Agenda item

The Head of Regulatory Services sincerely apologised to the Board for the lateness of the Supplementary Agenda Item – Proposal for Transaction Transformation of Worcestershire Regulatory Services (WRS).

The Head of Regulatory Services drew Members; attention to the Recommendations, as detailed on page 1 of the Supplementary Agenda Pack.

Members were informed that, as detailed in the report, that WRS had been exploring the options to improve the customer experience and enable a smooth customer journey for licence applicants and general service requesters for some time. There was an assumption now that all transactions would be fully e-enabled and on-line payment was the norm in virtually all walks of life, from booking a holiday to paying vehicle excise fees.

Pre-COVID, a group was established to look at this. The group was led by the host’s previous S151 officer because one of the potential outcomes was likely to be one partner collecting WRS related income on behalf of all six partners.

Internal audit had repeatedly expressed concerns with Partner Authority income reconciliation against licence records during annual audits. WRS had always responded that this situation could only be addressed by moving to a platform where payments were linked directly to the back-office system records (held in IDOX Uniform).  This was not within the gift of the service without changes at individual partners leading towards fuller integration of the payment process with the issuing of licenses.

This idea was resisted in the early days of WRS but in more recent years, officers from the six partner authorities seemed more confident that this would be a suitable way forward, with one partner collecting funds and sending these on at routine intervals to the other partners.  The precedent of WRS taking payments on behalf of partner authorities (through the host, Bromsgrove) had already been set with stray dog fees for example, albeit in much lower overall values than income from Licensing.

The pandemic had taught us that, in terms of the automation of transactions, we were somewhat behind other local authorities across the country, and currently budget a significant spend on the administrative side of the licencing service, where others had moved to a digital first assumption, automating payment and upload of applications to the back office. The WRS Licensing team had made significant changes through the pandemic, moving to a single method of application collection, however, this still required the additional support of printing off the application details and then manually inputting the data into the Uniform database system.

Prior to the pandemic applications would reach WRS through numerous channels, causing delays in them reaching the teams and inevitably impacting service delivery and partner performance indicators, as detailed on page 2 of the Supplementary Agenda Pack.

This had been improved somewhat, with some streamlining of the process due to the pandemic but WRS managers felt that this could go significantly further with some initial investment.

WRS had also previously investigated the use of the website as a channel to receive requests from our customers for environmental health related matters.  We currently only had the option of supplying forms that, when submitted, came into the back office as emails for manual inputting into the Uniform database system for processing, allocation, and action.  This could significantly delay the customer journey and did little to enhance the service given.  Because of this, the service did not encourage this route as a method of engaging with our service. 

Last year only 18 requests for service were received following completion of our on-line forms. By contrast, 2,412 environmental health service requests were received by telephone and 7,922 were received by email.  This overwhelmingly demonstrated that our customers wished to engage with us through electronic means.

Given the wide adoption of “digital first” policies by the whole local authority sector, making the on-line route the key channel for engaging with services, it seemed at odds withthe direction of travel that a group of key service areas that generated significant income streams for the district councils should be left out of this policy approach. 

The development of the EU Services Directive before 2010 had led local authorities to be required to offer on-line application processes. Government provided this option through the .GOV website, enabling all local authorities to achieve compliance in the timescales required. There were, however, only a limited number of compatible payment engines that linked to this website so as partners moved away from these, the gateway had effectively been closed as a legal route into the service.

At present WRS could only accept applications from two districts via .Gov as the remaining partners no longer had a compatible online payment engine. Officers therefore manually received applications and payments for these applications.

Government was also keen to close the .GOV portal, requiring that local authorities made their own compliant arrangements, to continue with this duty. On-going dialogue indicated that Government’s preferred date for final removal would be April 2023. The LGA keeps pressing Government on this, for fear that ultimately the service would be withdrawn leaving local authorities that relied on it, to put in place their own solutions for accepting online applications at their own expense, at a time when the financial environment for local authorities was difficult.

Previously a significant volume of applications had come into WRS through .Gov, mainly relating to the Licensing Act 2003 and other licenses where large scale national operators were involved. E-enabling our own platform would provide a suitable replacement portal to .GOV.

Members attention was drawn to the ‘Proposal’. 

