Our Strategy and Operating Plan
Introduction
Our vision is that every client receives a professional service, and every lawyer adheres to professional standards.
Our mission is to resolve complaints, prevent the common causes of complaints, and enable quality improvement.
We have five strategic aims to achieve our ambition to be an efficient and effective complaints, regulatory, and oversight body, delivering a quality service.
Our aims are to:
- Deliver our functions as a high-quality service which is accessible and inclusive, has good customer service at its heart, is prompt, and proportionate, and which delivers fair resolutions.
- Innovate across our complaints, regulatory and oversight functions by working as a performance-focused, agile, change-confident and resilient team, delivering continuous quality improvement and best value in our work.
- Prevent the common causes of complaints through analysis, shared learning and improvement work.
- Influence the evolution of the regulatory system across the legal services market through complaints learning and our regulatory and oversight functions.
- Transition the organisation through a period of strategic change and expansion of functions and role, supporting our staff, and focusing on a service design approach.
Our values are:
- Fairness: Our processes and outcomes can be trusted by all as fair, independent and impartial.
- Respect: We understand and respect the diverse groups we work with, work inclusively, and offer a good customer experience to all.
- Impact: Every element of our work will deliver a meaningful result.
- Learning: We continuously learn and develop, and share that learning, so we all improve our processes and the quality of our work.
- Clarity: Our decisions, explanations, communication, and services will be clear and accessible.
Projects are cross referenced to our strategic aims. [D] = Deliver, [Iv] – Innovate, [P] = Prevent, [If] = Influence
All timings are subject to change due to reform. As noted in our consultation on budget and operating plan, we face a period of unprecedented uncertainty and will adjust resource to meet the those pressing challenges and opportunities.
A. Statutory complaints service
- We will process an estimated 1,345 incoming complaints and maintain our performance and customer service on core processes including if we are starting to implement reform (designing and dual running a new system). [D, Iv, P]
- We will continue our innovation and change programme, including our agile process improvement work, looking for new opportunities to work more efficiently, reduce the time it takes to handle complaints, and improve the quality of our work. Following on from a significant court decision work is already underway to amend the process in a way which lays the foundations for the implementation of the new Act. [D, Iv, P]
- We will review the current system for opportunities for trialling changes under the Bill, before it comes into force, if we have been given flexibility in the complaints process and such trials are not incompatible with current drafting. [D, Iv, P, If, T]
- We will process an estimated 1) 11 incoming appeals, 2) 24 FOI requests, and 3) 21 GDPR requests. [D]
- If required, we will implement the complaints system for Licensed Providers (ABS) under the Legal Services (Scotland) Act 2010. [D, Iv, P, If]
- We will continue to review our approach to s17 non-compliance by solicitors to achieve a substantial and sustained change in the level of compliance [D, Iv, P, If, T]. We will:
- Consider our approach to using the S17 court process v progressing cases making decisions just based on evidence we have
- Monitor S17 engagement AND general engagement with SLCC
- Consider publishing cases
- Consider the impact of any changes in the Bill
- Re-engage with stakeholders on the issue
- Consider action on any gaps in our current approach – such as repeat offenders who may pose public interest issues.
- Our Service Experience Team (SET) will continue to identify proportionate new opportunities to improve customer service (either implementing reform, or for our existing process) and implement these within the year. Currently plans include [D, Iv, If]:
- Ongoing work on the SLCC’s feedback systems including our external feedback process, Trustpilot and how feedback is shared within the organisation to improve our services.
- Review of feedback work sitting with SET.
