Chris Nichols, CEO, Enforcement Conduct Board
August got off to a positive start with the timely payment of the levy from five of the largest enforcement firms. It is excellent to have received these funds, which are needed in order to progress our mission and the important work set out in our business plan.
Expanding our evidence base
A key area in which our funds for the year will be deployed is in the commissioning of research to improve our evidence-based understanding of enforcement action. I am excited about this work because, since starting at the ECB, one of the things that has really struck me is the lack of measurable evidence and data on what actually happens when enforcement agents arrive on people’s doorsteps.
Even though almost all doorstep interactions are captured by body worn video, I have not come across a proper analysis of this footage to give a sense of how often poor practice is emerging or of what the issues are, when it does.
This is important because the ECB needs to understand what is happening and where the risks are so that we can design targeted and proportionate responses that will be effective in eliminating harms.
So, we are planning to fill this gap by commissioning a piece of independent research, looking at a large sample of body worn video. And we are currently designing its core methodology which includes:
- Identifying the list of potential issues that we would like the researchers to look for in their reviews
- Producing briefing material for the researchers on the legislation and powers of enforcement agents undertaking civil enforcement work – we plan to focus on civil enforcement initially to keep the scope manageable and to allow greater depth of analysis in this area
- Developing a methodology that is consistent with GDPR legislation, with input from the Information Commissioners Office (ICO)- there is more work to do here but we are confident that we will arrive at an approach that is practical and proportionate in safeguarding personal data and which also allows the work to progress.
This approach is based on our work and engagement with stakeholders over the last few months. For example, from our engagements with the debt advice sector, we know that the misrepresentation of powers is a key area of concern that needs to be better quantified and understood. The research will help us to do so.
We will also be testing our ideas with both our engagement forum, which includes representatives from the debt advice sector and industry, and with the expert panels that CIVEA and the HCEOA helped us to set up.
We plan on going out to tender later this year with fieldwork work starting shortly after. We will update as the work progresses.
When the results of this research are ready, which we expect to be in the early part of 2024, we will also publish the results and the methodology in full so that everyone can see and scrutinise the results.
Engagement in Wales
In July we held our first Board meeting in Wales which, included an engagement session with Minister for Social Justice, Jane Hutt and Leader of Torfaen Council, Anthony Hunt.
This was a great opportunity to meet with them both to discuss how the ECB can progress our mission in Wales. We’ve had excellent support in Wales since our inception, including Welsh Water becoming the first utility company to publicly commit to only working with ECB accredited enforcement firms.
We expect to be able to announce that other big creditors will soon be making similar commitments and, following our productive session, we are hoping that other Welsh creditors will be among the next wave to do so.
To this end, David Parkin, our Director of Creditors and Government will be heading back to Wales in September to speak at the Welsh Local Government Association Conference about how Local Authorities can support the ECB’s mission.
Accreditation
In my last blog I promised to update on the launch of our accreditation scheme. I’m happy to report that following a productive discussion at our last Board meeting, the scheme remains on track for full launch in mid-September.
I will be doing a special edition CEO blog all about accreditation and what it means for enforcement firms, creditors, and enforcement agents when we launch next month – so please do keep an eye out for that.
Until next time!