There were two elements to the proposal. Firstly, there was the request for investment into a platform that provided the customer the opportunity to raise a service request for environmental health or licensing matters and, to apply and pay online for a licence, permit or registration. The detail of such requests would then be automatically fed into the WRS back-office Uniform system.  This would significantly reduce the number of back-office staff and would release officers and free up resources on theadministrative and front end of the service.

The second element of this proposal would be to invest in electronic ID cards for the taxi trade. This would enable officers to implement the new Taxi Standards more effectively and tie in with the reporting requirements to record a range of offending, suspensions, and revocations on the national NR3 database system. WRS currently already spent £2.5k on ID cards for the taxi trade but would like to use that current budget plus £22k to now introduce electronic ID cards for them. Electronic ID cards would facilitate immediate checks on identity and status of drivers, ensuring better protection for the public when officers were out carrying out checks

The Head of Regulatory Services further drew Members’ attention to the ‘System and Costs’ information, and the approximate costings from several suppliers, as detailed on page 4 of the Supplementary Agenda Pack.

The advantage of the “off the peg” solutions was that they come with pre-prepared forms that drop onto your website and would link into the back office with some configuration. Both were both more expensive in terms of initial investment and on-going running costs, but they would give a front end that was stable, used by others and presumably any changes in legislative requirements would be addressed by the supplier in amendments to the product package.

Doing nothing risked the service appearing to have been left behind and did not paint the best picture to potential customers for our income generation work in the absence of an online payment solution for in-house partner activities. 

Since all three approaches would require integration with existing systems including host finances, none of the options was cost free in this aspect. Therefore, whilst working with Idox would probably draw more of our in-house resource, it was likely to remain the lowest cost in terms of cash input.

The Head of Regulatory Services continued and in doing so referred to the ‘Benefits and risks’; and the assumptions, as fully detailed on pages 5 and 6 of the Supplementary Agenda Pack.

The Head of Regulatory Services highlighted that, should Members decide to take this project forward, that as detailed in the report; that there was potential for the shift to on-line payments to have more impact on particular communities in several districts, so officer members of the Board felt that, whilst in principle there were positives in the proposal, consideration should be given to equality impacts and, if necessary, some form of consultation be undertaken with the relevant traders in the area, particularly the taxi trade.

Members’ attention was further drawn to the financial considerations, as detailed on page 6 of the Supplementary Agenda Pack and the ‘Options Appraisal’ and the ‘Timetable for Proposal’ as detailed at Appendices 1 and 2 in the report.

The Head of Regulatory Services further informed the Board, that should they be in agreement with the proposal, that WRS would follow the procurement rules of the Host Authority, Bromsgrove District Council.

The Head of Regulatory Services responded to questions from Board Members with regard to:-

·         Electronic ID cards

·         Equalities impact

·         Liaison with the taxi trade

·         Licensing Surgeries / phone help

The Head of Regulatory Services reassured Members that the group that although the group that was initially established to look at this project, pre-covid; that the figures provided, within the report, had been given on several occasions, and that the costings given last year would not significantly increase.  Should there be any additional costs, WRS held reserves would be used to meet those costs.  He would reassure the Board that he would do his very best not to come back to partners within the next 12 months for additional funding.

Councillor S. Khan, Redditch Borough Council, expressed his concerns with regard to customers who were less IT literate being able to access services that were available on-line only.  Councillor Khan therefore asked if this could be reflected in the Recommendations and that the Recommendations be amended to include the relevant working.

Councillor Khan was reassured by the Technical Services Manager, that there was no intention of withdrawing Licensing Surgeries or existing phone help for customers.

The Head of Regulatory Services reiterated this and explained that, as detailed in the report; that there was the potential for the shift to on-line payments to have more impact on particular communities in several districts, so officer members of the Board felt that, whilst in principle there were positives in the proposal, consideration should be given to equality impacts and, if necessary, some form of consultation would be undertaken with the relevant traders in the area, particularly the taxi trade.

Having taken into account the concerns raised by Councillor S. Khan, Redditch Borough Council and on being put to the vote, it was:-

RESOLVED that the Proposal for Transaction of WRS Services report:-

(i)            be noted;  

(ii)          that Members agree in principle to the creation of a reserve, in the amounts outlined in the report;

(iii)         that Members agree that a detailed project plan be produced to be shared with and reviewed by Partner Officers of the Board, with progress reported back to future meetings of the Board; and

(iv)         that while Partner Officers of the Board work together to identify a suitable solution, that they also investigate any potential equalities issues that may arise; ensuring that support continued to be provided to those who required it.