Unison response to the business admin review

ContentsUnison response to the business admin review....................................................................................1

Introduction.......................................................................................................................................2

Overview...........................................................................................................................................3

Senior management..........................................................................................................................3

Core support......................................................................................................................................4

Business support officers...............................................................................................................4

Business support assistants...........................................................................................................5

Business support and administration team leaders.......................................................................5

Senior business support officers....................................................................................................6

Information and records management..............................................................................................6

Information and records management team leaders....................................................................6

Information and records management officers.............................................................................6

Information and records management assistants.........................................................................7

Information access manager (709586)..........................................................................................7

Support to Chief officers....................................................................................................................8

Personal assistants........................................................................................................................8

Executive officers...........................................................................................................................8

Other redeployment opportunities...................................................................................................8

Appendices........................................................................................................................................8

Appendix 1: Savings targets...........................................................................................................8

Appendix 2: Support to Chief officers supplementary documentation..........................................9

Appendix 3: Business support officer supplementary documentation........................................11

Appendix 4: Business support assistant supplementary documentation....................................17

Appendix 5: Information and records management supplementary information.......................18

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IntroductionThe Council indicated that it wanted to make savings of £1.75 million per year in business support and administration as part of the accommodation strategy (see appendix 1 as evidence). When the consultation period started this had changed to a figure of “at least £1.75 million”. It was not made clear to us or to affected staff what the figures for expenditure for business support services would be before and after the restructure and how it was decided which services would be subject to this review.

The proposed changes save far above the original £1.75m target, in a way which we fear is reckless and putting frontline service delivery at risk.

Furthermore, the Equality Impact Assessment was only completed two weeks after the consultation on proposed changes began. This makes it clear that the impact of the changes on people with protected characteristics was not considered in advance of the proposals being drawn up, which is deeply worrying. Especially as those in scope of the review are disproportionately female (71% compared with 57% across the Council), of black and minority ethnic (BME) backgrounds (46% compared with 37%) and disabled (7.2% compared with 3.3%), this is of concern and would seem to fly in the face of the public sector equality duty, which obliges public sector bodies to attempt to eliminate discrimination and to promote equality of opportunity.

That said, management have an opportunity to bear this in mind and to mitigate the impact of this review on women, BME and disabled staff, and our primary suggestion on how to do this is through adopting a policy of no compulsory redundancies. This policy would also enable Camden to hold onto valuable skills and experience which staff have, reduce unnecessary expenditure on redundancy/early retirement payments and additional potential costs in recruitment and agency cover after making staff redundant.

Even without making compulsory redundancies, UNISON has identified over £2.1 million in potential savings, which can be obtained by deleting 35.1 vacant posts and granting the 20 applications for early retirement/voluntary redundancy (ER/VR) which we are aware of (although of course there will have been more applications of which we are not aware so even more savings could be made).

Members are deeply unhappy that UNISON has not been provided with figures of workers applying for ER/VR. This has made it difficult to come up with a counter proposal and contradicts the Council’s commitment to working in partnership with the trade unions.

Our counter proposal based on no compulsory redundancies is in line with Council policy which is to try to avoid compulsory redundancies. Given the lack of information provided to us, please note that this counterproposal has some unknowns, and we are keen to work with management on finalising a new structure with no compulsory redundancies, and so repeat our request for figures on agreed applications for ER/VR to be provided as swiftly as possible.

In many areas we are concerned about the designation of posts as ringfence (alternative) as opposed to ringfence (oversubscription) or assimilation. As this could lead to large numbers of unnecessary redundancies, as well as unnecessary stress for staff made to re-interview for their own jobs. For a number of the posts, we believe that this designation is entirely incorrect, as the new post is

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substantially the same as the old post. If management does not take on board our feedback in this regard, we would consider any staff in the relevant posts being deselected beyond the necessary numbers to constitute unfair dismissal.

We strongly disagree with the proposal to downgrade the pay of the lowest paid workers in scope, from level 1 zone 3 to level 1 zone 2. We believe this is not only unjustified, as management recognise that the responsibilities of the new role are the same level as the current role, but is also cutting the pay of a grade of workers who are disproportionately from BME backgrounds.

Finally, we believe that there will be other redeployment opportunities elsewhere in the Council for staff at risk of redundancy, so we want to work with management to avoid compulsory redundancies, and want management to take all possible steps to avoid this. If compulsory redundancies appear likely, then Unison will register a formal dispute.

OverviewHere is a brief overview of our counter-proposal, which we expand upon and explain in detail below. In this table “n” represents the number of individuals in a ringfence who get appointed to a different role and “v” in the below chart indicates the number of applications for ER/VR, where v is equal to or less than the number of post reductions required in the management proposal.

Role No. Posts Level/zoneBusiness Support Manager 3 Level 5 zone 1Business support and administration team leaders

30-(v+n) Level 4 zone 1

Business support officers 114-(v+n+[no. senior BSOs]) Level 2 zone 2Business support assistants 19.2-(v+n) Level 1 zone 3Senior business support officer 12-v Level 3 zone 1Records Management officers (previously information and records management officers)

2 Level 3 zone 2

Information access officers (previously information and records management officers)

2 (including 1 based in school improvement)

level 3 zone 2

Complaints officers (previously information and records management officers)

6 (Same grades as currently)

Information access manager 1 level 5 zone 1Information and records management assistants

5-(v+n) Level 2 zone 2

Executive officers 21-(v+n) Level 3 zone 2Personal assistants 8.8 Level 2 zone 2

Senior managementFirstly, at a time of austerity, with years of pay restraint and hundreds of redundancies in Camden, we believe creating new, highly paid and unnecessary management posts is inexcusable. And that it was announced that the post would not be filled by any workers at risk of redundancy, but instead would be recruited to externally at a later date was experienced as a slap in the face by dedicated members of staff facing losing their jobs.

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We believe that the experience in CSF has demonstrated that an admin head of service is an unnecessary post. CSF, whose admin service is about as big as all the other directorates combined, deleted its head of service in a restructure in 2011/12, generating a significant saving. And service delivery has been completely unaffected.

So instead we propose that:

the service is managed by the Business Support Managers as there are three workers currently in post, we suggest that three are retained in the new

structure, in order to fund transitional posts lower down the scale.

Core supportWe feel we need to point out here that members believe that consultation in this area has been woefully inadequate. We provide vital support for frontline services supporting Camden’s most vulnerable residents. Management claim that the core support offer is based on the need they have determined, however you have refused to provide any evidence of this. And members are extremely suspicious that on the basis of a detailed exercise determining need that the number of business support officers and assistants comes to exactly 100 and 10, respectively. As these seem very much like arbitrary round numbers which happen to be lower than the current numbers.

We are also deeply concerned that management have not modelled the impact of these job cuts on the workloads of remaining staff, which could jeopardise service provision to the public.

Many members also felt that there was not much appreciation from management on what we actually do, day-to-day. Especially with respect to talk of rotating people around different tasks. As while it is true that the general skills to perform one of the business support officer/assistant jobs may be the same, many of them are very specialist, and take a significant amount of time (2-3 months or more for some posts) to learn to do. We note that the rhetoric around this rotation has softened since the start of the review, with the rotation being talked about being more like on a six monthly, as opposed to more frequent, basis. However we would like to point to the experience of CSF, where admin officers were put on generic job profiles back in 2008, so that they could be rotated. But our knowledge not a single person has been rotated, basically because it is impractical to do so due to the length of time it takes to learn a new role.

