Chief Executive’s Report, March 2025

Introduction

1. When the Board last met we had just launched our complaints scheme and since then, members of the public have actually started to use it. After the hard work that the team put in to building our scheme, it is incredibly heartening to see the team start to investigate and make a difference in real life cases.
   
   
2. It was also really positive to see us publish Version 1.1 of our standards with the new sections of guidance woven in. This guidance should really help firms and agents to ensure they are driving up standards and meeting all of the ECB’s expectations. The next big milestones in this regard is 30 April, when firms will need to provide us with a self-assessment of their compliance.
   
   
3. The backdrop to all of this was a positive meeting with the Courts and Legal Services Minister in March. The second round of levy collection is now complete and almost all of the licensing fees have been paid (with the final few due in April). The process has been very smooth and we are on course to realise our projected income for the year. A staged payment agreement has been made with one firm and they have one payment still to make. While this does impact the ECB’s cashflow, it is not detrimental to our operation.
   
   
4. Total expenditure for the year to 28 February 2025 is £1.06m against the reforecast of £1.11m, representing an underspend of approximately £49k. The largest variances comprise a £19k underspend of the legal budget and a saving of £13k from not bringing in additional financial support to assist with the annual budget. The management accounts also show an underspend of £9.8k on insurance however this is a phasing issue and we have now arranged for professional indemnity insurance at £7.5k. We are also underspent on staff travel and accommodation. As always, the budget is actively monitored and the Executive is confident that there are no areas of concern.
   
   
5. At the end of the year, after accruals are accounted for, we can consider any underspend from 2024/25 as being moved to strategic reserves.
   
   
6. The Board approved the draft budget for 2025/26 in January and the final budget has been brought to the Board for approval at this meeting. From next month, spend will be reported against the new budget.

Staffing update

7. Since the last Board meeting, we have welcomed our new Director of External Affairs into the team – Louise Rubin joined us on 27 January from Scope where she was Head of Policy and Campaigns. It is brilliant to have Louise on board to take on leadership of this area.
   
   
8. We have also progressed the recruitment campaign for a Risk and Compliance Principal who will lead the design of our oversight function. Applications for this role closed in mid-February and we are conducting interviews in March.
   
   
9. We are also pleased to announce that Holly Perry, currently the Director of Enabling Services at the Legal Services Board, has accepted the role of Director of Corporate Services on a 12 month contract, starting on 28 April. Jenny Prior will be stepping down from this role after a short handover period, with her last working day on 30 April.

Data Protection Update

10. We have made good progress against the Data Protection Implementation Plan presented to the Board in January. All staff have now completed both general data protection planning and have attended a half-day session in which the Director of Corporate Services, in her capacity as the ECB’s Data Protection Officer, provided training on how data protection and information security must be applied specifically to the ECB’s work and processes.
    
    
11. The Director of Corporate Services has completed the Certified Data Protection Officer training and the Board are in the process of completing the general data protection training.
    
    
12. Other recently completed tasks on the implementation plan include:

• data protection training added to the induction process and a new leavers process which specifically includes the removal of all biometric records from laptops
• Information Asset Registers for hard copies, retention schedule exceptions and destroyed and archived records
• A subject access request register and process guidance
  

13. Two actions that have been considered and found unnecessary are archive solutions for hard copy documents (no hard copy documents are kept, if this changes this will be revisited) and an auto-delete deadline for email inboxes (instead detailed guidance of what emails needed to be saved/deleted).
    
    
    

Accreditation

14. We are likely to receive applications soon for accreditation from two small civil firms.
    
    
15. Following a round of recent visits to councils by the Director of Creditors and Government, we have added Mid-Kent Services (which enforces for Maidstone, Swale and Tunbridge Wells) to the number of accredited in-house teams. This now stands at 9 and we hope to receive more applications soon.
    

ECB Standards Development

16. In early March, we published Version 1.1 of our standards which includes new guidance embedded in, covering areas including reasonable belief, contracting and remuneration and engaging with third parties. This guidance has benefitted from input from members of our panel of industry experts and debt advice experts and has also been reviewed by the Board lead in this area and the Chair.
    
