Supplementary written evidence submitted
by PCS
In this paper, we wish to submit some further evidence
and to comment on some of the claims made by Identity & Passport
Service (IPS) management at the Welsh Affairs Select Committee
evidence session held on 10 November 2010.
ON CONSULTATION
1. In an attempt to dismiss our complaints about
inadequate consultation, Sarah Rapson states in her answer to
Q64 that IPS took part in informal meetings with PCS; we also
understand that Damian Green has recently provided minutes of
a meeting with the union that took place on 28 September. IPS
management seem to be suggesting that PCS was prepared to consider
accepting office closures, which is not the case. We did indeed
take part in informal meetings, during which the closure of the
Newport office was discussed. What IPS management has not made
clear, however, is that throughout those meetings PCS maintained
a stance of implacable opposition to office closures and redundancies
in any office within IPS - and, indeed, to cuts in jobs and services
in any government department, in accordance with PCS national
policy. Sarah Rapson also told the Committee that PCS had seen
the full multi-criteria analysis prior to formal consultation
but although some union reps were shown the analysis, this was
not the version that was subsequently used and management were
still showing us the old version several weeks after the formal
consultation started.
2. We wish to reiterate our dissatisfaction with
IPS management's drip-drip approach to the provision of information
during the formal consultation period.
DOCUMENTS REQUESTED
BY PCS AND
BY THE
COMMITTEE
3. PCS told the Committee that a document on
the Application Processing Network Analysis Direction of Travel
had been shown to PCS in August and then withdrawn. IPS management
has now belatedly provided a copy of this document to the committee
and to PCS, after having been asked to do so by the Committee
Chair. The document raises more questions than it answers, however.
The Minister has stated in his further submission that the document
is, in effect, redundant and did not provide the basis for any
decisions subsequently made by himself or IPS. We find this puzzling,
since the document was produced on 25 August and the ministerial
submission on the Newport office was submitted shortly afterwards,
on 13 September. Our understanding was always that the submission
had been shaped by the Direction of Travel document, yet
if the latter was effectively torn up between 25 August and 13
September, as the Minister now claims, then it remains unclear
what analysis formed the basis of the submission.
4. The document effectively argues that staff
in IPS will increasingly become surplus to requirements due to
a rolling programme of "operational efficiencies" running
up to 2016, of which the closure of the Newport office is a part
(see, in particular, the graph on page five of the document).
Management have since informed us, however, that many of the planned
"operational improvements" mentioned in the document
have now been abandoned. For example: the projected future number
of on-line applications has now been brought down to 45% and,
most importantly, the project of "automatic" simple
renewals and extensions has been abandoned. All that remains are
some changes to Telephone Enquiry Bureau work and printing work,
along with what is called in the document "operational excellence".
This latter involves new working practices modelled on "lean
processing" (on which we comment further below). It should
be noted, however, that this is only at the trial stage and could
not be relied upon to deliver efficiencies.
5. There are currently only 50 surplus staff
within IPS, according to management, and it is only through the
implementation of "operational improvements" that the
agency will supposedly find itself over-capacity by a margin of
300 staff. If, as we are now told, some of the most significant
"operational improvements" will not happen after all,
it is difficult to believe that 300 people will be surplus by
the end of next year and the rationale for the Newport office
closure disappears.
6. In summary, the Direction of Travel
document and the minister's comments on it demonstrate that IPS
management has little basis for its prediction of 300 surplus
staff by 2011, other than citing "operational improvements"
that are only at the trial stage and will, we believe, deliver
minimal efficiencies; and that if this document was abandoned,
as we are now told, then IPS management's decision-making has
been even more haphazard than it already appeared, with no clear
basis for the ministerial submission that led to the office closure
decision. One might conclude that IPS made their decision and
then worked backwards from that position, producing arguments
to provide ex post facto justification.
