CIVEA responds to CSJ report, Still Collecting Dust.
“CIVEA is disappointed by the failure of the Centre for Social Justice to fully engage with the enforcement industry before publishing this report. Unfortunately, the points made in this report are undermined by incomplete research, partial responses, assumptive analysis and a lack of robust data. As representatives for the majority of enforcement firms across the country, Our industry insights could have negated assumptive inaccuracies and helped to provide more reliable and robust findings.
Problems include attempts to ‘normalise’ figures from recent freedom of information requests for inclusion in this report, such as claiming more liability orders are issued than penalty charge notices, which is factually incorrect. Last year, 4 million penalty charge notices (road and non-road charging) were recovered through enforcement action, compared to 1.6 million council tax arrears cases passed from local authorities, of which a third of liability orders are returned without action. The report also attempts to make a correlation between arrears and collection by implying improper use of civil enforcement regulations, discount schemes and vulnerability. Debt collection practice in the commercial sector is often held up as an exemplar for its engagement with the money advice sector, communication with customers, support for vulnerable people and affordability assessments for repayment plans. All of these practices can be seen in the enforcement industry and, as in private debt collection, have become integral to daily operations. Enforcement firms use the same technology to engage and assess the ability to pay as the best debt collection firms. However, council tax is a regressive tax that impacts more people on low income and therefore more people are in arrears, which has nothing to do with how it is collected.
By consulting the industry, CIVEA would have helped to avoid misinterpretations being presented as facts. CIVEA has committed to work with the Enforcement Conduct Board, which was set up and funded by the industry, to provide fresh insight which will improve on commentary that does not hold up to scrutiny. We will continue to gather independently assessed evidence transparently and to the highest standards of rigour.”
Note to editors:
Enforcement firms have invested in a range of compliance-related infrastructure that was not part of cost bases used to derive the original 2014 statutory fees. Examples include Breathing Space administration costs, GDPR and Subject Access Request costs, body worn videos for enforcement agents (voluntarily mandated by the industry), expanded welfare teams, vulnerability teams and audit functions, in addition to oversight mechanisms such as independent advisory groups and the Enforcement Conduct Board.;
Who is CIVEA?
CIVEA represents approximately 40 companies that make up more than 95% of the entire enforcement industry. We are not debt collectors and only undertake visits to premises after a local authority or public body has failed to recover funds and takes an individual to court under the Taking Control of Goods regulations 2013. The number of certificated enforcement agents fell by 33 per cent between August 2017 and January 2023.
Press Contact for CIVEA:
Joe Cuffaro, WSA Communications
Email: joe.cuffaro@wsacommunications.co.uk
Telephone: 01908 371177
CIVEA
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