Today we have published responses to our recent consultation on strategy, budget and operating plan.
We would like to say a special thanks to organisations and individuals who took the time to respond, despite the deadline overlapping with the coronavirus situation. We are required by law to publish outcomes by the end of March, so whilst we understand the public and lawyers will be focussed on the current situation, we need to ensure we deliver our statutory duties.
We were glad of strong support for a focus on prevention of complaints, in particular from the profession. The best way to make the system more efficient is to reduce the common causes of complaints, which reduces concerns from the public, which then reduces our work and its costs. We look forward to working with our stakeholders to achieve this, and will ensure that this is based on a sound understanding of the trends in complaints, the needs of the profession and the expectations of consumers.
We were also pleased to receive positive feedback for our continued work to support early and consensual resolution, where that is appropriate, and to ensure all parties understand how this can be achieved and why it can be beneficial.
We will also consider some changes in light of the feedback, including:
- Given the strong support for greater focus and prominence for our work on prevention, we will seek to reflect this in the drafting of the strategy. We will also consider how to include references in our operating plan to joint work with stakeholders in this area.
- We will flag more overtly that work on digital, process improvement and prevention is all aimed specifically at the complaints system. We’d felt this was implicit, but are happy to make it clearer.
- We will consider what more we could do to make consumers aware of their right to complain and what to expect from the complaints process, from first tier through to our own procedures.
- We will reflect on whether we could do more to promote early and consensual resolution.
- We will consider how to clarify where we feel efficiencies could be made in our work. We had included specific commitments to improvement in terms of ‘best value’ but will respond to feedback to be more explicit about opportunities to find efficiencies and drive down costs.
- We will revisit our KPIs to see whether we can be clearer about the outcomes we want to achieve.
On some other issues views were mixed. We set out a priority around achieving reform to create a better regulatory and complaints system for consumers and lawyers. Some organisations commented very positively on this. Others did not see trying to improve the wider regulatory system which we sit within as one of our functions. We will reflect on this, especially in light of the Competition and Markets Authority report published last week.
Although we asked specific questions on budget and possible cost savings we received very few comments on this, other than concern at increasing costs. We had set out the challenges and drivers of this. There was discussion of a freeze or reduction for public sector lawyers from one stakeholder, and we commit to consulting on that issue again specifically next year to get wider views.
The issue of Coronavirus was raised, and whether this could be reflected in either the budget or the levy collection process. It is not the SLCC who collects the levy, so we are liaising with the relevant professional organisations to see what might be possible. We are also currently considering the likely impact of the situation on our operational plan for this year and next, and may need to make further amendments on that basis as the situation develops. A final budget is not laid in the Scottish Parliament until April.
Other key themes from the responses are also being considered. The SLCC Consumer Panel will also consider responses made to its strategy and workplan in due course.
The final decision of the SLCC’s Board on budget will then be laid before the Scottish Parliament.