UNISON has no objection to staff moving post and learning new skills, however we believe this should only be for workers who want to. And there have to be sufficient staff in place to train someone new to an area.

Also, on a general note we believe that the removal of the mid-level grades in this area effectively eliminates career progression for administrators. We believe this will have a detrimental impact on staff motivation and retention. Therefore we are proposing the maintenance of a higher grade post, a senior admin officer or project post, to give staff the possibility of improving their skills, taking on more complex work, budget monitoring or supervising staff.

Business support officersWe are concerned at the drastic reduction in posts numbers (141 down to 100), and the effect this will have on service delivery and workloads. So we propose that:

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instead of cutting numbers down to 100, management grant requests for ER/VR at this level, to avoid making compulsory redundancies, and having to interview such a large group of workers

even if the remaining cohort is larger than 100, instead of selection and compulsory redundancy, recruitment is just frozen and the numbers gradually reduced by natural wastage. This will save money on redundancy pay, save time on a huge number of interviews, save stress for staff and will help keep valuable knowledge and experience, so people can train colleagues when they leave

to remove the senior administrative officers from this ringfence, and instead propose the creation of a new post, detailed below.

See appendix 3, below, for more information and individual responses from workers ring fenced to the business support officer role, illustrating for example the complexity and specialist nature of some of these posts.

Business support assistantsThis role is of particular importance in this review. Firstly, it is of course the lowest paid, and secondly it has the highest proportion of BME staff (57%). And it is facing not only the second largest cut in posts, but crucially an overall reduction in the grade.

Cutting the pay and sacking the lowest paid and most heavily black and minority ethnic section of the workforce would seem to be a discriminatory act, and would seem to go against the Council’s stated intention of reducing economic and racial inequalities.

We also do not accept that it is a lower level of responsibility than the current roles. Indeed, by designating the post as a ringfence (oversubscription) post management are accepting the new role is substantially the same as the old. Therefore by the same logic the evaluation of the grade should not change.

Therefore we propose that:

numbers at this level be reduced solely by ER/VR as a transitional step, and subsequently further numbers be reduced by natural wastage

these staff are given adequate training and development opportunities in order to be in a good position to advance and be appointed to higher graded posts in future

that the downgrading of the role be stopped, and it be graded at level 1 zone 3.

See appendix 4 for evidence and responses supporting these requests.

Business support and administration team leadersMembers are concerned here that insufficient numbers are proposed to be able to adequately support supervisees and services.

Therefore we propose that:

the number of posts in the new structure as a transitional step should be reduced only by ER/VR as a transitional step, and that further reductions should be gradual by natural wastage.

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Senior business support officersDue to the lack of possible career progression in the new structure, the low number of team leader posts, and the need to reallocate more complex work like budget monitoring, we propose:

the creation of a senior business support officer post, to engage in complex, specialist and project work, budget monitoring and/or line management of some business support officers and assistants, for example the child protection conference minute takers, SEN and psychology and integrated youth support service

that this role is equivalent to the current senior admin officer role (level 3 zone 1), and so those workers could be assimilated into this role. It could also be equivalent to some other roles, like business support officer (level 3 zone 1) so these workers should also be eligible for this ringfence

that 12-v of these posts be created.

See appendix 3 for more evidence on this point.

Information and records managementSee appendix 5 for more evidence and detailed responses for this segment.

Information and records management team leadersFor this post we propose that:

some candidates for this post should be ringfence (oversubscription) as the new post is substantially the same as the previous post

the number of posts should be reduced by the number of applications for voluntary redundancy, up to 2, as an interim measure

considering the information access manager (710896) as one of the information and records management officer posts, and moving it into the school improvement service, as it is responsible for highly specialist SLA work which sits in school improvement and which other services buy into (up to £30k) making it substantially self funding. Or if this is not agreed also ring fencing this post to an information and records management officer post (see next section)

an additional post could be maintained for a set period of time to work through the backlog.

Information and records management officersDue to the highly specialist and statutory nature of this work, in addition to the huge and increasing workloads and backlogs of up to 3 years in some instances we feel that management’s proposals are unworkable. Workers simply do not have time to spare to train the rest of the team to perform their specialist individual tasks, even if this were desirable. Also, the designation of all of the posts as ringfence (alternative) creates the real risk of unnecessary compulsory redundancies. Which we believe would create unnecessary expense, and would also be “unfair” on the basis that the new jobs are substantially the same as the current jobs (as in the new structure the complaints officers will not be doing data protection/FOI work, and the DPA/FOI workers will not be doing complaints).

Information access officers can only process around 350 FOI requests per year – the Council receives 1800 not to mention over 300 SARs and the 85 case SAR backlog.

Therefore we propose:

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moving the two records management posts out of this team, into the corporate records management team by assimilation on the same grade (if this is not agreed, then instead we propose moving the two posts directly into this section by assimilation)

matching the information access manager (710896) post to this section as well as a ringfence (oversubscription) (if moving it into school improvement is not agreed)

instead of a generic information and records management officer post, creating two sub teams containing:

6 complaints officer posts (on the same grades as currently), linked to directorates (2 to CSF, 2 to housing, 2 to ASC) into which current complaints officers can be assimilated. At least until such time as there is a corporate complaints review.

2 information access officer posts (level 3 zone 2) into which the current FOI/DPA/EIR officers can be assimilated

to maintain departmental links with individual officers to provide additional staff, at least in the short term, to cope with the workload and to deal

with the CSF backlog.

See the subsections of appendix 5 for detailed additional information and justification on these points.

Information and records management assistantsFirstly with this role we believe that the proposed new job is substantially the same as the current one. Therefore we reject the idea it should be a ringfence (alternative) and think it should be ringfence (oversubscription) or assimilation. If more staff than necessary were deselected through a selection process at this level we would consider this unfair dismissal.

With this role, we (Unison, supported by nearly all staff in scope) believe management are mistaken in their proposal to have these workers log all complaints, information and subject access requests. As this is not a simple logging exercise as sufficient assessment is required in determining how to deal with even the initial stages of any of these requests / complaints including identification of wider issues. And having somebody else log these would not save time for officers but would be a duplication of work.

Due to the high workload and backlog, we are also concerned that the new structure may have insufficient staff to cope.

Therefore we propose:

to remove logging all complaints/requests from the list of tasks for this role to designate the role ringfence (oversubscription) rather than ringfence (alternative) to reduce the numbers of staff by the ER/VR only as an intermediary measure, and if

necessary make further reductions by natural wastage.

See appendix 5.4 for more evidence and information on this role.

Information access manager (709586)This role was originally created when a previous role was split into two, resulting in the creation of the information access manager and corporate records manager posts. We believe it is inconsistent,

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therefore, that one of these posts is just being deleted, especially as we believe that the post being deleted contains a BME member of staff, whereas our understanding is that the other post does not.

Due to the continuing high workloads in the service area, we propose keeping this post, at least for a transitional period of one year.

