Identity Cards for Foreign
Nationals Programme
Immigration Group
Apollo House
Wel esley Road
Croydon
CR9
Mr James Elsdon-Baker
Web www.ukba.homeoffice.gov.uk
13 January 2010
Ref: 12874
Dear Mr Elsdon-Baker
Thank you for your email of 25 September 2009 where you have requested
information about the UK Border Agency biometric enrolment pilot with the Post
Office for identity cards for foreign nationals. This falls to be dealt with under the
Freedom of Information Act 2000.
As you are aware, section 10(1) of the Freedom of Information Act requires that we
respond to requests within 20 working days. Your request was received by us on 25
September 2009 and the statutory date for our response to you was 23 October.
Although I understand that you received a letter informing you that UK Border
Agency would need more time in order to carry out a public interest test and the
deadline was extended to 23 November, no subsequent update of the situation was
given to you. This was a failure on our part to keep you properly informed of the
progress of your case. It is clear to me that we have not met our obligations under
the Act and I offer my sincere apologies for the delay.
You have requested details of the 17 Post Offices that are to be involved in the trial
and these are as follows:
Office
Address
Postcode
Battersea
202 Lavender Hill
London
SW11 1AA
Beckenham
22 Rectory Road
Beckenham
BR3 1AA
Beeston
6a Chilwell Rd
Beeston
NG9 1AA
Office
Address
Postcode
Bracknell High
Street Bracknell
RG12
1AA
Cambridge
9/11 St Andrews Street
Cambridge
CB2 3AA
Camden High
114/120 Camden High
London
NW1 0RR
Street
St
Durham
33 Silver Street
Durham
DH1 3RE
Earls Court
185 Earls Court Road
London
SW5 9RB
Kingstanding
25 Kingstanding Centre Birmingham
B44 9HQ
Middleton
53 Manchester New Rd Middleton
M24 1SQ
Old Street (205)
205 Old Street
London
EC1V 9QN
Oxford
St Aldates
Oxford
OX1 1ZZ
Redditch
Alcester Street
Redditch
B98 8AB
Romsey
15-23 Church Street
Romsey
SO51 8WA
South Shields
Kepple Street
South Shields
NE33 1AA
Stamford
All Saints Place
Stamford
PE9 2EY
Union Street
489 Union St
Aberdeen
AB11 6AZ
You have also requested any documentation, including minutes of meetings,
correspondence and reports of the decision making process, cost and risk
assessment of the trial. I have considered the public interest in disclosing
information regarding our arrangements with the Post Office Limited. I have decided
that a number of documents are suitable for release. In applying the public interest
test I have balanced the arguments for and against releasing information and
decided that some documents are suitable for release in ful , some for partial release
and others are not suitable for release at all for the reasons described below.
Section 42(1)
Some of the information you have requested fal s within the scope of Section 42
Legal Professional Privilege.
I can confirm that we received legal advice regarding our contractual and commercial
arrangements with the Post Office Limited. The content of the legal advice is
however exempt under Section 42(1) of the Freedom of Information Act 2000.
Section 42(1) allows public authorities to exempt information if a claim to legal
professional privilege could be maintained in legal proceedings.
With regard to Section 42(1) we have considered the public interest there may be in
the circumstances of this case in disclosing the information to you. There is a clear
public interest in ensuring that there is a transparency in government decisions and a
public interest in understanding how these are made. However there are strong
public interest considerations in favour of protecting legal advice. There is a strong
public interest in a person seeking access to legal advice being able to communicate
freely with his legal advisers in confidence and in being able to receive advice from
his legal advisers in confidence. The underlying rationale for having a strong rule
against disclosure is that it encourages full and frank exchanges between clients and
their legal advisers, which is judicially recognised as being something strongly in the
public interest for a variety of reasons. It is therefore considered that the public
interest in maintaining the exemption in Section 42 in this case outweighs the public
interest in disclosing the information.
Section 35(1)(a)
Some of the information you request fal s within the scope of Section 35(1) (a)
Formulation or development of Government Policy.
I can confirm that the benefits, costs, risks and issues involved in deciding whether to
proceed with the Post Office trial have been assessed and some of the documents
relating to these are being released to you in full or in part. However I do not
propose to release to you all documentation regarding these discussions. Section
35(1)(a) allows us to exempt information if it relates to the formulation or
development of Government policy.
The use of this exemption also requires us to consider whether in all the
circumstances of the case the public interest in maintaining the exemption outweighs
the public interest in disclosing the information. We have considered the public
interest there may be in the circumstances of this case in disclosing the information
to you. There may be a public interest in greater transparency making Government
more accountable to the electorate and increasing trust, and a public interest in being
able to understand the ful considerations taken into account in any policy decision.
We have considered whether in al the circumstances of the case the public interest
in maintaining the exemption outweighs the public interest in disclosing the
information. We have concluded that the balance of the public interest lies in favour
of maintaining the exemption for some documents (or parts of documents), while for
other documents or parts of documents the balance lies in favour of release.
Disclosing all the advice and consideration regarding our options for biometric
enrolment would constrain policy development with regard to the future direction of
the programme, use of third party suppliers and the wider National Identity Service.
Section 43(2)
Some of the information you request falls within the scope of Section 43(2) Prejudice
to Commercial Interests of any persons.
If I were to disclose al of the information you have requested, this would be likely to
prejudice the commercial interests of both the Home Office and those companies
with whom the Home Office enters into contracts.
This exemption requires us to consider whether, in every respect the public interest
in maintaining the exemption stated above outweighs the public interest in disclosing
the information. We have considered the public interest in disclosing al the
information to you. There wil be a public interest in immediate disclosure to ensure
that there is ful transparency in the Home Office’s use of public funds and in
particular to maintain the Department’s accountability to taxpayers. Disclosure of this
information would also enable the public to assess whether or not Home Office is
getting best value for money in terms of its contracts with those who it procures
contracts, such as those it commissions to carry out biometric enrolment on its
behalf.
We have also considered the public interest in maintaining the exemption. There is a
public interest in Government departments being able to secure contracts that
represent value for money and anything that would undermine this is not in the public
interest. Value for money can be best obtained where there is a healthy competitive
environment, coupled with the protection of Government’s commercial relationships
with industry. Were this not the case, there would be a risk that:
• Companies would be discouraged from dealing with the public sector, fearing
disclosure of information that may damage them commercially, or
• Companies would withhold information where possible, making the choice of
the best contractor more uncertain as it would be based on limited and
censored data.
We have therefore concluded that, whilst some of this information is suitable for
release, the balance of the public interests identified lies in favour of maintaining the
exemption for the remaining information. This is because the overall public interest
lies in ensuring that the Home Office’s ability to protect its commercial
competitiveness is not prejudiced. However, the overall costs of the identity cards for
foreign nationals programme over the coming ten years are published every six
months in the ID Cards Costs Report which is readily available in the public domain.
This contains the costs of operating the Post Office trial.
