filing system in an organisation has developed organically with little or no controls, users and business units are left to devise their own preferred ways of filing paper records with no corporate approach or requirement for current finding aids. As a result only users from within that part of the organisation could search for and retrieve paper records.
In a bid to reduce costs each part of the organisation ‘copies’ their paper filing structure into a filing structure on the file system. This leads to an impossible system whereby users are unable to locate or retrieve any electronic records where they do not have specific knowledge of that part of the filing structure.
This case study identifies how poor planning and management of paper records, copied into an electronic environment, will frustrate users trying to identify where to capture or retrieve records from. It will also lead to a failure in the filing structure as a whole.
In some circumstances an organisation may choose to use the filing structure to record details about related physical records using a simple text file as a place marker. Alternatively where a physical record tracking system is in place it may be beneficial for the organisation to align this with the filing structure (to mirror it) to present a consistent view of the organisations records irrespective of format.
Where can I learn more?
Storage of paper records
In addition to managing the alignment of paper and electronic records an organisation needs to consider how it stores the paper records. Specifically it should consider:
- identifying and categorising the records to ascertain their use, content and volume
- developing and managing a disposal policy concurrent with that of the electronic records held in the file system • specifying and managing access to the paper records, including any offsite locations • identifying the usage of the paper records to establish frequently accessed records which may need to be stored more centrally • tracking and management of the custody of paper records when held in a file store or at a user’s workstation • assessing the most suitable means of storing the records to ensure they are accessible and not at risk from environmental or accidental damage • development of auditing and reporting on the use, access and disposal of the paper records
These activities will help the organisation ensure its paper records are well maintained and managed to the same level as the electronic records within the file system. More information is available in guidance produced by The National Archives:
• Identifying and specifying requirements for offsite storage of physical records: nationalarchives.gov.uk/recordsmanagement/requirements-offsite-store.htm
Record Management Code of Practice reference
• Guide 4: Keeping records to meet corporate requirements • Guide 6: Storage and maintenance of records • Guide 7: Security and access • Guide 8: Disposal of records • www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm Further reading
General Records Management Guidance
- The National Archives Guidance on records management: nationalarchives.gov.uk/recordsmanagement/advice/default.htm
- The National Archives Guidance on electronic records management: nationalarchives.gov.uk/information-management/guidance/e.htm
- The National Archive Guidance on digital continuity: nationalarchives.gov.uk/information-management/our-services/digital-continuity.htm
- Records Management Society guidance: www.rms-gb.org.uk/resources
- Information Commissioner’s guidance: www.ico.gov.uk/tools_and_resources/document_library.aspx
- JISC guidance on records management: www.jisc.ac.uk/publications/documents/pub_rmibp.aspx
- JISC Infonet infokit on records management: www.jiscinfonet.ac.uk/InfoKits/records-management
Useful Publications
- Managing digital continuity: nationalarchives.gov.uk/documents/information-management/managing-digital-continuity.pdf
- Jay Kennedy and Cheryl Schauder, Records management, a guide to corporate record keeping (second edition, 1998)
- Elizabeth Shepherd and Geoffrey Yeo, Managing records a handbook of principles and practice (2003)
- Effective records management. A management guide to the value of BS ISO 15489 (British Standards Institute, 2002) This is a four part guide www.bsigroup.com/ Standards and Codes
- Revised Records Management Code of Practice (2009): www.justice.gov.uk/guidance/freedom-and-rights/freedom-of-information/code-of-practice.htm
- ISO 15489-1: 2001 Information and documentation – Records management: www.iso.org/iso/catalogue_detail?csnumber=31908
- ISO 23081-1: 2006 Information and documentation - Records management processes - Metadata for records: www.iso.org/iso/catalogue_detail.htm?csnumber=40832
Legislation
- Data Protection Act 1998, Chapter 29: www.ico.gov.uk/for_organisations/data_protection_guide.aspx
- Freedom of Information Act 2000, Chapter 36: www.legislation.gov.uk/ukpga/2000/36/contents The Environmental Information Regulations 2004, SI No. 339: www.legislation.gov.uk/uksi/2004/3391/contents/made
- Public Records Act 1958 Chapter 51: nationalarchives.gov.uk/policy/act/default.htm
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929e225e568e6f9d3271cffe5fe3c50132852170 | Managing Public Expectations Planning as a democratic process
- Representative democracy is the bedrock of planning
- Increasing calls for participative democracy Planning as a democratic process
• Councillors have 2 roles: • Ward councillors: community leaders • Committee: • decisions in accordance with plan & other considerations. • represent the interests of the whole community
• Local opposition or support for a proposal is not in itself a ground for refusing or granting planning permission, unless it is founded upon valid material planning reasons. Localism and planning decisions
“It cannot be that a strategic facility to provide for the needs of a very wide area can be decided solely on the basis that the local community do not wish it to be located within their area…… If applied widely, this could hold up economic recovery as well as deprive future generations of important developments and facilities.”
“There is nothing …… which indicates that…. a particular, and in this instance, very localised group of residents should be able to prevent planning permission being granted simply because they do not want it.” Public Representations
• are background papers and public documents
• should be included with the agenda or at least summarised in a consistent way.
• be reported to the meeting should they be received after the agenda has gone out (with a cut off period) Public speaking
• Publish scheme in their constitution/on website.
• May be local limitations on number of speakers for each ‘side’
• Allow an equal amount of time for • representations ‘for’ and ‘against’ the application Neighbourhood Planning mechanisms
- **Neighbourhood Development Plans**: Once ‘made’ (passed examination and referendum) are part of the development plan, and therefore used as a policy framework for the determination of planning applications.
- **Assets of Community Value** – can be a material consideration eg Kensal Rise Library. Neighbourhood Planning mechanisms
- **Community Right to Build**: Whilst maintaining the principle of the green belt, communities will be able to develop land subject to doing the work and passing examination and referendum (via an NDO).
- **Neighbourhood Development Orders**: Like Local Development Orders (bestowing PD rights) but made by the Parish/Forum. Neighbourhood Planning Steps
STEP 1: Get informed: mycommunityrights E.g. Locality ‘Road Map’
STEP 2: Designate Neighbourhood Planning Area + Forum
STEP 3: Consultation and community engagement
STEP 4: Local Authority publicise the plan
STEP 5: Examination of plan
STEP 6: Referendum
STEP 7: Plan Made!
6 weeks
6 weeks
6 weeks
6 weeks
Association of Democratic Services Officers
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Subsets and Splits