Support to Chief officers

Personal assistantsWe believe that this job is substantially the same as the current work undertaken by the executive assistants on SO2 (see appendix 2 for evidence of this). Therefore we propose:

that SO2 executive assistants are marked as ringfence (oversubscription) to these posts that by the same logic, of these posts being substantially the same, they should be graded at

level 3 zone 1 that SO2 executive assistants should be able to apply for the executive officer posts on a

voluntary basis.

Executive officersWe propose that:

the higher graded staff in this ringfence, already on level 3 zone 2 should be down as ringfence (oversubscription) rather than alternative, as we believe the new post is substantially the same as the old post

the number of posts should be at least 8, to ensure that the workload can be covered, at least for a transitional period

as outlined in the previous section, the SO2 executive assistants should be able to apply for these posts on a voluntary basis.

Other redeployment opportunitiesIn the event that management does not agree with UNISON’s proposals, we would instead demand that the following steps be taken to make every effort to avoid compulsory redundancies:

providing us with a list of all agency workers across the Council, where they are engaged, what they are doing and what their level of pay is

providing us with a list of vacant administrative posts elsewhere across the Council, including schools

working with UNISON to redeploy staff in alternate positions where necessary, providing additional training to staff to help them be appointable to

alternative roles.

Appendices

Appendix 1: Savings targetsScreenshot of essentials homepage about the admin review:

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Appendix 2: Support to Chief officers supplementary documentationEvidence and additional information from workers matched to the Support to Chief officers segment.

2.1 See attached the old attached HASC executive assistant job profile

2.2. See attached the new PA job capsule with similarities marked

2.3 Index detailing job profile similaritiesNew Job Capsule Current Job ProfileAdmin Support Page 1 – item 1Planning Page 4 – item 6Data Collection and Analysis Page 1 – item 6

Page 2 – item 9Diary, Event and Correspondence management Page 1 – item 2Customer Service Page 1 – item 4Assessment Pages 3 & 4 – items 3, 4 and 5

2.4 Individual comments from an executive assistant1. What sort of information gathering/investigations took place in order to establish the work

that is done on a day to day basis by the current Executive Assistants? As I understand it, no discussions, interviews or time and motion studies were conducted with the EAs in C&E and I can therefore only assume that the information gathered about the C&E EAs current day to day responsibilities has come from discussions with managers who form part of the steering group or from merely looking at the current job descriptions. I do not believe that this is an acceptable way to fully understand the role that the EAs carry out. Any assessments

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resulting from this inadequate process about how long each task takes, how frequently it occurs and the level of complexity are therefore baseless. Without doing this sort of detailed assessment of current responsibilities, how can you quantify how much time existing EAs spend on particular tasks and therefore go on to quantify the proportion of the role that does or doesn’t stay the same in the new proposed structure and whether the old and new roles are/aren’t fundamentally the same/sufficiently similar etc…?

2. If a proper investigation had taken place, you would know that management of portfolio meetings is already undertaken separately in the C&E Directorate by Sandy Grove (not an EA) as it would be in the proposed new structure. You would also know that the remaining workload for each C&E EA (on a 1:1 basis for each AD) fills an entire working day or more. I would like to know how you propose that this workload can be doubled (by looking after 2 ADS) and still achieved within the same amount of time. I would also like to know how you justify effectively renaming the role that the current C&E EAs carry out as Personal Support Assistants, doubling the workload and reducing the pay grade by two levels?

3. From experience of the previous EA review within C&E, the staff affected by the review strongly pushed back against the new structure and how management supposed that it would work without having any true understanding of how the EAs operate and the relationships with other support staff (in that case PAs, in this case PSAs). It is a complex, intricate and nuanced way of working and there doesn’t seem to be any true understanding of that. For example, the job capsule of the proposed EA role states in relation to correspondence: ‘Provide high level support in the management of correspondence relating to portfolio holders, freeing up chief officer time and building capacity. The job capsule of the proposed PSA role states: Provide high level support in the management of correspondence, including inbox management, freeing up chief officer(s) time and building capacity. It seems to me that the only difference is that EAs deal with portfolio holder correspondence and PSAs deal with all other correspondence. But how does that work in reality? It doesn’t. Are you suggesting that the PSA is who is managing the inbox sees an email from a Councillor and they identify whether that Councillor is a portfolio holder or not. If not, they deal with the enquiry, if it is, they read on further to establish whether the enquiry relates to the portfolio or not (very often portfolio holders will email ADs about issues within their constituency but outside of their portfolio remit). If not, the PSA deals with it, if it does, the PSA passes it on to the EA? Doesn’t that overcomplicate matters? And if the EA isn’t managing the inbox how will they know there is any correspondence to reply to? Does that require the PSA to forward everything on to them? What if there are several emails in one long chain? The EA would most likely end up managing the inbox themselves too, meaning two people are doing it at once. What is the system for that? How will duplication be prevented? What if correspondence from a portfolio holder contains a number of queries some relating to the portfolio but others not? How is that dealt with? And on it goes…… You may think that this is needlessly getting down into the nitty gritty, but this is the important stuff. I am not trying to be awkward. This is how the EA role works on a day to day basis which you have no understanding about and if these fine, intricate elements aren’t clear it creates a monster of a process. This is just one small example of many.

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4. The consultation documents imply that the Executive Officer roles will be ‘floating’. This will not work in practice. For an EO to maintain a strategic oversight of a portfolio(s) they need to be assigned specifically.

5. My extensive experience of working as both a PA and an EA for ADs and the Director have shown to me that the most effective structure would be to maintain a 1:1 support for all ADs and Directors at the existing EA level. I also suggest that Member Services take on the responsibility of managing portfolio work instead of assigning it to the new EO roles. I appreciate that savings need to be made and these could be found through eliminating the lower grade support roles (DSOs, PAs) etc. In my experience it is consistently challenging to recruit staff for current EA roles who are of the calibre desired by ADs/Directors and who possess the nous and strategic thinking to be able to do the role well, as well finding staff who will stay for a good length of time. Recruitment and retention is a huge problem, at least in C&E. By turning the EA role into a PSA role by effectively reducing the grade and pay level, as well as doubling the work load, the problem will only be exacerbated.

6. In the event that no changes are made to the proposed structure, I strongly suggest that one or more 6 month fixed term contract transitional EO roles are added to the proposed structure. The changes that you have put forward are significant with a large number of redundancies and major alternations to job descriptions. In addition, all the changes take place over a period of time where the Council will be experiencing some significant organisational changes itself with the move to the new building. With the review coming into effect in the middle of this there will undoubtedly be a bedding in period whilst the new way of working is established. The fixed term role(s) would add a buffer of essential support to ensure that service to DMTs, Councillors and stakeholders does not suffer at limited cost to the Council.

2.5 Individual comments from another executive assistant1. If some of the present EA’s were not successful for the EO roles, the council would lose skills

that are not easy to recruit. EA roles in C&E have been notoriously difficult to recruit and retain to because of the high level of knowledge, skills, expertise and behaviours required.

2. If recruitment and retention to the current EA roles is so difficult, how will the PA’s be able to do that job at a lower paid salary and have to look after 2 ADs. How will they keep the PA’s in that role with loads more work and a lower salary?

3. The EO role has a huge work load – I know as I am doing it now as an EA. 6 across the council is certainly not enough. This figure should be increased to at least 8 minimum. Working with portfolios is a huge amount of work.