Section 31(e)
Some of the information you requested fal s under Section 31(e) Prejudice to the
operation of immigration controls.
If we were to disclose information regarding the detailed operating processes
(including security processes) for how the pilot with the Post Office wil work this
could substantially prejudice the operation of our immigration controls. These
processes were assessed as part of the decision making process as to whether the
trial with the Post Office should proceed and played an important part in assessing
risks, costs and benefits. The disclosure of documents relating to these elements
may enable individual immigration offenders or those seeking to undermine the
system to evade detection. The use of this exemption also requires us to consider
whether in al circumstances of the case the public interest in maintaining the
exemption stated above outweighs the public interest in disclosing the information.
We have considered the public interest there may be in the circumstances of this
case in disclosing the information to you. There is a public interest in disclosing the
information as it wil increase the transparency of the work of the UK Border Agency.
There is also a public interest in ensuring that there is public confidence in the
operation of our immigration controls, in this case through operating identity cards for
foreign nationals, and disclosure would allow the public to assess the effectiveness of
the methods employed to assess those seeking to remain in the United Kingdom.
We have also considered the public interest there may be in maintaining the
exemption. There is a strong public interest in ensuring that those seeking to evade
immigration controls in order to remain in the United Kingdom il egally or seeking to
abuse the system are unable to do so. Through being able to access information
regarding the detailed processes and security measures put in place for the Post
Office pilot, such offenders may be able to evade detection and others may seek to
undermine the immigration system.
We have considered whether in al circumstances of the case the public interest in
maintaining the exemption outweighs the public interest in disclosing the information.
We have concluded that the balance of the public interest identified lies in favour of
maintaining the exemption because it is in the overal public interest.
Summary of documents for release
The documents we are releasing in ful or part comprise:
• Letters of communication between the Chief Executive Officers of the UK
Border Agency and Post Office Limited;
• Memos between senior officials outlining why the UK Border Agency should
go ahead with the Post Office pilot;
• Extracts from the Programme Board minutes pertaining to the Post Office
pilot;
• Extracts from the business case;
• Extracts from the risk register; and
• Extracts from the commercial strategy.
I also thought you would find it useful if I described an overview of how the decision
making processes with the UK Border Agency and wider Home Office operated in
relation to going ahead with the Post Office trial.
As part of the rol out of identity cards for foreign nationals we have been assessing
the options to provide enrolment accommodation or services as part of the wider
business case. The preferred option needs to be affordable, achievable, secure,
flexible for customers and provide good value for money.
We have been in discussions with the Post Office for a year. We have assessed the
pros and cons of proceeding with a biometric enrolment trial within the existing
governance structures of the programme, the UK Border Agency and the Home
Office. These include updates on progress at our regular programme boards,
scrutiny of the overal business case at the UK Border Agency Joint Approvals
Committee and also the Home Office Group Investment Board. Senior Directors
within the UK Border Agency have liaised with colleagues in the Identity and
Passport Service, Legal Advisors, Home Office Commercial and colleagues in the IT
and Security Directorates in weighing up whether to proceed with the trial.
In keeping with the spirit and effect of the Freedom of Information Act, al information
is assumed to be releasable to the public unless exempt. The Department wil ,
therefore, be simultaneously releasing to the public the information you requested
together with any related information that wil provide a key to its wider context.
If you are dissatisfied with this response you may request an independent internal
review of our handling of your request by submitting a complaint within two months to
the address below, quoting reference 12874. If you ask for an internal review, it
would be helpful if you could say why you are dissatisfied with the response.
UK Border Agency
Central Freedom of Information Team
11th Floor
Lunar House, Short Corridor
40 Wel esley Road
Croydon
CR9 2BY
During the independent review the department’s handling of your information request
wil be reassessed by staff who were not involved in providing you with this response.
Should you remain dissatisfied after this internal review, you will have a right of
complaint to the Information Commissioner as established by Section 50 of the
Freedom of Information Act.
Once again please accept my apologies for the inordinate delay in responding to you.
Yours sincerely
Rob Carolan
ICFN Programme Director
Item 1 - Letter from Post Office Limited to Lin Homer
5th November 2008
Dear Lin
In response to the United Kingdom Border Agencies` request I am pleased to provide you with this
outline of how a Biographic and Biometric enrolment service could be piloted for the Foreign
National Identity Card programme. I believe that our response is based on providing you with a
value for money, secure, flexible and scaleable service that provides convenience and assurance
to your customers and administrative cost-savings to you. I would add that we are committed to
working with you to ensure that we meet your timelines.
We have responded to your requirements by suggesting an innovative service which drives toward
further automation. This service, I am sure, wil continue to provide benefits to both your customers
and the United Kingdom Border Agency.
I am delighted to give my personal support to this response as it builds upon the existing service
that Post Office Ltd and DVLA are currently embarking upon and I look forward to building a
successful partnership with the United Kingdom Borders Agency.
Yours sincerely
Alan Cook
Managing Director
Post Office Ltd
Item 2 – Note from Jeremy Oppenheim to UKBA Board
From: Jeremy
Oppenheim
Cc: Rob Carolan
Regional Director (NEYH)
National Lead, Economic and Family
Migration
4th Floor (Steel)
Vulcan House
0114 207 1773
21 October 2009
UK Border Agency Board Members and Regional Directors
Update on implementing identity cards for foreign nationals
I wanted to update you on how we are getting on with implementing identity
cards for foreign nationals. On 24 September the Home Secretary
announced that we had hit our target of issuing 75,000 cards by November
two months early. To date we have issued over 95,000 cards. This
demonstrates the first class work by the operational teams, the ICFN
programme and our delivery partners (internal and external). Overall
resilience of the system is also much improved and we have entered student
surge in good shape.
The Home Secretary also announced our plans to accelerate the programme
by introducing cards for those extending under Tier 2 from the New Year. We
have agreed arrangements for a biometric enrolment pilot with the Post
Office which wil help support the increased volumes through student surge
and beyond. We went live from the Post Office’s model office in London on
the 28th September and we wil rol out across 17 sites over the next few
weeks. Together with our PEOs and the four IPS offices, this wil increase
capacity and customer choice.
We recently launched the UK Border Agency’s first online booking service for
those booking premium in country appointments or biometric appointments.
This went live on 18th September and was delivered in just 8 weeks. Over
25,000 users have already registered and more than 6,000 appointments have
been booked.
October has seen another first for the programme – col eagues in London
and the South East have enrol ed the first medical case using the mobile
biometric equipment. Using this discretionary service we take the kit to the
person’s home or hospital for those who cannot travel to enrol. We also have
a few FNPs being enrol ed during October using this equipment. We are
currently reviewing extending this to those wil ing to pay for a personal service
in time for the implementation of ICFNs for Tier 2 on 6th January 2010.
Our new card reading pilot is also going wel . We have deployed the new
hand held machines at Stansted and Terminal 3 and 4. Col eagues in Border
Force have been verifying 50-60 cards each week at these ports – this
technology al ows us to check the person’s fingerprints against those
encrypted on the chip on the card. We have also deployed a card reader
at LSE Enforcement.