TRANSPARENCY
Cancellations of Interviews
7. In response to Q93, the Minister stated that
information about how many customers had failed to turn up for
interview had not been withheld. This is simply false: after the
Committee's evidence session, we gave a document to members of
the Committee which demonstrates beyond doubt that that information
has been withheld. The Minister has stated that some of this information
is published as a matter of course - in which case, it seems incomprehensible
that management should redact such information in communications
with the union.
8. In his letter to the committee of 15 November
2010 the Minister states that 352 applications to the Newport
office resulted in cancellations of interviews, yet our point
was about the effectiveness of the Interview Office Network
- rather than the Newport office - in deterring fraud and figures
for interview cancellations within the Network have still not
been presented either to PCS or to the Committee.
Intimidation of staff who comment publicly
9. Newport office staff have received letters
from management containing an implied threat of disciplinary action,
in relation to interviews that some of them had given to the media. Yet
these interviews referred only to the personal circumstances of
the staff in question and their concerns for the future if the
office should be closed. We consider this to be heavy-handed
and intimidating.
Welsh Language provision
10. Throughout their evidence, IPS management
maintained that there had been no intention or consideration of
removing the Welsh Language Application facility in IPS. We have
now, however, presented Committee members with the draft Equality
Impact Assessment, which clearly shows that IPS management had
been giving consideration to withdrawing the facility. IPS may
now backtrack on this but the draft document demonstrates that
they had considered breaching the terms of the Welsh Language
Act - or, at least, trying to see how they can "get around"
it. PCS reps in Newport have raised with management our concern
that the provision of a face-to-face Welsh language service is
already barely adequate and non-existent on Saturdays, only to
be told that this does not mean there is any need to improve the
service in future.
SERVICE TO
WALES AND
NEWPORT
11. In response to several questions, the Minister
and Sarah Rapson both stressed that there would be no change to
the service to South Wales and the South-West of England. We remain
highly sceptical about this. As Jessica Morden implied in asking
Q120, it is very doubtful whether counter staff, security, fraud
detection, processing, printing and the Welsh Language Service
could all still be provided if there were a mere 30-35 jobs in
Newport - especially when it is intended that the office should
also conduct interviews of first time applicants. We believe that
IPS management is cutting costs in preference to protecting and
sustaining an award-winning service.
OTHER COMMENTS
12. We have continuing concerns about the effects
of "efficiency savings" on service provision, especially
in relation to public safety. For example, "Operation Excellence"
(referred to in paragraph 5 above), which is being trialled in
the Durham office, against the objections of PCS, involves stripping
back-office processing work of any processes deemed to be unnecessary,
such as the examination of the counter-signatory section of the
application form. The potential consequences of this are demonstrated
by the concerns already raised by staff in the Interview Office
Network (ION) regarding the introduction by management of a "Risky
Decisions" log. This is to be completed following a passport
interview, to record instances where a decision to fail an applicant
cannot be justified under current policy but the interviewer or
office manager is uneasy about the "pass" decision because
of the limited quantity or quality of data available on the applicant,
on which to base their decision. IPS acknowledge that such insufficient
or poor-quality data might be a consequence of previous efficiency
savings, such as the withdrawal of counter-signatory examination,
or of a failure to act on warnings flagged up by the Personal
Identity Process. This demonstrates that cut-backs in the application
processing offices can adversely affect the quality of information
available to interview office staff, to the extent that they cannot
perform their duties to their own satisfaction. With identity
theft in the UK estimated to cost £2.7 billion, the Government
should be investing in services that protect identity yet, by
introducing this log, IPS appear to be saying that making risky
decisions is part of a passport interviewer's job. This represents
the abandonment of the concerns that led to the ION's establishment
and suggests that IPS is gambling with the safety of the public.
13. In conclusion, PCS believes that the comments
provided above further substantiate the concerns that we have
already put before the Committee about the proposal to close the
Newport office and the wider "efficiency" agenda within
IPS.
November 2010
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