Appendix 3: Business support officer supplementary documentationEvidence and individual responses from workers ring fenced to the business support officer role.

3.1 Comments of child protection minute takersSUMMARY

We note the proposed restructuring of the administrative service does not envisage a dedicated child protection minute-taking service. Nor does it provide for a dedicated supervisor co-ordinating that service.

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We submit that a pool of dedicated minute-takers is needed to ensure a high-quality service for our customers. This is because of the particular skills and personality needed to be a competent child protection minute taker; the benefit to the smooth running of the service of having a small team working closely with conference chairs; the depth of knowledge, skills and experience needed to do the job well; and the time-consuming nature of the training. Conference Minutes are used by the Local Authority in any legal proceedings.

We propose that the new administrative structure includes a dedicated minute taking service. Should there need to be a change to the current structure where only Safeguarding Administrators are minuting Child Protection Conferences, the most sensible change would be a pool for Child Protection and Vulnerable Adult meetings.

We propose that the new structure retains the current supervisory role at senior administrative level. The senior administrative role of co-ordinating the service is essential. It is a full-time job in itself and requires someone to monitor performance of the service closely; co-ordinate, supervise and support the minute takers; ensure that social work practitioners and administrators alike are performing their roles in convening and conducting conferences correctly and promptly to maintain the standard of the service.

SKILLS

Child protection minute taking requires a particular set of skills and a particular level of emotional intelligence that not every administrator has:

Particularly good written communication skills;

Particularly good listening ability;

The ability to concentrate for a long period (conferences can last for up to four hours, with over twenty people in attendance);

An ability to assimilate, understand and translate into plain English the jargon used by all sorts of professionals: psychiatrists, youth offending service workers, housing workers, speech and language therapists, educational psychologists – the list goes on and on.

Not all competent Administrators make competent Conference Minute Takers

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Other Qualities

Resilience: minute takers are exposed to distressing information at conference – doubly so, as they re-live the conference when typing up the minutes. In our experience some otherwise highly competent administrators have been unsuitable for the role due to a lack of resilience.

Professionalism: minute takers need to respect the information shared in conference as highly sensitive and confidential. All information heard in the Conference is heard on a “need to know” basis. If a large number of Administrators undertake the role of Conference Minute Taker we would not meet this level of confidentiality. A requirement of the Conference Minute Taker is to sometimes minute meetings about our colleagues (LADO Meetings) which obviously need to be kept strictly confidential. A large pool of Minute Takers would not ensure this level of confidentiality

DEPTH OF KNOWLEDGE

Acquiring the deep and specific knowledge necessary to do the minute taking role to a good standard requires being exposed to and immersed in child protection work, either as a dedicated child protection minute taker or as a member of a children’s social work team dealing with child protection issues.

Administrators ‘dipping in and out of child protection work’ as well as performing other duties across the council will be severely hampered in terms of opportunities to gain that depth of knowledge.

TRAINING

It requires an experienced existing minute taker to train a new minute taker (assuming this person has the capability to learn this skill), and the process typically takes four to six weeks. It is not uncommon for the process to take longer depending on how much time the trainer and trainee have available and on the trainee’s learning style and speed, whilst the Conference Minute Taker maintains their own work and responsibilities. An incompetent Conference Minute Taker will have a “knock on” effect on the Chair’s time restraints as they will have to spend a lot of time correcting Minutes before they can be sent out.

3.2 Response from two business support officers in HASCWe have received confirmation that the posts (709894.Business Support Officer – Level 2 zone 2) and 709897.Business Support Officer - Level 3 zone 1 will be deleted and will be included in a ring -fence (over subscription) for the position of Business Support Officer at Level 2 Zone 2.

The response below relates to the post 709897.Business Support Officer - Level 3 zone 1 which one of us has been covering during a secondment and which is the other’s substantive post.

Our concerns are:

a. The proposed core offer does not include budget monitoring – an essential activity for the 709897.Business Support Officer - Level 3 post.

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b. The proposed staff structure does not include Level 2 posts to manage work of significant complexity.

We believe there would be a significant budgetary and reputation risk to the council if the support currently being provided to the Joint Commissioning Teams stopped.

This post carries out budget administration across a wide range of joint commissioning budgets by ensuring income and expenditure is on track. It also manages the governance of funding transfer agreements between the NHS and the council.

Section 256 – Transfer of funds

The post collates governance documents between NHS and the local authority (S256 and S76 Memorandum of understanding) and co-ordinates the annual process of updating, validating and sign off between Camden CCG and Camden Council. Funding is dependent on the timely sign off of and accuracy of these agreements. The post raises invoices based on S256 agreements and works with Finance contacts in Camden CCG to ensure annual income from the NHS of £12,352,839.03. This will increase to circa £19m with the implementation of the Better Care Fund. The post also carries out end of year reconciliation and submits this to both the local authority finance team and also to the NHS teams.

The post provides financial administration of expenditure across various mental health and public health commissioning budgets, across 85 purchase orders for £14,627,369.86 each year.

Q - Why is further governance needed on top of Ebuy processes?

A - unlike Oracle (used in the CCG), Ebuy does not have the inbuilt capacity for the budget holders to authorise release of funds for payment of invoices. It also is not as robust as Oracle in setting up purchase orders.

Co-ordinated governance needs to sit behind high value purchase orders to reduce duplicate or inaccurate invoices being receipted, or of providers continuing to receive payment when under-performance had been identified, or of late payments on sensitive contracts.

This post provides reconciliation at end of year on budgets administered through Ebuy using Cedar.

This post also provides assistance with monitoring of other budgets. In particular that of the Clinical staffing budget for Camden Learning Disabilities Service. The post provides regular updates on variance on a budget of £1,240,756.

Q - Why is this needed?

A - Because high value purchase orders for service level agreements with providers like C& I do not provide enough detail to drill down into the staffing budgets. A purchase order for £800,000 pa with C&I will show as approx. £215K per qtr. expenditure on Cedar. This post reconciles individual staff costs across 5 clinical staffing groups with invoice backing from C& I so that each clinical team has a picture of how vacancies and agency are affecting the budget. From this we are able to drill down into department, down to staff members to identify costs and to understand how the budget might

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move during the year. This level of information would not be kept in Cedar to be viewed by a financial advisor and would not be kept by the service head.

The outcome of the activity above is to enable commissioners and service heads to more effectively manage their budgets, to ensure timely payment to providers and to protect Camden’s reputation.

Both the work on the section 256s and the CLDS budgets are not undertaken by the finance teams nor do they have the capacity or structure to do this.

In conclusion, we believe that the complexities and inter-relation of health and local authority payments, the degree of autonomy and responsibility involved, of problem solving and working with others on all levels warrants this post being graded at Level 3 zone 1.

We believe that if the co-ordination and continuity of having a resource within the Business Admin Team were to stop, it could significantly affect the administration of budgets.

3.3 Collective response from Unison members in Special Educational Needs and psychology We have very serious concerns about the proposed centralisation and generalisation of the service in the proposals.

Our service provides a statutory framework for assessing, delivering and monitoring support for those children who have the biggest barriers to achieving the best learning outcomes. It is a service essential for these children to gain equal access to an education. As a statutory service, it has to be mindful of statutory time limits as well as being ultimately held to account through a tribunal system.