    
17. In early March we also issued our request that all firms and in-house teams to provide the ECB with their self-assessment of their compliance with standards by 30 April. We will use their responses to establish a comprehensive view of the level of compliance across the industry and to identify individual areas of risk and concern to shape ECB operations oversight, which begins in earnest in April.
    

Complaints handling

18. Our complaints handling function went live on 6 January. So far, we have received 36 complaints, and we are receiving approximately six new cases a week.
    
    
19. As of 10 March, we have six live cases, three are at initial consideration stage (where we ask can we investigate the complaint), two are at further consideration stage (where we ask should we investigate the complaint) and one is being investigated.
    
    
20. All bar one of the 30 complaints we have closed, were closed at the initial consideration stage. 24 of those were premature in that the complaint had either not been put to the firm for consideration or needed to be escalated through the firm’s current complaints process or the firm hadn’t been given sufficient time to respond to the complaint. We have offered assistance to five people who struggled to pursue their complaints in escalating them to the relevant firm.
    
    
21. We decided not to investigate one complaint at further assessment stage because it was more appropriate for it to follow the council’s complaints process.
    
    
22. Even at this early stage, analysis of our closed complaints shows that approximately 40% (12) of complainants either reported, or we noted from their complaint form, that they had some form of vulnerability. The most prevalent being a mental health issue, such as depression or anxiety. What is not clear is whether the cause of those mental health issues was in part related to the enforcement activity.
    
    
23. On the whole, our complaints management system is working well so far. It has delivered on the promised functionality and enables us to easily see complaints through from start to finish, with firms and complainants able to access the system when needed. As with any new case management system we have had a few teething issues and we continue to work with our case management provider (Tizo) to sort those out as and when they occur. The issues so far have mainly related to automated email notifications and firms accessing messages via the online portal.
    
    
24. We now have Teams telephony in place and are in the final stages of setting up the voicemail system to manage incoming calls to us. For complainants, the system encourages callers to use the online portal as a means of keeping up to date on their complaints, while at the same time enabling people to leave messages if they need to.
    
    
25. We have also continued to make good progress on agreeing MoU’s with the LGSCO and PSOW. We have met with officials from both ombudsman schemes and are in the process of finalising the relevant drafts.
    
    
26. We expect the volume of complaints to keep rising over the coming months. We are planning to present a paper with some early insights on our complaints trends to the April Board, alongside providing a demonstration of the complaints system in action.
    

Creditor engagement

27. Following the arrival of the ECB’s new Director of External Affairs, we are considering a wider plan of engagement with creditors, particularly from the energy sector. We are likely to start with two energy firms that have indicated an interested in engaging with the ECB on approaches to vulnerable customers, which chimes in well with the ECB new standards here, which we are developing for the spring.
    

Communications and Engagement

28. Since the Director of External Affairs arrived we have delivered our routine contributions to the trade press and begun to increase our social media presence with a steady flow of Linked In and X posts. Over the coming months, we will review our approach to communications and develop a strategy that identifies our key audiences and makes recommendations as to tone and narrative, bringing this to a future Board meeting.
    
    
29. We put out a low key package of communications activity around the launch of our Business Plan consultation on 19 February, with further communications on our newly updated Standards on 6 March.
    
    
30. We have had meetings with a number of oversight and industry bodies since the last Board meeting. These include:
    a. CIVEA’s Executive Council
    b. The Public Services Ombudsman for Wales
    c. British Parking Association
    
    
31. We have also engaged with the debt advice sector at both our Stakeholder Engagement Forum and the Taking Control Coalition regular meeting.
    

Political strategy and public affairs

32. The Chair, CEO and Director of Creditors and Government (DCG) met the Minister for Courts and Legal Services, Sarah Sackman, on 27 February. The meeting was positive, with the Minister indicating her support for the ECB.
    
    
33. The meeting with the Minister followed a debate in Westminster on the regulation of the industry, led by new Labour MP Luke Charters. The Chair, Chief Executive and Director met Luke Charters MP before the debate to provide him with our arguments in favour of statutory powers, which informed his speech. In the debate, it was pleasing to hear the MoJ Minister (Alex Davies-Jones MP) refer to the “excellent work that the ECB has already done”.