Jeremy Oppenheim
Item 3 – Note from Tony Mercer to Justin Holliday seeking funding
agreement
Resource Management Directorate
Room 1206
Apollo House
36 Wellesley Road
Croydon
CR9 3RR
Tel +44 (0)020 8760 8525
Fax +44 (0)020 8760 8529
Email:[email address]
Web www.ukba.homeoffice.gov.uk
To
Matthew Coats, Justin Holliday, Jeremy Oppenheim, Julian Kel y
Cc
Lin Homer, Jonathan Sedgwick, Simon Elwel , Az Ootam, Maria
Woolstenholmes, Rob Carolan
From Tony
Mercer
Date
10 February 2009
Subject
ICFN – Opportunity to pilot biometric enrolment at Post Offices.
Further to Lin’s meeting with James Hall on 29 January, I wanted to write to you to formalise
the position regarding the potential to use Post Offices for identity card biometric enrolment.
Background
As you are all aware, we have successfully rolled out biometric enrolment at six public
enquiry offices (PEOs) around the UK and at the IPS office in Armagh (although this is a
mobile enrolment kit that we take to and from the office ourselves once a week). Our volume
projections show that these arrangements will provide sufficient accommodation until the
student surge in the late summer. We need to agree and implement plans for additional
accommodation well in advance of this so we have time to test processes fully prior to
implementation.
The IPS long term strategy is to develop market enabled front office services for the wider
NIS with one or more commercial partners. IPS are in discussions with a range of potential
providers at present (such as Boots, the Post Office, HSBC and WH Smith) but it is unlikely
that the market wil provide this service before 2010/11 (although IPS may set up some pilots
with providers to test the concept). At the meeting with James Hall on 29 January Lin
expressed her support in principle for this and agreed it is an option for UKBA in the longer
term, should it fit with our target operating model, but it cannot satisfy our immediate need to
build capacity in 2009.
The Challenge
IPS have also recently informed us that they are keen to utilise capacity within their own
accommodation (Interview Office Network and regional offices) and offer us additional
accommodation. On paper it would appear that the spare capacity within these offices could
cope with the additional UKBA footfal but in spite of this we are keen to keep other options
open to ensure we meet our timescales and build a flexible solution for the future. We need
to increase our network to cope with the additional footfall, improve accessibility and
coverage and to protect service standards.
For the last few months we have also been engaging in discussions with the Post Office and
DVLA regarding an option for outsourcing biometric enrolment on a pilot basis (either a direct
contract with the Post Office or via the DVLA framework which is already in place).
I recommend that in the short to medium term we look to implement a mixed economy
of enrolment solutions that balance our own accommodation, IPS (where possible)
and the Post Office.
The Post Office Proposition
The Post Office is already building a biographic and biometric capture capability across its
network. DVLA are looking to utilize this service for the renewal of driving licenses with the
capture of an image and digital signature.
DVLA have confirmed that they are content that their Post Office arrangement, which was
awarded to single tender (and the proposal to extend its use to UKBA biometric enrolment),
is OJEU compliant. There have been no challenges to date and there are unlikely to be any.
DVLA lawyers are confident the arrangements would withstand any legal challenge and this
contract is not cross-subsidising the Post Office.
The current delivery schedule allows for a pilot before full scale implementation. Via this
framework it is possible for the Post Office to enhance the service to provide UKBA with:
• Biometric capture for postal applications (and send securely to UKBA)
• Check and send and biometric capture (applicants can take their completed
immigration forms and supporting documents to the Post Office who would check
completeness before forwarding to UKBA).
The Post Office have recommended we start with just biometric enrolment (we could think
about check and send if the pilot is successful). The Post Office has proposed to run a pilot
for six months at a number of Post Offices nationwide (up to 20 depending on our
requirements) so this can be evaluated. At the end of the pilot we could continue and ramp
up volumes or end the service. At this point we wil have more information about the
progress of the IPS market enabled service and may be able to take part in some of their
commercial pilots.
UKBA would run the fingerprint checks itself after the customer has visited the Post Office to
record their fingerprints (which would be transmitted securely to UKBA). If there were any
issues (eg IDENT1 hit or mismatching identity) the applicant would be asked to make an
appointment to visit a UKBA office where further investigations could be undertaken. The
Post Office would not have access to any fingerprint databases.
Potential Costs
There would be no upfront costs for the Agency in using the DVLA Post Office contract. The
Post Office investment in the wider contract is already guaranteed by DVLA transaction
volumes (7.5m over 5 years). There would be no contractual tie-in to the DVLA contract
should we chose not to extend beyond the pilot.
The costs have not yet been finalised and we are stil negotiating but they are likely to be
below £10.50 for a biometric enrolment (our current working figure). By utilising the DVLA
framework we are likely to be able to reduce this slightly as the contract has a mechanism
which reduces costs as overall volumes grow.
We have two options about how to apportion these costs – they could be fully covered by
UKBA or fully / partially charged to the client by the Post Office. As we have already set fees
for 09/10 it may be assumed that we wil need to pick up all the costs of the pilot.
Over a 6 month pilot we might expect the Post Office to handle up to 50,000 applications
which would cost up to £550,000. We are in the process of comparing the detailed costs but
indications are that this wil cost less in set up and running costs than that which is within the
funding allocation for running ICFN in 09/10.
Benefits
At present there are few options that are likely to implementable in time for the summer and
this is our best opportunity to increase the capacity for enrolling biometrics. It does not lock
us into a contract for any significant length of time and is flexible enough to meet our needs.
The Post Office option builds on work we are already doing with DVLA and they are keen for
us to join with them on this initiative (there are also cost reductions built into their framework
as volumes grow so we could benefit from this). Other benefits of working with the Post
Office are:
• Post Office has vast experience of dealing with the public;
• Government supportive of building services within Post Office;
• Wide national network of offices (we could pick those that meet our geographic
need);
• No accommodation set up costs for UKBA;
• Builds on DVLA service;
• UKBA would need fewer additional resources and less capacity (although we need to
bear in mind the drive to create jobs in the public sector);
• Quicker process for applicants as they do not need to go through the PEO and wait
for the results;
• Lessons learned for longer term enrolment by commercial partners for the NIS.
At the same time we should pursue working closely with IPS on this to utilise any spare
capacity in their office network and the wider market enabled service but stress that we only
want the basic enrolment service at this point with the least complexity possible.
Item 4 – Note to Finance Director, Commercial Director
From: Rob Carolan, ICFN Programme Director
08 April 2009
Jeremy Oppenheim, Julian Kelly, Maria Woolstenholmes
Cc: Laura Morris, Claire Cockburn, Martin Medforth
Update on Post Office Negotiations for biometric enrolment
I wanted to update you on the progress we have made with the Post Office work,
particularly regarding costs. Tony Mercer wrote to Matthew and Justin and others on
10 February to gain their agreement to the general Post Office approach and this
was agreed. We have now reviewed our accommodation requirements over the year
and in terms of PEO, IPS and Post Office and have recommended that we require 14
sites from the Post Office (and this wil be kept under review).