Administrative support to this service has to be of a quite specialist nature. It requires a detailed knowledge of the processes involved both internally and potentially externally and cannot be based on ad hoc arrangements as appears in the proposal. There are a range of functional links as a multi-agency approach is often a key to accessing the support children and young people require. The Business support is essential to co-ordinate and record a range of panels that make decisions about the support children and young adults require.

There also has to be a highly sensitive and complex interface with the service users. Support that doesn’t meet these standards could result in the Authority not only losing credibility with the service users and partner organisations, but could also cost the Authority money. This support has to be delivered when professional members of the service are ‘away from the office’ for many days at a time. Over the years the administrative support has on occasions been increased to ensure service delivery, even in the face of austerity cuts.

Unfortunately the timing of the review could not be worse. The statutory basis of the service is changing as new legislation comes into force from 1st September 2014, the Children & Families Act 2014. The Authority’s responsibilities will increase:

The student range goes from 2-19 years old to 0-25 years old, The time limits will reduce from 26 to 20 weeks, It is estimated that the complexity of the cases will involve more agencies than before, An enhanced monitoring and review process, The need to transfer all existing arrangements for students (Statement of SEN) to the new

framework (Education, Health & Care Plan), The introduction of a multi-agency ‘single planner’ role requiring both professional and

administrative support,

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To Whom It May Concern

Working within a published ‘Local Offer’ framework.

Although the these changes will come into effect immediately some, will develop significantly over the next four years possibly to a greater extent than now. To make these changes at this time as you will agree will further complicate the work of the service and could lead to unnecessary problems for the Authority.

We believe the best administrative support to the service should be managed within the service. On this basis it will be responsive to the changing demands of the service over the next four years. The size of the team should be maintained over this period to provide stability for the major changes that will result from the new legislation. The business support provided by the new proposal will not meet the demands of the service even without the changes that are due to take place and would leave the existing service in danger of ‘failing’. This could be a costly mistake for the Authority and we ask that an alternative, which involves locating the Business Admin support within the service, is seriously considered.

3.4 Comments from a senior admin officer in MALT In addition to the issues raised by the Child Protection Administrators that minute Child

Protection case conferences and other professional meetings there is the minuting of the Fostering and Adoption Panels. These are all day meetings, requiring tenacity and skill to write complex minutes of highly confidential meetings. In the paperwork for these meetings are the life stories of potential foster carers and adopters that includes information about their relationships, physical and mental health for example.

As someone who has minuted these meetings and child protection case conferences, Panels are like 5 or 6 case conferences in one day, dealing with personal issues of both the children and the adults that are highly confidential. Therefore these meetings need to be minuted by only a small group of people and would fit with the team that Unison speak about in their response to the consultation.

The other factor about these meetings is the gathering of the paperwork for Panel meetings. Each case requires a number of reports and information from different sources, including staff in fostering and adoption team, staff in Children in Need teams and other professionals, including the Medical Adviser etc. This is a task and a half getting all this information together by the tight timescales that are needed to ensure Panel Members receive the paperwork in sufficient time before the meeting.

After the meeting, in addition to writing up the minutes workers need to prepare detailed letters for foster carers or adopters in a timely manner to meet deadlines set out in the Regulations. Therefore these members of staff need time after the meeting to do this in a timely manner to meet these Regulations.

To reflect the complexity of this role they are currently graded at Level 3, Level 1. There will be no change in the expectations of the workers performing this role but they are being downgraded to Level 2, Level 2 and will be sitting and working alongside colleagues who will not need to have such a high level of expertise in minute taking. What is the logic for this? This will also be demotivating for the workers involved.

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This restructuring of the administration service does nothing to enhance the career progression of workers and makes the gap between front line staff and managers even greater. Only by moving out of an administration role into another support role in the Council will anyone be able to have any chance of moving from the equivalent in the old grading structure from Scale 6 to PO3! This widens the current gap considerable from the current position of SO 1 or 2 to PO 2.

Appendix 4: Business support assistant supplementary documentationEvidence and individual responses from workers ring fenced to the business support assistant role

4.1 List of current tasks undertaken by one of these jobs, compared with scale 6

Scale 4 Scale 6Indexing IndexingScanning ScanningE-buy E-buyCore Support Inbox Core Support InboxStationery/office supplies Stationery/Office suppliesManagement Service Inbox Management Service InboxEquipment booking (Laptop/Projector) Equipment booking (Laptop/Projector)

I-casesCommercial Waste Commercial WastePhone cover for team meetings Phone cover for team meetingsOne Print One PrintMail Merges and Mail outs Mail Merges and Mail Outs

4.2 Response from another scale 4 admin assistantMy argument is SC4’s (Level 1 Zone 3) should remain the same grade or higher because we are already doing SC6 (Level 2 Zone 2) tasks.

The following job tasks illustrate the point from a C&E perspective. Here are just some of the tasks that both SC4 (Level 1 Zone 3) and SC6 (Level 2 Zone 2) are doing – there is no difference.

Service specific

Workflow allocation, PCN Cancellation, Parking Service inbox, Commercial Waste contracts, Bin deployments and repair, Fix penalty notice, Regulatory flare reports, RIDDOR reports, WISH referrals, PARQ Sports welcome survey, CAHT sport Vouchers, Class registers, Shape up, CINTAS retrieval

Core Support

Commercial waste deletions, Indexing, Engineering and Sports inbox, I casework, Paper order, Water bills, e-buy

4.3 Response from another scale 4 admin assistant in culture and environmentComparison of tasks between scale 4 and Scale 6 administrators:

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Tasks Scale 4

Scale 6

Basement - Case file retrieval

Basement filing - Planning

Clearing up files

Committee PowerPoint presentations

Committee agenda

Crystal reports

Decisions - Planning

Decisions GOL

Decisions Section 106

Members briefing

Planning & Trees - Indexing

Planning & Trees - Scanning

Revisions

Section 106 emails

Section 106 filing

Site notices

Site Notice Preparation

Statutory register filing

Weekly list

Appendix 5: Information and records management supplementary informationEvidence and collective/individual responses from workers ring fenced to the information and records management segment

5.1 Collective response from all matched to the information and records management officer and team leader rolesAll of the staff who have agreed this response have had their posts transferred to the new Information and Record Management Team that is referred to in paragraph 6.6 (2 x Team Leaders) and paragraph 6.7 (10 x Information and Record Management Officers) of the consultation document.

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The views and comments expressed below are the views of us all (please note that some of the staff within scope are on leave and it has not been possible to consult them). Please take these comments into account as part of the consultation exercise

1. It is not easy to understand the basis on which the 10 posts at Management Officer level have been selected. For instance, so far as complaints are concerned there are 6 posts (2 from Children Schools and Families (CSF), 2 from Adult Social Care (ASC) and 2 from Housing (HG) and yet there are no posts from Culture and Environment (C&E), Finance (FN) or Parking (PK) so far as complaints are concerned. If complaints in these 3 services are to remain within those services it begs the obvious question as to why this is so and why cannot the complaints process for CSF, ASC and HG remain within their respective service areas. We believe that the council’s best interests lie in leaving the complaints process for all areas remaining within the service area they support and in which they are already imbedded and to which they add value. If, however, complaints from all services in the council (i.e. C&E, FN and PK) are to be dealt with by this team then the obvious question is “where are the resources coming from to deal with this substantial extra workload). Can we please have clarity about which service areas will be included in this new structure so far as complaints are concerned. Similar clarification is needed so far as FOI/DPA/SAR/EIR requests are concerned. If (as suggested by Management during this consultation period) complaints and information requests from C&E, FN and Parking are indeed to be included then we would have grave reservations about the ability of the team to cope with the substantial extra workload (as much as a third extra).

