CCR2 Litigation A forum for discussion
A group of enforcement agents is tackling the key issues facing the sector, with data and regulation both on the agenda
David Smith Head of public affairs and research, the British Parking Association
dave.s@britishparking.co.uk
One of the many areas that we have a keen focus on is enforcement. We have formed an electoral college for enforcement agents and this group holds special interest meetings two or three times a year. Meetings have taken place since 2008 and
the aim is to help the association respond to the government’s enforcement initiatives and to help members to cope with their implementation. The group helps to raise the profile of the work of enforcement agencies and to provide a significant networking opportunity.
A steady state Enforcement is, in many ways, in a steady and unspectacular status. Following the implementation of the Taking Control of Goods Regulations in 2014, there has been little or no negative reaction. The next critical stage is the publication,
by the Ministry of Justice, of the year one review – which will be 12 to 18 months overdue – and the year three review, which will be more substantive, in 2017.
Recent issues discussed at the enforcement
agents special interest group included: l The use of body-worn video and the implications in terms of data protection and the Information Commissioner’s Office’s (ICO) attitude. Their introduction across the sector has been very positive, but there will be challenges in ensuring the data is used and retained in accordance with the ICO’s requirements.
Following the implementation of the Taking Control of Goods Regulations in 2014, there has been little or no negative reaction
l The DVLA remains a challenge in terms of the accuracy of data. The frustrations faced by those involved in the enforcement arena are shared by local councils and enforcement agencies alike. l The issue of vulnerability remains at the top of the agenda. The recognition, in the new regulations, that protection should be provided is readily accepted. However, attempts to exploit this can lead to some frustration. Agencies continue to invest heavily in specialist training for collections staff and, where possible, work with local third-sector groups. l The role of in-house enforcement operations continues to vex the industry. The increase of in-house teams has raised the question of whether the public and private sectors are delivering the same breadth of service, or are the public sector teams only delivering the front-end compliance process in many cases? This is clearly against the spirit of the
legislation and the intentions of the Ministry of Justice. CCR2
January 2017
www.CCRMagazine.co.uk
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