That note contained high level details of the potential costs and we have now been
able to firm up on these as follows:
• There are no upfront costs for the Agency in using the DVLA Post Office contract.
The Post Office investment in the wider contract is already guaranteed by DVLA
transaction volumes (7.5m over 5 years). There would be no contractual tie-in to
the DVLA contract should we chose not to extend beyond the pilot.
• There are our own start up / connection costs (mainly ATOS) that would be
needed for any new site. It is estimated that this wil cost in the region of
£400,000. This is included within our programme resource levels for 2009/10.
• The Post Office have proposed to charge
UKBA £5.00 per biometric enrolment
undertake. This is in line with the fee that they are charging the DVLA for their
basic photo service as part of the wider parent contract so we are unlikely to be
able to negotiate this down any further. In fact we are getting more for our £5
than DVLA. This is cheaper than UKBA providing additional accommodation,
staff and equipment for this service so benchmarks well.
• Additionally, they will charge the
applicant £7.50 handling charge. This
additional £7.50 charge wil be administered by the Post Office and is completely
separate to our charges (much like the current passport check and send service
or a photo-me booth). Whilst this is an additional charge on top of the
immigration fee, we can develop robust lines about how it wil help make life
easier for foreign nationals applying for cards as the Post Office sites are more
accessible and quicker than coming to a PEO. The option to attend the PEO and
not pay the additional £7.50 wil remain an option should applicants prefer not to
pay for this convenience.
• There wil be a nominal handling fee charged to us from DVLA (~£2,000 per
month) which wil pay for our proportion of the administrative costs.
We need to agree the
duration of the pilot. We had initially discussed a 6 month
pilot but I recommend that it makes better sense to run this until the end of the
financial year. We wil then have time to embed the changes and stil have time to
renegotiate and change our minds if needs be. We do of course need to bear in
mind that if we do not progress the Post Office solution past Match 2009 we wil need
significant additional accommodation and would need time to implement this.
Over a 9 month pilot we would expect the Post Office to handle between 50,000 and
70,000 enrolments depending on how efficient they are and the overall supply
volumes. This would cost UKBA between £250,000 and £350,000 and is well within
our 2009/10 budgets (we have ring-fenced £1.5M operational spend for alternative
providers)
Jeremy, Julian and Maria – subject to final commercial and technical
agreements which Martin and I are taking forward are you content that this is
affordable and can be signed off?
Handling
There has been significant interest in this initiative from BERR as they try and build
up the role of the Post Office. We do not want to overly publicise this service as we
need to carefully control the flow of applicants to the Post Office branches
participating in the pilot so we wil need to develop and approach to advertising and
media interest in this. Post Office are supportive of this.
We also need to consider the impact on the wider IPS led market enabled initiative
that is currently underway. Whilst it is not anticipated that other providers wil be on
board before 2011/12, we will be setting a precedent with the Post Office and
shaping the market with a price. We have attended IPS’ first Front Office Services
Development Group with the potential suppliers and they are not yet aware of our
work with the Post Office. IPS are of course aware of our progress and the risk it
poses. We need to work with them to ensure careful handling in this area.
Rob Carolan
Item 5, 6, 7 – Extracts from ICFN Programme Boards
Title of meeting
ICFN Programme Board
Date
9 June 2009
Time
14:00-16:30
Venue
2MS –
Fry Building Room - F329 NW
Chair Jeremy
Oppenheim
Secretary
Nicola Murfitt
Attendees
Annex A
Copies to
Annexes A and B
Apologies Annex
B
ID
Action
Owner
AC-030
IPS to provide PKISS release 2.1 progress updates to the Board going
PW
forward.
AC-031
KP to set up workshop with PO colleagues to discuss issues outlined and
KP
possible solutions to getting the original delivery date of 3/9/09 agreed.
AC-032
Post office to be discussed at the next Board with discussion topics clearly
RC
outlined.
AC-033
GK to report upon how ICFN service management/ operational
GK
performance is progressing to the Board going forward.
AC-034
Report to be provided at the next Board covering key activities, costs and
GH
how we envisage managing the transistion to the ICFN family. The cost
side needs to cover the current 09/10 Arc card spend and what would
happen is we stopped that and applied it to the ARC to ICFN transition.
AC-035
FS to ensure decrease of ARC cards is reported upon regularly.
FS
AC-036
NM to invite Huge Ind to the next ICFN Programme Board.
NM
AC-037
AB to join up with work being done by Laura Hooper to scope delivery
AB
option in detail.
AC-038
A presentation covering what can be implemented in the short term
AB
(delivering in Q2/3 2009)
and in the long term as a ‘joined up’ solution for
UKBA incorporating ICW deliverables is required for decision at the next
Board.
AC-039
DSU sign off is needed on the 1000 record pack ‘end process’ (destroying
GH
the cards) and set out for JO to review at the next Board. (Cat Donahue
was identified as the IPS security lead (for handling data correctly) that
could provide some lessons learned from passport production).
SUMMARY MINUTES
1. Welcome & Introductions
Attendees introduced themselves and Jeremy welcomed the Board. (See Annex A for full list
of attendees, page *).
Actions were run through with updates made direct to separate log (see ICFN Action Log).
Last months Minutes (28.4.09) were approved.
2. ICFN Programme update
LM presented ICFN Programme update outlining key points as:
ICFN Programme has been presented with several big challenges since the last Board. Th
e
programme has been and is continuing to work closely with all delivery partners (HOIT, Atos,
DVLA and IPS) to rectify issues presented.
ICFN 08 has successful y transitioned to HOIT Service management.
ION go live dates
(first go live was confirmed at 12th of June**) and incremental rol out was
confirmed.
JO queried whether incremental roll out to ION go live was best approach
SB confirmed this was one of the best options and that the first go live would be discussed at the
internal IPS RAB (a check point for readiness) meeting tomorrow.
JO confirmed that he does not want a further slip on the 12th of June date for IPS ION go live.
A discussion around PKISS took place with key points being:
The 1 month slippage on PKISS release 2.1 does not affect go live at present.
There is a need to understand whether PKISS release 2.1 incorporates cover for recent issues
as well as existing problems and highlights how MFTP will deal with increased volumes
JO queried why we could not continue with MFTP
LM outlined reasons; Due to volume increase, human error, additional pressure of CWIC
project.
JO queried expected date for resolution
RC confirmed the 5/9/09 subject to the necessary issues (bullets 2 and 3 above) being
understood and resolved.
LM confirmed that in order to ful y understand whether PKISS release 2.1 will cover off the
current problems ICFN will incorporate an e2e messaging review within the Home Office
Delivery Unit (HODU) work. IPS confirmed they are looking at contingency to deal with
increased volumes and that they are looking to improve the SLA with Thales.