2. The decision to have completely generic job capsules (job descriptions?) can only be seen as an exercise in "dumbing down". The belief that anyone can do anyone else’s job and that we are all interchangeable must mean, by definition, that Management is moving away from the current situation which has encouraged staff to build up a solid experience and knowledge base about a specific area of work. This has enabled staff to add real value to the area they work in as they can give advice and can call upon their experience to help ensure that the correct decisions are reached. It is also surely unreasonable to expect any member of staff to cover everyone else with any sort of effectiveness. We believe that the service will suffer if this insistence on completely generic job capsules is rigorously enforced. There is, for instance, limited mention of knowledge of FOI/EIR on Job Capsules. How can staff be expected to apply exemptions/exceptions, deal with internal reviews and ICO complaints, as well as internal requests for advice - without an expert practitioner knowledge of these information access regimes? There are surely many situations where expert knowledge should be valued over the service that can be provided by a generic worker. The need to get things “Right First Time “ both as a way of saving money and at the same time providing a first class service to residents spring to mind (and getting it “Right First Time” is much more likely when expert knowledge is available).

3. There are 3 natural sub-divisions within the Information and Records Management Officers as currently proposed and they are complaints, information (comprising FOI and DPA) and record management. However, we understand that corporate records management is outside the scope of this Review and will continue with its current responsibilities. Based on the principles and philosophy of this Review (indeed based on its whole rationale) it makes

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little sense to have two separate corporate teams responsible for Record Management. We believe, therefore that Records Management posts should be removed from the scope of this Review and be transferred to the corporate team. The remaining staff will then form two natural sub-divisions (complaints and information) and staff should be assigned to one of these 2 sub-divisions only and should only be expected to provide cover for other staff in their sub-division. Normally, staff should be expected undertake a single role in their sub-division, thus maintaining the principle that it is the council's interest to build up experience and a sound knowledge base about a specific area of work.

4. Job capsules should be reviewed listing the tasks that each post will be expected to perform. As currently written these job capsules give no idea about the work that each post will be expected to undertake. How can staff be expected to perform when there is no detailed list of tasks for the post they occupy? How will they be appraised and how will performance targets be set if there are only vague and extremely generalised descriptions of the work they are expected to undertake? How can performance possibly be measured?

5. The job capsule for the posts for which we are ring fenced uses the word "complaint" just once and yet 6 of the 10 posts in this Division are currently complaints officers. In this connection there seems to be a fundamental ignorance of the work done by complaints staff. For instance complaints staff facilitate and assist with investigations and responses to complaints and play an important role in learning from complaints about which there is no mention. There is also no reference to Ombudsman issues which have a high profile and are managed solely by the Complaints Service for each Directorate. Although staff in CSF were asked to complete various spreadsheets about workload it is not surprising that there are these errors and omissions as no-one that we are aware of subsequently spoke to any of the 10 staff whose posts are now in the Management Officer team before putting forward these proposals. Staff in other departments besides CSF were certainly not consulted. The relationship between workload and the number of posts has simply not been explained. This becomes even more the case if work from C&E, FN and Parking is to be included in the workload of the new team. The new structure also makes provision for the ‘SLA with schools’. This is a specialist role currently managed by a CSF Manager whose existing post will henceforth be within this new service and yet there is no reference to it, or its complexities, in any of the job capsules. We would need clarification of how the SLA is going to be delivered as schools have signed up to and expect a specific, schools focussed service which is far wider than FOI, DPA and Complaints. That this is not referenced in any sufficient detail in the proposed structure is yet another example of the inadequacy of generic job capsules as any sort of guide to the work that will actually be carried out.

6. There is a close link in Housing complaints with Members Enquiries and MP enquiries. This link will now be broken as Members Enquiries and MP enquiries will be dealt with by teams supporting Chief Officers. Many of these enquiries are also complaints and the separation will undoubtedly lead to duplication and confusion. It is surely better to have all work like this which overlaps significantly within the umbrella of a single team.

7. The 3 posts of Information and Record Management Assistant – Level 2 Zone 2 are supposed to log all complaints and FOI/DPA’s. This is simply impractical. The workload will be far too

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heavy and it assumes that the work done by complaints officers is mostly straightforward data input. This is not the case and care has to be taken in deciding how to deal with complaints, including the ability to draw senior management’s attention to cases that have the potential to embarrass the council at the earliest possible opportunity. The fact that there have been no ombudsman findings of maladministration against the council for many years is not an accident. It is partly the result of work done by complaints officers who add real value to the complaints process. This added value will almost certainly diminish as a result of the generic approach and the loss/dilution of expertise built up over many years.

8. Lesley Piggott, in one of her presentations, remarked that reducing the level of duplication would make the team and Council function better. We would like to know the rationale and evidence for this comment in the context of the experience of all the FOI,EIR,DPA Officers. This experience suggests that a very small majority of requests (possibly 1% or less) are truly identical, as Lesley would know from the housing benefit requests that her service received every 3 months or so and required a recalculation of figures to provide a response. If the new service is pinning its hope of reducing work by getting rid of repeated requests then this is unrealistic. Also will the AD for the new service be responsible for getting buy in from senior managers for their teams’ information to be put into the public domain? Past experience would indicate that this is the only way in which this type of information will be released.

5.2 Further, detailed collective response regarding information and records management segmentCurrent situation with information requests:

1. According to business object reports produced from ‘i’case the number of logged FOI/EIR requests being completed within statutory deadline could be as low as 75%1

2. The number of FOIs the Council received was over 18002in 2013 – the second highest number in local government

a. The number has been steadily increasing year by year3 and will continue to increase4

b. Most ideas put forward for keeping down the number of requests are naive:i. requests vary widely in nature and only a very few are repeated

ii. requesters do not search for earlier releases – they send in an email3. Requests for FOI/EIR internal review consistently show:

a. some areas (notably within C&E who do not have a departmental FOI Officer):i. are not processing requests correctly

ii. some are not even loggedb. responses vary considerably in quality - many are poor (mainly C&E again):

i. questions posed are not answeredii. exemptions / exceptions are not cited or are applied incorrectly

iii. information is released in incorrect formats (e.g. native excel)4. CSF has backlog of 85 subject access requests (SARs) – some dating back to 2011 - most

cases will take many days (each) of Officer time to process1 Figures provided by ‘Business Intelligence – ICT’ for FOI response 90631562 Cases created analysis on ‘i’case shows 18513 Trend: 2010 shows 1354, 2011 shows 1670 and 2012 shows 16134 As of 20 March, 483 received - indicating over 2000 for 2014 if rate continues

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a. The ICO has already issued a finding against the Council on one of these cases5

b. Following a recent ‘whatdotheyknow.com’ FOI there is likely to be adverse publicity6

5. Since the FOI internal review panel has been abolished:a. Internal reviews are stacking up and not being processed quickly enoughb. whilst the quality of decisions being made seems reasonably good the

administration of internal reviews (previously under taken by the panel) has fallen on the corporate FOI team who are struggling to cope

c. late responses to internal reviews increases the likelihood of complaints to the ICOd. The ICO specifically criticized in a recent decision notice against the Council:

http://ico.org.uk/~/media/documents/decisionnotices/2014/fs_50509472.pdf7

6. ‘i’ case is not ‘fit for purpose’ - ask anybody who uses it for processing information requestsRisks

1. The Council will be publicly named and shamed by being put on the ICOs monitoring list: http://ico.org.uk/what_we_cover/monitoring_compliance

2. Release of information under FOI that should be exempted can result in reputational damage and even a fine from the ICO: http://ico.org.uk/news/latest_news/2013/london-council-receives-penalty-after-2000-residents-personal-details-published-online-20130823

3. The Council will be reported to the ICO again (or even sued) for non compliance with the Data Protection Act for not processing SARs within the statutory deadline

The reasons outlined above show the importance of getting it right first time – and that we are not really doing this enough at the moment.