- We will ensure our approach to accessibility and inclusion in embedded in all our work. We will consider how we could make our service more visible and accessible to those who might need it, including consumers in vulnerable circumstances, those suffering trauma, and those with protected characteristics under the Equality Act, along with specific consideration of the UNCRC. [D, Iv, If]
- Last year we reviewed our own equality data and multiple sources of information on the population of Scotland and Scotland’s legal profession. We also reviewed a dip sample of reasonable adjustments we made, and where we dealt with translation issues. We’ll build on that learning with projects to proportionately respond to issues highlighted by last year’s work. [D, Iv]
- We will develop an options appraisal for publishing more information related to the working of the SLCC Board and select an option for piloting or permanent deployment with the following year’s operating plan. [D, Iv, If]
B. Statutory oversight, trend reporting and our outreach service
- We will continue work to deliver our statutory duties of oversight in relation to the Relevant Professional Organisations. We will follow up on recommendations made to the Law Society of Scotland and Faculty of Advocates on complaint handling and redress arrangements. We will engage with the Association of Construction Attorneys on its regulatory scheme and complaints process. [D, Iv, If]
- We will process an estimated 15 incoming handling complaints and maintain our performance and customer service on core process including if we are starting to design and implement the changes in the new Act. [D, If]
- We will deliver a programme of outreach to the profession through newsletters, videos, online content, training and events. [D, Iv, P, If]
- We will review our tracking of regulatory risk factors to help identify potential consumer detriment and ensure our approach is embedded across the organisation. [Iv, P, If]
- If required, we will review the approved regulator complaints system under the Legal Services (Scotland) Act 2010 to ensure it remains fit for purpose after the eventual launch of the licensed provider scheme and with associated communications and the training of staff (all needing updated, due to delays in the regulatory scheme being launched). [D, Iv, P, If]
C. Statutory consumer panel and aligned work
- The Consumer Panel will consider how to develop its workplan and ways of working in light of new powers and duties coming from reform. [D, Iv, P, If]
- The Consumer Panel will ensure a clear consumer voice influences the SLCC’s policy development and will provide a vital consultation and challenge role as the organisation moves to transition planning and implementation. [D, Iv, P, If]
- We will ensure our transition plans, and any other significant strategic decisions, are delivered in line with the requirements of the Consumer Duty and other statutory duties influencing policy development (including around equality and diversity). [D, Iv, If]
D. Business functions to support the delivery of our statutory functions
- Following an independent governance review in 2024-2025 we will implement any recommendations from the report which have been accepted by the Board and in a proportionate manner. [D, Iv]
- We will keep under review AI options which may in the future streamline our HR processes, including recruitment and on-boarding. [D, Iv]
- We will carry out a full review of employee benefits. [D, Iv]
- We will develop our use of technology to deliver our role. This will include scoping a review of our IT support contract and considering a tender process (this may be delayed to accommodate reform work). We will also undertake a five-year review of personal hardware needs (laptops etc) and plan a replacement cycle. [D, Iv]
- We will explore new technology options to improve efficiency, including the use of Microsoft co-pilot for areas of work such as minute production. [D, Iv].
- Having tendered our Internal Audit work last year, we will work to establish a new rolling cycle of internal audit. [D, Iv].
- We will continue to implement our data action plan, review progress and begin to scope the next phase of this work. [D, Iv, P, If]
- We will start work to look at how our carbon footprint can be accurately calculated, and we will consider how our e-footprint for carbon can be reduced. We will encourage the use of volunteer days to support sustainability initiatives. [D, Iv]
- We will prepare our statutory Biodiversity Report to showcase the work we have done over the last 3 years. We will also continue to seek new ways to reduce our carbon footprint. [D, Iv]
- As required by our lease we will develop a schedule of work to refresh interior decoration, as well as reviewing desk usage and numbers to ensure an effective working environment for staff. [D, I]
- We will submit our application for revalidation by the Ombudsman Association (due in September 2025) so that we can remain an active part of a community which shares best practice and provides the public an independent assurance on our process. [D, Iv]
- We will work with Scottish Government on the public appointments process to replace members demitting office in March 2026. [D]
- We will undertake initial work to prepare for the potential retendering our Legal Panel. The current contracts are until October 2026 (extendable to October 2027). This work may partly depend on the timetable for reform implementation. [D, Iv]
- We will undertake initial work to review our case management systems and options for upgrading and development or replacement. [D, Iv]
E. Engaging in reform and improving the process
- We will take legal advice on the operation of the new Act and liaise with Scottish Government on commencement orders and funding. [D, Iv, P, If, T]
- We will attend relevant regulatory and complaints events to build knowledge and networks to assist in the implementation of new ways of working following legislative change, and to inform ongoing continuous improvement generally. [D, Iv, P, If, T]
F. Reform implementation
- We will start work on an overarching statement on organisational purpose and regulatory approach based on the new Act (including consultation with stakeholders) as this will inform our approach to implementation (and therefore be required before we can submit a request for transition costs). [D, Iv, P, If, T]
- We will carry out initial scoping and costing of a revised complaints process for complaints again lawyers and firms. We are likely to recommend implementing this using an ‘agile’ approach, which has proved successful in other work, testing new approaches before finalising them into a new initial system. [D, Iv, T]
- We will carry out initial scoping and costing of a revised handling complaints process (complaints about how a Relevant Professional Body has handled a complaint. [D, Iv, If T]
- We will carry out initial scoping and costing of establishing and running a register of unregulated legal services providers. [D, Iv, P, If, T]
- We will carry out initial scoping and costing of a complaints process for unregulated providers. [D, Iv, T]
- We will carry out initial scoping and costing of implementing new processes for the development of guidance on complaints and issues arising from complaints, and the development of policy in relation to other new functions and powers (indemnity, trend reporting, public interest disclosure, etc.). [D, Iv, P, If, T]
- We will carry out initial scoping and costing of implementing a significantly expanded role for the consumer panel. [D, Iv, P, If, T]
- We will carry out initial scoping and costing of implementing an entity-based charging regime. [D, Iv, T]
- We will carry out initial scoping and costing of the business systems, staffing supporting work needed to enable a transformation programme across all work, and on an ongoing basis for new functions, as required by the new legislation. [D, Iv, T]