SB confirmed the PKISS release 2.1 is progressing however the supplier is limited in terms of
resources.
SB confirmed PKISS release 2.1 go live date as 5/6/09 for UKBA.
AC-030– IPS to provide PKISS release 2.1 progress updates to the Board going forward.
JO queried whether the current reconciliation process (a mitigating action for the current issue of card
duplication) is done manually.
LM stated that this process is no longer manual but automatic via an Atos created report, which takes
3 hours for a resource to carry out.
LM outlined other areas of ICFN activity as:
A new piece of work is being started up which wil look at the highest capacity we can get
through our doors prior to student surge.
Fixed priced contracts wil be in place going forward with Atos to lower costs in our
Programme.
RC confirmed delivery date for Post office as 03/09/09.
MD mentioned further slippage to delivery date due to issues around CCTV, 1000 records etc.
potentially moving the delivery date back to the 3/10/09.
AC-031 – KP to set up workshop with PO colleagues to discuss issues outlined and possible solutions
to getting the original delivery date of 3/9/09 agreed.
AC-032 – Post office to be discussed at the next Board with discussion topics clearly outlined.
3. ICFN 08 transition to HOIT Service Management
DM provided a run through of the paper outlining key points as:
Last week (ending 5/6/09) the ICFN 08 and HOIT Service transition management team met for
the last time.
There are a few areas outstanding which are being worked on and are acknowledged by both
parties.
The e2e solution has been transitioned to HOIT.
Discussion/ questions:
RC queried as to whether we wil now be in a better place when it comes to project liaison and
delivery going forward.
DM confirmed that the HOIT team are already involved with up and coming work.
JO queried route to sorting and raising problems in live environment.
DM confirmed that GK and Darryl Lippert act as the point of contact for any issues for
escalation and that an alternative route for escalation was to raise the issue via usual help
desk numbers used by al staff.
SD commented that L&SE regional operations team have a good relationship with HOIT and
feel confident in their operations and staff to provide a suitable level of information if there are
any system viruses.
AC-033 – GK to report upon how ICFN service management/ operational performance is progressing
to the Board going forward.
4. Arc cards and replacements
FS provided a summary of the paper and what was required from the Board:
Asylum registration card (ARC) is a second generation ID card which was implemented in
2001 and has been operating successfully since them. It holds biometric data (fingerprints)
and is available for asylum seekers showing identity and entitlement (in order for external
organisation verification).
2x batches of 250,000 ARC cards have been purchased since go live in 2001.
The rate of asylum has significantly increased resulting in limited card availability therefore a
decision needs to be made in order to further provide cards to asylum seekers. Options
presented to the Board were:
1. To integrate the ARC card in to the ICFN family as a variant or;
2. To put in a repeat order for existing cards.
Decision required: An owner in order to take this forward is to be confirmed along with a
governance structure and a quick decision in order to al ow for adequate planning and delivery of
the chosen option.
Discussions/ queries:
SD expressed Huge Ind’s view of there should only be one card and his view was to go with
the ICFN integration option.
JO queried whether the Programme has the capacity to look at the ARC to ICFN transition.
The team agreed to look at the next level of detail to bring back for decision.
JO queried minimum batch order figure
FS confirmed that Sagem ARC card causes the 250,00 batch order restraint.
Decisions:
JO confirmed business owner as Huge Ind (Asylum Strategy).
AC-034 – Report to be provided at the next Board covering key activities, costs and how we envisage
managing the transition to the ICFN family. (The cost side needs to cover the current 09/10 Arc card
spend and what would happen if we stopped that and applied it to the ARC/ ICFN transition).
AC-035 – FS to ensure decrease of ARC cards is reported upon regularly.
AC-036 – NM to invite Huge Ind to the next ICFN Programme Board.
5. Contact centre - Online appointment booking
AB provide an overview of the paper:
Paper covers the need for further appointment booking capacity and why online booking is
advantageous over increasing call centre capability. Decisions required were outlined as;
To agree principal of the project, to commission scoping phase and agree resources
needed / governance within ICFN Programme.
Discussions/questions:
CS mentioned possibility to join up with ICW (Rachel Fisher is the contact)
Jo mentioned he has a new resource named Laura Hooper who has been hired to review
the current problems with the call centres and propose solutions.
JO is due to report to the UKBA Board on this matter in the next month.
Technology options included using existing Q-Matic or working in conjunction with ICW.
Decisions:
The project needs to go ahead with an expected delivery date being Q2/3 2009.
The requirements definition, testing etc need to be l oked at.
AC-037 – AB to join up with work being done by Laura Hooper to scope delivery option in detail.
AC-038 – A presentation covering what can be implemented in the short term (delivering in Q2/3
2009)
and in the long term as a ‘joined up’ solution for UKBA incorporating ICW deliverables is
required for decision at the next Board.
6. 1000 record pack approval
GH outlined the need for a 1000 record pack to be issued to DVLA when they calibrate their
machines:
This record pack is a pre-curser to DVLA signing off on the SLA.
DVLA require this record pack in order to baseline machine in regards to throughput.
Decisions:
Principle has the go ahead subject to the following conditions:
Sign off by DSU is gained;
ICFN are confident that this will not lead to duplicate cards being issued and;
The handling process of destroying the cards is to be defined and set out for JO to review.
AC-039- DSU sign off is needed on the 1000 record pack ‘end process’ (destroying the cards) and set
out for JO to review at the next Board. (Cat Donahue was identified as the IPS security lead (for
handling data correctly) that could provide some lessons learned from passport production).
7. CWIC
AB outlined the background to the paper. The decision required from the board was to agree the
location of the data processing team for CWIC and determine whether CWIC casework should be:
Considered within existing casework teams (in Croydon or Sheffield) in line with our current
process on domestic abuse cases, or;
Whether a specific team undertakes this casework, as part of the Expanded Biometric
Supervisors Unit.
Decision:
Confirmation for this to go ahead at the Sheffield site and KC will integrate the additional
CWIC cases of 300 per year into existing case working process.
Title of meeting ICFN Programme Board
Date
11th August 2009
Time
14:00-15:30
Venue
Apollo House, Croydon
Chair Jeremy
Oppenheim
Secretary
Nicola Murfitt
Attendees
See Annex A
Copies to Annex A and B
Apologies
See Annex B
ID
Action
Owner
AC-048
LM to pick up DVLA test records issue (action 00-47) with JO as a
LM
matter of urgency.
AC-049
AC-0049 – DM/HOIT to understand and report upon the cause,
DM / HOIT
business impacts and key mitigations of the 3/8/09 outage by the end
of the week (14/08/09).
AC050
CK to keep Ruth Pope in HODU up to date with ICFN operational
CK
failures.
AC-051
SC to liaise with POL and confirm that utilising the model office as a
CS
live customer environment is a possible option and report back to JO
by week ending 21/8/09.
AC-052
LM to raise issue with Sarah Rapson and gain a decision on the ION
LM
DR second line by 12/8/09 COB.
