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Independent Review of Regulation, Audit, Inspection and Complaints Handling in Scotland

The UNISON Scotland Submission
To Scottish Executive Scrutiny Review Secretariat

June 2007


UNISON Scotland welcomes the opportunity to respond to the Independent Review of Regulation Audit Inspection and Complaints Handling of Public Services in Scotland. UNISON is Scotland's largest public sector trade union representing 160,000 members delivering and scrutinising public services. UNISON represents the majority of employees in the National Health Service and local government in Scotland, and large numbers of employees working in the voluntary and community sector, police staff and scrutiny and review bodies for example the Care Commission. UNISON Scotland welcomes the opportunity to comment on this review.

Independent Review of Regulation, Audit, Inspection and Complaints Handling in Scotland

UNISON Scotland's experience of scrutiny regimes supports the interim conclusions in the review paper:

  • The burden of external scrutiny has grown significantly since devolution
  • The costs of scrutiny have increased significantly
  • The external scrutiny system is unnecessarily complex, lacks coherence and there is lack of evidence on impact
  • There is duplication and overlap between scrutiny bodies causing unnecessary burdens on providers
  • The public voice is not sufficiently represented in external scrutiny
  • The complaints system is unnecessarily complex and not fit for purpose

The defining difference between public and private services is democracy. It is democracy that makes public services responsive to the needs of those who pay for and use them. UNISON believes that democracy is about more than elections and a Scottish Parliament; it is about ensuring that the public can meaningfully participate in the decision-making processes about public services.

Democracy requires government at all levels to ensure adequate opportunities for the general public to participate in and influence the policy making process. This should be more than being asked to comment on plans that have been made in private. It should mean involvement in developing desired outcomes and the methods to achieve them. To facilitate this, organisational structures need to be decentralised to the appropriate level for each function.

Democratic structures create public bodies which are open and transparent in their dealings with the public. Government at all levels must explain and accept responsibility for its actions. However, weak mechanisms and the rise of the quango state have devalued many of our democratic structures. We currently have 144 quangos in Scotland spending nearly £10billion.

UNISON believes that public bodies should as far as possible be directly elected, for example, direct elections to health boards. While for some quangos direct elections may not be practicable, an amalgam of elected representatives, appointed laypersons and professionals with a statutory duty to engage with service users and the public would provide an accountable alternative. Others could be incorporated into existing democratic structures.

Expanding the number of scrutiny bodies and increasing their power will not provide the services people need nor improve their confidence in delivery. Only involving users as partners, not customers, in a meaningful decision making process will achieve this. Public service organisations (PSOs) should have a statutory duty to do so. This must involve a high degree of transparency and the provision of capacity for users to fully participate. Genuine involvement is more than just consultation. It means involving users and staff in defining the problems as well as the solutions.

The best public service organisations are developing a range of such mechanisms and there should be a forum to provide guidance and disseminate best practice. UNISON is supportive of an increased role for voluntary and community organisations, and staff representative bodies in working with elected representatives to influence planning and delivery of local services. This cannot be achieved without appropriate resources. These are not just financial, although that is clearly crucial, it also means politicians and public service workers developing listening skills, the skills to get people together to discuss issues, and to ensure that all voices are heard, not just the best educated, wealthiest or the loudest. All PSOs should be required to produce a corporate strategy on participation and involvement which demonstrates how users, community organisations, staff and their trade unions can be involved in the planning, design, monitoring and review of services.

Complex services, "fair to all" and "personal to each of us" cannot be delivered by central mandate. There must be space for local innovation with broad standards set to disseminate best practice. Users of public services are not homogeneous. The needs and wants of differing groups need to be taken into account when evaluating service delivery.

Appropriate performance measures are essential. Traditional methods of measuring the performance of organisations have concentrated on cost accounting methods that are not be entirely suitable to public services. There is also a concern that a costly, bureaucratic, scrutiny industry is developing to examine public services. The measurements used to assess performance are often subjective and fairly crude and do not take into account all the factors involved in providing a service. They are also often based on what data is already being collected or from the private sector. This can lead to pressure on PSOs to concentrate on such indicators to the detriment of the services they provide: the furore about GPs appointment waiting time guarantees in England illustrates this.

Targets should be based on inputs, outputs and outcomes together with process measures. Financial systems will also need to be reviewed to be consistent with this approach. It should also be recognised that assessing outcomes is fraught with the difficulties of identifying cause and effect and the influence of other policies and organisations. There is also a concern about how open, transparent and useful reports are to the public.

Revitalising public services requires innovation so new ideas and improvements to the way services meet the needs of people are developed. PSOs must also have the capacity to allow innovation to occur; otherwise no amount of innovative thought will actually translate into better services at the frontline. Innovation requires challenging the assumption that public services are based on a "one size fits all" approach. This process requires transparency and an element of risk taking, so it is necessary to end the blame culture to enable innovation to take place without recrimination. Giving staff the resources and freedom to develop networks to learn from best practice is the most effective route to improvement.

Efficiency and effectiveness in the public services are about more than price. The public has a right to expect high performance from public services. That performance should be rooted in a culture of citizenship not consumerism. The quality of services offered - not just the lowest cost - must be a crucial factor. Any analysis of the performance of public services needs to take into account the often-variable funding levels that public services receive as well as their interaction with other public service organisations and the possible impact on their service provision. UNISON recognises that all public sector organisations should be aware of opportunities to work more efficiently and effectively. Genuine scrutiny should provide an opportunity for best practice to spread.

The current amalgam of scrutiny bodies leads to a time consuming set of visits and reports which divert time and resources away from service delivery. There is little or no coordination between audit and regulatory bodies so a review can start a few days after the previous review finishes. Scrutinisers are also often looking for similar information but in very different formats. This means the same data cannot just be passed on but has to be re-collated and reports have to be rewritten within weeks of each other. This complex duplication of data gathering is particularly frustrating for staff. It also leaves organisation with large periods of time where key members of staff are fully involved in reviews rather than delivery of services.


In conclusion UNISON believes that the burden of external scrutiny needs to be significantly reduced. Any new process needs to be greatly simplified and should bring to an end the duplication and overlap that causes significant difficulties for the delivery of services.


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For Further Information Please Contact:

Matt Smith, Scottish Secretary
14, West Campbell Street,
Glasgow G2 6RX

Tel 0845 355 0845 Fax 0141 342 2835

e-mail matt.smith@unison.co.uk

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