Getting it wrong – even more of the time?

Unfortunately the proposals put forward under the review seem to guarantee that in the future we will be doomed to get it wrong even more of the time. In my view they are quite simply breathtakingly reckless. Please mark my words – the proposed new Record Management and Information team represents an impossibly huge gamble - in area where the Council cannot afford to take risks. To an impartial outside observer it may seem that these proposals signal that the Council no longer attaches any importance to FOI/DPA compliance.

1. Taken together the 20 posts in scope for the team are currently only processing 66% of the Councils FOI/EIR requests and only 65% of the SARs8

a. I believe that the situation is similar for complaintsb. This would represent an impossibly huge increase in workload for Officersc. Not to mention the extra work that would come from deletion for the Corporate

Information Access Managers post (who will do Internal Review for SAR and cover the other aspects of this post - see attached9). From the response to my enquiries it does not really seem that a lot of thought has been put to how the Council can replace the expertise lost

5 ICO: RFA0518305, LBC: 82322786 LBC: 92671127 FS50509472 – see paragraph 60 (page 12)8 Cases created analysis Oct 2012 – Aug 20139 RE_ Business Support review_ response to consultation 2

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2. Detailed knowledge of the FOIA is the first requirement in my current JD (attached10). It does not feature in the any of the JDs for the new team.

a. How can Officers apply exemptions / exceptions, help administer internal reviews, respond to ICO complaints, and deal with internal inquires if they do not have a detailed working knowledge of the information access regimes?

b. Believing that a skills audit and resultant training will bring officers up to speed is simply a forlorn hope. Please see the ICO guidance for some bed time reading: http://ico.org.uk/for_organisations/guidance_index/freedom_of_information_and_environmental_information and: http://ico.org.uk/for_organisations/freedom_of_information/internal_guidance

3. FOI Officers in large public bodies are FOI practioners:a. Through applying exemptions, seeing the results of internal reviews, ICO and

tribunal decisions and referring to the ICO guidance they obtain a specialist working knowledge that takes years to build up

b. This knowledge base can be built or used to tweak and adjust the Council’s FOI practise as new decisions come to light

c. This knowledge increases the likelihood of getting it right first time it enables: i. Correct exemption decisions to be made quickly and efficiently11

ii. Internal enquiries need to be answered promptly and correctlyiii. Members of the public to be advised in accordance with s16 of FOIA

d. The Council will find it impossible to recruit and retain FOI practioners to a “Records and Information Officer” post

e. The loss of FOI expertise will result in more internal reviews, ICO complaints and an increasing drain on Legal (more expense) to deal with these and internal FOI queries12 that could more simply be dealt with by FOI Officers.

f. Incidentally it is often the case that even senior layers in legal will seek advice from FOI Officers on FOI matters.

4. Dealing with FOI/EIR, complaints (and statutory complaints) or Records Management issues require vastly different knowledge bases, different skill sets and different attitudes

a. How will the team be trained up to be specialists in all these areas (standards will need to be maintained) – can the Council afford this?

b. The Council will end up with a team who are ‘jacks of all trades and masters of none’c. For five years I worked as an FOI Officer will also providing cover for the Complaints

Officer – it almost impossible to make progress with FOIs while trying to deal with complainants on the phone

Counter Proposal

1. Rather than have “people with particular areas of expertise who will lead on these areas” (see attached13) it would be better to form two sub teams:

a. One dealing with Information Access the other dealing with Complaintsb. These teams would have the advantages:

i. Cover – while Officers are on leave

10 JP~HASC BMS~IAOfficer~May1211 Knowing the subject means you do not have to ‘look it up’ all the time12 I have 531 emails (relating to enquiries - not my cases) since 20.09.13 – let alone telephone enquiries13 RE_ Business Support review_ response to consultation 1

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ii. Collaboration – made easier on difficult casesiii. Continuity – new FOI practitioners or Complaints Officers could be recruited

when Officers leave and can be inducted by relevant teamiv. Competence – FOI/DPA and Complaints expertise would be retained at a

high level (a pay rise would help with this as well)c. Retain departmental links (at least one Officer for each department)

i. knowledge of the departments and their work areas is importantii. you have to understand the information to apply exemptions

iii. you have to know where to source it it is to collate itd. Records Management function could be moved into Corporate Records

Management team to concentrate and retain expertise there2. Effectively resource teams

a. Increase officer number to cope with adequately workload (see attached)14

b. Initially provide extra numbers to deal with CSF SAR backlogc. Provide training to keep abreast of latest developments in fields

Abolish ‘i’case, provide suitable ICT system and redaction software15

5.3 Individual response regarding the information and records management segment, with specific reference to SLA workSee attached PDF labelled appendix 5.3.

5.4 Responses regarding the information and records management assistant rolesJoint response from two current information assistants:

1. The job capsules that we have been matched to are significantly similar to the jobs that we are doing now, Therefore we do not feel that having to re interview for a post that is almost identical to what we do now would be beneficial. Whilst working in both the Freedom of information, data protection, Adults and Children’s complaints unit we have acquired a lot of the knowledge already needed for these post.

2. 3 posts for Information and Record Management Assistant – Level 2 Zone 2 has been identified and it is expected that we support the 10 Information officers, with the level of work we currently do which is already at a very high capacity it is simply impractical to think that 3 people would be sufficient enough to support 10 people who already themselves have a very high work load.

3. Within the current Freedom of information team there has been a significant increase in FOI’s in the last 12 months. One worker currently manages the full initial FOI process having looked at the new structure there does not seem to be a provision made for any CSF FOI officer within the 10 IRMO. A point of contact for CSF staff and someone that already understands and has built a rapport with these staff is needed FOI Request are not a simple administrative process and there requires sufficient assessment in determining how to deal with even the initial stages of any of these requests including identification of wider issues. The FOI process has its own statutory requirements and complexities.

14 Estimates produced by Corporate information Access Manager15 Equipping lawyers to do redaction is a waste of their time and the Council’s money

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4. Currently both CSF FOI and SAR’s are at an unmanageable level and are under resourced in both areas however no provision has been made to support these areas and it is expected that staff that do not understand these structures will have to pick up this work load, who themselves already have a high work load.