AC-053
JO to raise funding ownership issue to the ICFN Central Operations
JO
team with the Immigration group Board by week ending 14/8/09 and
to liaise with Tony Smith in regards to locating the unit in LSE
AC-054
LM to work with DM in regards to front and back end alignment.
LM
AC- 055 TG and CC to incorporate new roll out plan in to existing stakeholder
CC / TG
engagement plans which will need to be reviewed by JO.
AC-057
CC to issue volume projection re-cut to RH, IPS and HOIT colleagues. CC
SUMMARY MINUTES
3. Post Office Limited (POL)update
SC outlined the key highlights in regards to this update:
POL Communications lead have been in touch with Eleanor West (ICFN Comms
lead) to discuss external stakeholder plans and level of involvement.
Phil Burrett and Dan Turner visited POL offices to enrol 10 members of the team. Al
10 enrolments went smoothly and no issues occurred.
The data flow from enrolment through to card production is being reviewed to ensure
this process is adequate.
The site survey is complete with no issues.
POL Security lead is providing a draft of the key document set required for
accreditation of the final solution to UKBA by week ending 14/8/09.
A meeting regarding service delivery with HOIT and ICFN is due to take place within
the next two weeks with the aim being to bring together an initial draft of the service
management framework.
Main issues reported as:
o How the datagram from POL to UKBA can be securely read. POL met with
their suppliers (Cogent and Phoenix) and UKBA’s supplier ATOS to re-define
the boundaries of secure firewalls and secure end to end messaging. The
solution for this issue is to be released by COB today (11/08/09).
o How CCTV is delivered to UKBA. POL suggested that they store the footage
until UKBA can push a secure message down to the UKBA server. POL
reported that they are expecting confirmation from ICFN as to whether this
can be carried out.
LM queried the data standards.
SC confirmed that if any changes were to be made to the equipment (that could
potentially affect the data standards) that UKBA would be involved in the risk
assessment from the beginning and that this would be classed as a formal change
request in which UKBA would be invited to attend all three change Boards that this
request would be required to go through.
SC confirmed that the expected delivery date for the model office is the end of
September and that the first office available to the public will be the 5th of October.
SC proposed that the model office be made available for customers if UKBA were
interested in pursuing that route.
JO confirmed that he is keen to pursue the route of the model office being available
for public use.
JO asked SL how much of an impact Front Office going live at 5/10/09 would have on
student surge.
SL expressed that this would impact the business in terms of dealing with another
change at the same time as student surge.
JO recommended that the ICFN Programme team work closely with SL in terms of
key dates.
JO queried where we are at with IONS
LM replied that all four ION sites are now live however there is a second line (for DR
purposes) which is not yet in place. This is causing IPS to impose a limit of 100
enrolments per site per day.
LM has suggested that the ramp up take place asap so if any teething problems are
to occur they can be worked through and fixed prior to student surge.
GB commented that ATOS can support the POL in bringing the live environment
forward to suit the model office delivery date of the last week of September.
AC-051- SC to liaise with POL and confirm that utilising the model office as a live customer
environment is a possible option and report back to JO by week ending 21/8/09.
Title of meeting ICFN Programme Board
Date
8th September 2009
Time
14:00-15:30
Venue
Apollo House, Croydon
Chair Jeremy
Oppenheim
Secretary
Nicola Murfitt
Attendees
See Annex A
Copies to Annex A and B
Apologies
See Annex B
ID
Action
Owner
AC-060
Programme to monitor benefits realisation closely and report back to CS
future meetings.
AC-061
NM to send SD Benefits Realisation Management plan (BRM) and
NM
include BRM discussion in October’s Board agenda.
AC-062
Claire Cockburn to draft a submission to Sarah Rapson regarding
CC
ION support thanks and extending ION office hours/days.
AC-063
DM to tailor the Programme Board Service Management report to be
DM
more focused around the steps being taken to tackle the root cause
of incidents and to feature a column displaying incidents that remain
unsolved.
AC-064
DM to look at the way in which Glasgow PEO escalate incidents and
DM
meet with ATOS to look at problem management and incident
categorisation – to ensure incidents are being raised efficiently.
AC-065
RC to review escalation procedures with HOIT and ensure they are
RC
efficient.
AC-066
LM to set up a workshop to review the PKISS manual E2E process
LM
during peak service.
AC-067
IPS to provide ICFN with a forward looking service management
WH
document covering ION’s costs involved.
AC-068
PB to work with IPS to outline the benefits and risks of IPS carrying
PB
out PKISS 2.1 options work and present this to Jeremy Oppenheim
and Justin Holliday ASAP.
AC-069
DF to issue projected volumes during student surge to Kevin
DF
Sheehan and IPS team members.
AC-070
WH to update RC as to progress IPS have made with the
WH
accreditation of PKISS prior to the next Board.
AC-071
LM requested that thoughts the board members may have on initial
LM
and future ownership of online booking service management to be
passed on.
AC-072
JO to talk to Simon Elwell about Online booking and possible ICW
JO
ownership.
AC-073
LM to arrange a live online booking demonstration for the next Board LM
(October 6th 2009).
AC-074
DM and DF to complete the student surge action plan with actions
DF
from HOIT.
AC-075
SL to co-ordinate the weekly and monthly PEO stats feed to ICFN
SL
from all regional branches.
AC-076
LM to look in to acceleration of ramp up for online booking and the
LM
impact of more people using Online Booking instead of
TelePerformance.
AC-077 DF to look in to the costs involved in extending PEO office hours and DF
work arounds available to increasing office hours without incurring
extra costs and present at the next board (October 6th 2009).
AC-078
DF to see if customer searches at PEO’s can be stopped during
DF
student surge.
AC-079
DF to feed into the regional director meeting on a Monday afternoon
DF
to update preparations for student surge.
AC-080
SD to gain confirmation from the International Group that there is no
SD
risk associated with the document reference numbering structure as
is. Once confirmation is obtained this is to be forwarded to Rob
Carolan in writing.
AC-081
MK to draw up the level of risk and degradation alongside the
MK
preferred option for a temporary solution to the POL
Communications link and submit to Jeremy Oppenheim and Justin
Holliday for sign off out of committee.
AC-082
NM to add e-Borders Modernising Border Programme to October’s
NM
agenda.
AC-083
RC to ensure CK is made aware of HOIT’s request to be included in
RC
any decision around mobile ramp up.
SUMMARY MINUTES
1a. Welcome & Introductions
JO Welcomed the Board and al attendees introduced themselves.
1b. Minutes & Actions
The minutes from Tuesday 11th of August were approved and actions reviewed. Updates to the action
log have been made directly to the ICFN Programme Board action log spreadsheet (separate
document).
2. ICFN Programme Update
JO updated the Board on preliminary HODU findings:
The issue of confidence between IPS/UKBA was raised. The HODU team felt too much time
was spent checking each others work.
JO also asked for a greater degree of challenge of ICFN from board members.
LM outlined the key updates from the Programme update paper.
