In Focus Consumer Credit
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to deliver essential services such as food and medicine to the most
vulnerable, utilising vehicles, fuel and IT provided and funded by our members. Some councils asked agents to continue with light-touch contact to support people struggling with outstanding debt. Telephone calls and e-mails were used
to offer extensions to repayment schemes or arrange payment holidays in line with responsible collection practices.
Post-lockdown With the government decision to allow enforcement visits to recommence from 24 August, it is an appropriate time to explain the CIVEA Post-lockdown Support Plan, which all our members have committed to implement. To simply restart enforcement visits once
the government eases restrictions would not be acceptable. Therefore, prior to recommencing any
visits to customers, members will implement a pre-visit letter and vulnerability identification phase. Anyone who has missed a payment or been out of contact will receive a standard reconnection letter. To ensure consistency and prevent confusion, this will be a universal templated letter plus follow up communica- tion. Firms will use a standard letter unless their council clients require an alteration. The letter seeks to engage with customers
to understand how they have been affected by the COVID-19 crisis and respond as appropriate. Each case will need to be offered support as appropriate, including signposting to the Money Advice and Pension Service and debt advice charities.
Enforcement visit suspension When enforcement visits resume, individuals will be given 30 days’ notice of a visit by an
enforcement agent, unless the local authority has specific requirements. This is to provide sufficient opportunity
for engagement with customers prior to the attendance of an enforcement agent, which could prevent additional fees being added to the outstanding debt
Training All enforcement agents will be required to undertake additional, mandatory CIVEA-approved training prior to any recommencement of visits. The newly-designed training programme
will include: the effective use of protective equipment and social distancing requirements, how to protect themselves and those that they encounter in the community, This will be supplemented by refresher training on supporting vulnerable people and recognising mental health issues.
Pre-visit assessment Where a telephone number has been sourced and if appropriate to do so, members will now make outbound calls in advance of enforcement visits to identify vulnerabilities or changes in circumstances.
Post-lockdown visits Initially the debts that are enforced will be predominantly older traffic offences and magistrates’ court fines that will have been suspended for an additional five months. The courts will need time to clear the
backlog of casework. Local authorities have already reinstated parking enforcement and the courts are coming back online, so it is appropriate for enforcement visits to be resumed as part of the civil justice process. Overdue council tax for this year will not
feature for many months, and councils will need to balance their legal obligation to recover revenue for the taxpayer, with responding to individuals and families affected financially, socially and healthwise by the COVID-19 pandemic. l Agents will receive refresher training on how to identify any vulnerabilities or changes in circumstances. l Visits will be contactless in line with our safe working practices guidance. l Enforcement agents will not enter premises to take control of goods. lWhere appropriate, vulnerable people or
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Anyone who has missed a payment or been out of contact will receive a standard reconnection letter. To ensure consistency and prevent confusion, this will be a universal templated letter plus follow up communication
those who have been severely impacted financially by the pandemic – such as by loss of job or being on Statutory Sick Pay – will be referred to debt advice agencies for additional support. l In these circumstances, the case will be placed on hold to be monitored, with contact by welfare staff, as appropriate, prior to proceeding. The fees incurred will remain in place. l Vulnerable people will be referred to their creditor for additional support, where appropriate.
Data collection and recording All members will collect and record details of customer vulnerabilities, in line with data protection requirements.
Provision of protective equipment The majority of enforcement payments are made by telephone before an enforcement agent is required to visit or after a letter has been left. When visits are necessary, we will work with members to source sufficient workwear and hygiene supplies to protect and reassure staff and members of the public. Enforcement agents will practice social
distancing, comply with enhanced hygiene techniques (including disinfecting their kit) and be issued with hand sanitizer. This is in full compliance with the government and Public Health England advice. We are confident that the measures
included in the Post -lockdown Support Plan are a sensible and proactive response to an exceptional situation. We willk remain under scrutiny, with other sectors watching with interest as we all adjust to the post-lockdown environment. CCR
July 2020
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