5. Currently there is a back log of overdue Subject Access Requests with currently no designated officer processing these. Additional qualified staff will be required to clear this. Bringing this forward into a team where officers are not experienced in dealing with these will not clear this back log and I only feel that this will transfer the problem.

Comment from a current information assistant:

At present I manage at least 30 live FOIs for my Department at any one time. I can see no advantage to be had from someone inputting cases onto iCasework and then passing them on to someone else to co-ordinate. It is adding another level of work rather than streamlining a process. No ownership is going to be taking by the person inputting the data.

Comment from a worker ring fenced to the team leader role:

It is proposed that these three posts will log all CSF complaints, ASC complaints, FOI / EIR requests and subject access requests in line with the data protection act. This is not a simple logging exercise as sufficient assessment is required in determining how to deal with even the initial stages of any of these requests / complaints including identification of wider issues. Each process has its own statutory requirements and complexities.

List of tasks currently undertaken by information assistants, demonstrating that they cover the tasks to be undertaken by the new information assistant role already, and so should be ringfence (oversubscription) rather than alternative:

Worker 1 receiving and logging Data Access requests drafting the response for Data Access requests applications in line with the statutory

requirement. the archiving and maintenance of CSF’s business and financial records . first point of contact for the Information access team. coordinating the retrieval of records prepare and process records into accessible/readable Volumes of data in

preparation for the redaction process. archiving the business/financial files within CSF liaising with the offsite storage company in terms of coordinating collections,

retrievals and also instructing and carrying out destruction of records once retentions dates have expired

carry out validation and verification of requestors ID, coordinate the search and retrieval of requested information and also the

coordination and facilitation of the file viewings.

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processed small Subject Access Requests in cases where the client is has requested specific information

Worker 2 Logging FOI requests Responding to requests and leasing with staff for FOI response. Signoff and lease with AD Assisting parents with school complaints. Assisting schools with SLA enquiries Assisting schools with Complaints. Previously logged and monitored stage 1 CSF and ASC Complaints. Previously logged stage 2 complaints

5.5 Collective response from CSF and ASC complaints officersIntroduction

1. In response to the Business Support and Administration Review 2014 our approach is to address the services being managed under the Record & Information Management Service within the existing Business Management Service.

2. We have also worked in partnership with CSF Complaints who are in agreement with the proposals we have put forward.

3. We hereby wish to submit a Counter Proposal for the information the Record Management Service to enable the services to operate independently Complaints & Members Enquiry, DPA/FOI and Records Management with their current staff. We are proposing that Members Enquiry be incorporated in the Complaints Unit.

4. The main concern is that the services ASC Statutory Complaints, FOI/DPA & Records Management provided within this area of Business Service are statutory functions which are deemed as front-line services, the gateway to the organisation.

5. CSF Statutory Complaints operate the same function similarly to ASC and should be independent of operational line management and of direct service providers (e.g. children’s social work). Issues around possible ‘conflict of interest’ need to be considered when organising local structures. (Please refer to Getting the best from Complaints”)

6. The ICO inspected Camden in the last 12 months and HASC were successful and instrumental in the outcome due to the robust way in which HASC manages FOI/DPA and Records Management.

7. All the above listed services are govern by law and should maintain a high profile in the organisation with how they are managed and reflected in an organisational structure see NHS Complaints (England) Regulations 2009, Children Act 1989, Complaints Procedure (Social Services Complaints Regulations 2006), Data Protection Act and The Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011.

8. The Members Services have recently undergone a review that overhauled how the services were managed. We believe it is imperative that these remain as they are and other Member

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Enquiry Services are bought under this separate within the proposed structure and is managed by central team.

STATUTORY (CSF & ADULTS) COMPLAINTS

Process

1. Other complaint services outside of HASC and CSF appear to have maintained their complaints team status quo. We would like to know why the same decision has not been afforded to the remaining complaints unit/service in HASC and CSF.

2. What has happened to the Council-wide Complaints Review?

3. The IT system (ICasework) does not support a team managing or sharing cases.

4. Why do we need to be re- interviewed for one of the 10 posts when it is highly unlikely the 10 officer’s ring fenced will only have understanding rather than experience of each other’s roles and would require additional training to undertake the “significant” difference in the post as outlined in the new Information and Records Manager post?

5. Complaints Legislation, Roles & Responsibilities should be reflected in the job capsules as a statutory service

Function

1. A Designated Complaints Manager (DCO) should exist for CSF Complaints Representation Procedure as outlined in the CSF Complaint Regulations /Children’s Act 1989.

2. The Statutory Procedure for Complaints should be seen on par with Safeguarding as we have to assess risk on the complaints received and determine the appropriate course of action working alongside service managers from CSF and ASC.

3. Camden CSF Complaints procedure requires all Stg2 complaints to be investigated by external independent personnel (investigator and independent person). This ensures the requirements of the function can be met in a timely manner. We welcome some information/clarity with regards to what this will entail for the New Team leader post identified as the investigating officer?

4. The Statutory Complaint practitioners manage and hold a caseload from beginning to end of complaint process, overseeing and facilitating the process on behalf of the Directorate, responsible for the Directorate responses at all levels of the procedure on behalf of the Assistant Director/Director, co-ordinating professional meetings held with Snr Service Heads and Service Heads, mediation/resolution meetings. They also chair service manager, practitioner briefings/pre-meetings, deliberation meetings, facilitate the Stage 3 Review Panel process. (Please see attachment extract form “Getting the best from Complaints” outlining the role and responsibility of a CSF complaints officer/manager overseeing the Statutory Complaint process).

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5. In conjunction with point 9 ASC Complaints have accepted CSF position with regards a managerial role for the service as this should enhance the line management function for ASC. Albeit the statutory service has been separated for three years so none of the managers eligible for the post have the experience of both statutory functions to support the staff the re-organisation is proposing.

6. The arrangements for commissioning and procurement is impacting on the CSF statutory functions, as the review has led to advocacy, IP and training contracts not proceeding as normal because it conflicts with the organisational way of working. The training arrangements have impacted on ASC Complaints.

7. The Statutory Complaints Service is responsible for the Policies and Procedure, Publicity and Training and the strategic overview of the service being provided and this rests primarily with the Complaints Officers.

FOI/DPA & RECORDS MANAGEMENT

1. FOI/DPA/Records Management - Why has this service not been centralised in its entirety?

2. The status quo for FOI/DPA/Records Management should remain if other similar services have remained unchanged.

3. How have you assessed the potential risks for the statutory functions within the proposed new structure? High assurances was given following the ICO Inspection on the basis of HASC management of these functions the changes is likely to threaten this.

MEMBERS ENQUIRIES

1. Members Enquiries have undergone a massive overhaul to improve the responses/enquiries are not missed there is concern that any changes at this point will de-rail this.

CONCLUSION

1. Members Enquiries/FOI/DPA & Complaints responsibilities that has been diverted away and not taken up in scope should be centralised inclusive of the budget that goes along with these posts.

2. The solid experience and knowledge is important to learning and service improvement of Complaints & Members Enquiry, DPA/FOI and Records Management Services and therefore the status quo should remain.

3. We are not confident that the functions and responsibilities of the posts in Complaints, DPA/FOI and Records Management have been fully accounted for and therefore staff do not believe they have the capacity to carry out the duties required of the staff.

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