Other comments made were:
Positive GIB session on the 3rd of October however it was noted that the Programme needed
to improve benefits ownership, tracking and relisation and that a additional commercial
resource was needed moving forward.
The current period was an intensive time for the team however all major deliverables were still
on track for delivery.
RC commented that the 75k card target has been delivered early (public pledge was to be
delivered by November 2009).
JO raised the following:
That a note be drafted to Sarah Rapson regarding his and ICFN team thanks to ION staff for
all their hard work and support and extending ION office hours/days.
That he would be sending a submission to the Home Secretary regarding the 75, 000 card
target in advance of the Home Secretaries announcement about T2 acceleration and Post
Office pilot on the 24th of September.
His concern about network stability; especial y in Glasgow where in August,14 incidents
occurred during a 1 week period, which has since been ratified as 14 during a month.
AC-060 – Programme to monitor benefits realisation closely (as a result of the GIB meeting).
AC-061 – Claire Cockburn to draft a submission to Sarah Rapson regarding ION support thanks
and extending ION office hours/days.
AC-062- NM to send SD signed of BRM plan and add BRM discussion to future Board agenda.
3. HOIT for ICFN Service Management update
DM outlined the key updates from the HOIT Service Management paper.
The following discussion points were covered:
DM provided a verbal update on the latest incidents.
RC queried the Service Management update in terms of the information as it focused more on
the symptoms and causes of incidents rather than the steps being taken to tackle the root
cause It was agreed that this would be the focus with future reports.
RC echoed the concerns of Jeremy in regards to network stability issues in Glasgow and was
especial y concerned that Glasgow had experienced 14 incidents in 1 week and asked how
HOIT to investigate further.
DM responded that the Service Management team had not been notified of the 14 incidents
Glasgow and suggested the fol owing action points:
1. To look at the way in which Glasgow PEO escalate incidents
2. Meet with ATOS to look at problem management and incident categorisation.
3. CC to provide note from RD concerning these issues.
AC-063 - DM to tailor the Programme Board Service Management report to be more focused
around the steps being taken to tackle the root cause of incidents and to feature a column
displaying incidents that remain unsolved.
AC-064 - DM to look at the way in which Glasgow PEO escalate incidents and meet with ATOS
to look at problem management and incident categorisation – to ensure incidents are being
raised efficiently.
AC-065 – RC to review escalation procedures with HOIT and ensure they are tight.
4. PKISS 2.1 release progress update
WH outlined the key updates from the PKISS progress update paper.
Update on PKISS re-accreditation to be provided to RC out of committee prior to the next
Board.
WH raised the following decision required by the Board: IPS had asked for a decision from the
Board in regards to whether they feel there is value in perusing options available to the
manual workaround currently being utilised in version 108.05 the Board were not comfortable
with the risk posed and deferred pending further information re- actual risk.
The following actions form the decision:
AC-066 - LM to set up a workshop to review the PKISS manual E2E process during peak
service.
AC-067 – IPS to provide ICFN with a forward looking service management document covering
costs and next version testing.
AC-068 - PB to work with IPS to work out the benefits and risks and present this to Jeremy
Oppenheim and Justin Holliday ASAP.
AC-069 - DF to issue projected volumes during student surge to Kevin Sheehan and IPS team
members.
Once the above actions had been carried out the decision (regarding PKISS Manual work around
options work) should be taken out of committee by Jeremy Oppenheim and Justin Holliday and
reported back to the Board by Rob Carolan on the 6th of October.
AC-070 - WH to update RC as to progress IPS have made with the extension of PKISS re-
accreditation prior to the next Board.
5. Online booking update
LM outlined the key updates from the Online Booking update paper.
LM outlined that the next steps now needed to be explored and agreed. Currently ICFN were
talking with Denise McDonagh and other HOIT team members to agree where Service
Management should reside.
AC-071 - LM requested that thoughts the board members may have on initial and future
ownership of online booking service management to be passed on.
AC-072 - JO to talk to Simon about Online booking and possible ICW ownership.
AC-073 - LM to arrange a live online booking demonstration for the next Board (October 6th
2009).
6. ARC Project update
RC updated the Board:
Elaine Bass and Huge Ind had confirmed that the current ARC process was to remain until the
Immigration Group had the budget to cover design and implement a new card.
7. POL Update
SC outlined the key updates as:
Testing continued to move forward.
Revised data had been sent over to UKBA for cards to be produced – awaiting confirmation of
successful completion from UKBA.
Over the counter process flow was to be finalized and signed off soon.
Anticipated volumes as each site was taken on and potential ‘throttle’ control was being
looked at by ICFN and feedback was to be sent through to POL soon.
UKBA had confirmed that there was a press release going out within the next few weeks
however SC stressed that early site of the press release is appreciated as POL had an
internal sign off process to go through.
The communications link was due to be in place next week however this had now slipped by 6
weeks. A workshop was taking place during the Board meeting between POL, ICFN and core
suppliers on both sides to walk through solutions available in place of the communications link
as a temporary measure.
SC stressed that stakeholders would need to have sight of and sign off on the options before
we could move forward.
SC noted that commercially the contract was moving towards a live service and SC
recommended that the focus be on a pilot service contract (in the interim) in order to help
move things forward quickly.
The following discussions took place:
SB queried how much e2e testing was required from the post office.
RC confirmed that 5 sets of completed data records needed to be pushed through the e2e
system in order for testing to be successful. If not, the capture at POL would be tweaked until
it worked.
JO requested confirmation of Post office pilot go live date.
SC confirmed the 28/9/09 as the go live date assuming that accreditation of the interim
solution would be in place.
DM queried whether ICFN would await the accreditation of the interim solution before a public
announcement of the post office pilot was announced.
RC confirmed that nothing would be announced until we had the green light.
DM queried whether the production of 5 cards was enough to test the E2E system.
RC confirmed that the test was just to check that data could pass through PKISS and produce
a card to required standard – this was not a “stress” test.
8. ION ramp up
NP reported the fol owing:
She and DF would be visiting each IPS ION site during the following week to see if they could
help with any issues during ramp up.
9. Student surge action plan
DF outlined the key points from the student surge action plan paper.
The following discussions took place:
DM commented that HOIT and DF have very similar action plans and was pleased at the
alignment to date.
JO queried the ease of ramp up for online booking should it become successful and the
possibility of accelerating that ramp up. .
DF proposed an increase in opening hours during student surge.
JO queried whether it was possible to stop searches at PEO’s.
SD and SL responded that they did not want this to happen.
AC-074 - DM and DF to complete the student surge action plan with actions from HOIT.
AC-075 - SL to co-ordinate the weekly and monthly PEO stats feed to ICFN from all regional
branches.
AC-076 - LM to look in to and include the ease of ramp up for online booking and the possibility
of getting people to stop using TP should this become a desire of the business.
AC-077 - DF to look in to the costs involved in extending PEO office hours and work arounds
available to increasing office hours without incurring extra costs and present at the next board
(October 6th 2009).
