See answers to previous information requests

Follow on request from WBCIR:19959

My original request sought information on any equivalent bailiff services, not solely High Court Enforcement Officers, across all council functions (Council Tax, Business Rates, sundry debt, parking, etc.) over the past five years. In order to ensure a full response, could you please:

1. Confirm whether any non-HCEO enforcement agents (for example, certificated county court bailiffs, trading-standards enforcement teams, in-house ARP Enforcement officers acting under bailiff powers, or any other provider of bailiff functions) have been used by Wokingham Borough Council in relation to Council Tax, Business Rates, sundry debt or other civil recovery during June 2020–June 2025.
Council Tax have used Enforcement Agents between 2020 and 2025. Otherwise, as previous response to 19959.

2. Complaints & Audit Data
o Any internal audit reports, complaints registers or data analyses concerning HCEO conduct, including numbers of complaints received, outcomes, and any remedial actions taken.
No internal audit reports are kept. Complaint registers contain personal data and will not be released - Section 40 exemption. This is an absolute exemption and doesn't require a Public Interest Test. Complaints are discussed with Enforcement Agent providers who put in place remedial actions.

3. Risk & Governance Policies
o Copies of any risk-assessment documents, governance policies or due-diligence assessments (including insurance reviews) your council uses to monitor or vet enforcement firms.
This information is not held by the Council.

4. Council–Agent Communications
o All email correspondence, meeting agendas and minutes between this council and any HCEOA member firm concerning enforcement-agent performance, complaints or operational matters.
High Court Enforcement Officers are a specific type of bailiff - all HCEOs are bailiffs, but not all bailiffs are HCEOs. We have taken this question to not just apply to HCEOs as would be not applicable otherwise. Under section 12 exemption this would take more than 18 hours to complete this request. There are approx. 3000 cases per year. Without doing the work we wouldn't know what is still held or need redacting. If we took this as 1 minute per case it would be approx. 250 hours (50 per year) which is same as the parking timescales of previous request. Section 32 Enforcement warrants are issued by the courts and would therefore be exempt and Section 40 where it relates to personal data. These latter exemptions are absolute and don't require a public interest test.

5. Scrutiny Committee Records
o Agenda papers, briefing notes and minutes from Overview & Scrutiny Committee or Audit Committee meetings where private-enforcement arrangements or HCEO performance were discussed.
No information held.

6. Performance Metrics & Payments
o Quarterly or annual KPI reports, scorecards or payment schedules tracking enforcement-agent performance (e.g. levies collected, revenue share, performance deductions or bonuses).
No information held.

7. Training & Vetting Requirements
o Details of any training, accreditation or vetting standards imposed on contracted HCEOs (for example, ECHR/vulnerability training), and dates of last review or update.
No information held.

8. Regulatory & MP Correspondence
o Any letters or emails between your council and Members of Parliament, governmental departments (e.g. MoJ, ICO, HSE) or regulatory bodies (e.g. HCEOA, SRA) regarding private enforcement arrangements.
No information held.