AC-078 - DF to see if customer searches at PEO’s can be stopped during student surge.
AC-079- DF to feed into the regional director meeting on a Monday afternoon to update
preparations for student surge.
10. IDENT P2 approach sign off
RC reported that the IDENT Phase 2 approach was designed to prevent card number
replication.
There was no longer a risk of card number replication due to the document numbering
structure used for ICFN and Visa and since this risk was no longer valid RC would like
confirmation from the International Group that ther were content for ICFN to use IDENT1 as
detailed in the original contract and not proceed with the Phase 2 upgrade.
AC-080 - SD to gain confirmation from the International Group that there is no risk associated with the
document reference numbering structure. Once confirmation is obtained this is to be forwarded to Rob
Carolan in writing.
11. Post Office Communication link Options Paper
There was insufficient information to enable an informed decision to be taken and this would
be progressed out of committee.
More work was being undertaken by the team on this.
AC-081 - MK to draw up the level of risk and degradation alongside the preferred option for a
temporary solution to the POL Communications link and submit to Jeremy Oppenheim and
Justin Holliday for sign off out of committee.
Any Other Business
PC confirmed that e-Borders had begun the Modernising Border Programme and asked the
Board whether they would want an overview of the Programme at the next Board.
AC-082- NM to add e-Borders Modernising Border Programme to October’s agenda.
DM requested that HOIT were included in any decision around mobile ramp up.
AC-083- RC to ensure CK is made aware of HOIT’s request to be included in any decision
around mobile ramp up.
Annex A
Attendees
Jeremy Oppenheim (JO) (Chair) NEYH Regional Director
Rob Carolan (RC) (ICFN Programme Director)
Laura Morris (LM) (ICFN Programme Manager)
Steve Dunwell (SD) (ICW Programme Director)
Simon Black (SB)(Identity & Passport Service)
Kevin Sheehan (KS) (Identity & Passport Service)
William Highfield (WH) (Identity & Passport Service)
David Armour (DA)(International Group)
William Bouquet (WB)(HO Corporate Services)
Steve Lamb (SL) (NEYH Regional Operations Director)
Peter Clark (PC) (e-Borders)
Sonia Dower (SD)(LSE Operations)
Mohammad Khan (MK)(HOIT)
Gerard Kool (GK)(HOIT)
David May (DM) (HOIT)
Richard Harris (RH) (DVLA)
Spencer Chapman (SC) (Post Office)
Richard Turner (RT) (Atos Origin)
Sean Gibson (SG) (Atos Origin)
Claire Cockburn (CC) (ICFN Strategic Manager)
Nicola Percival (NP) (ICFN Business Change Manager)
David Fielding (DF) (ICFN PMO Manager)
Annex B
Apologies
Clive Jones (UKBA Commercials)
Paul Waring (Identity & Passport Service)
Nominated representative - Simon Black
Glyn Williams (International Group)
Nominated representative - David Armour
Naomi Hatton (Earned Citizenship)
Tom Greig (HO Corporate Services)
Nominated representative - William Bouquet
Julie Gillis (e-Borders)
Nominated representative - Peter Clark
Mike Lyne (Secure ID)
Frank Smith (National Biometric Identity Service)
Emma Churchill /
Carolyn Bartlett
(Immigration Policy)
John Dalton (HOIT)
Nominated representative – Gerard Kool/ David May
Sue Caulfield (Immigration Fingerprint Bureau)
Graeme Barker (Atos Origin)
Nominated representative – Richard Turner
Item 8 – extracts from BRP Business Case
service, and that suitable test environments are available prior to acceptance of new
systems.
The June 2007 Business Case used variations within these capabilities to define its
options. These were subsequently refined in the papers sent to JAC and GIB in
September and December 2007.
Additional Capabilities developed Since December 2007
Since approval in December 2007 additional capabilities have been added to the
core BRP system. These have been reviewed individually by senior UKBA officials
and endorsed by ministers. This update to the June 2007 Business Case focuses on
the costs and benefits of these additions. The additional capabilities are described in
the following table:
Additional
Description
Capability
IDENT1 (police
This provides a robust and sustainable IT link between the core BRP
fingerprint database) system and the police and security services fingerprint database for
checking
fingerprint checking before the issue of an identity card. It checks
whether applicants have committed any crimes in the UK or appear on
any counter terrorism databases. It utilises infrastructure put in place
for biometric visa checks.
These checks thus enhance the security of the UK and help the UK
economy by reducing criminality and deterring criminals from applying
for cards and from committing crimes whilst in the UK. It reduces the
reputational risk to the Home Office that migrants convicted of serious
crimes are granted leave to remain and issued with a BRP card.
Mobile enrolment
This capability provides mobile enrolment for those applicants unable
to attend a UKBA/Post Office/IPS site. It will address the needs of
housebound applicants who are physically, medical y or mentally
incapable of leaving their home.
This service meets requirements under the Disability Discrimination
Act.
Secure delivery
BRP cards and other documents are sent to customers via secure
courier delivery route which reduces the likelihood of documents being
lost or stolen in the post falling into the wrong hands.
Enrolment at Post
This is part of the record biometric capability and allows customers to
Offices/IPS / FOS
enrol their biometrics at designated offices within the Post Offices/IPS
providers
networks. It is only for the recording of biometrics – no caseworking or
delivery of cards will be made through these channels. The Post
Office and IPS have more geographically extensive networks than
UKBA and so are nearer the heaviest concentrations of national
applicants. The provision of this capability significantly reduces the
travel time and costs required to enrol, but does not deliver any other
significant benefit directly to the BRP project. The ability to enrol at
post offices wil have a significant impact on the NIS as a whole.
Verify biometric
0% 20% 0%
before issuing
CONS
Inconvenience to
none 20% none
Applicant
Risk of
high medium
low
loss/interception
Although the preferred option from the previous 2007 business case did not include
secure delivery, it was subsequently decided to use the Secure Mail Service provided
by DVLA and has been endorsed by Ministers. It also contributes to the quantified
benefit that arises from the fact that we will not need to replace cards that are lost in
the post. This benefit is only quantified to the value of £116,000 over the project
lifespan; however this quantification does not reflect the wider economic and
security-related harms that might occur as a result of cards falling into the wrong
hands.
2.1.1 Accommodation and enrolment
Accommodation / biometric enrolment is a core requirement because UKBA cannot
operate the card service without enrolment facilities run by UKBA
and additional non
UKBA provision. The costs are spread across all the capabilities that require
accommodation.
The original business case concluded that it was unlikely that the existing UKBA
estate would give the best possible coverage for the target applicants. For this
reason, we explored the use of other local office networks to implement a hybrid
UKBA – external solution, such as the DVLA, who are producing the card.
Since this Business Case was submitted in June 2007 there have been several
developments affecting the provision of BRP accommodation:
• DVLA stated that the decision to deliver biometric enrolment at their offices
would need cross-Ministerial agreement and it is not in line with their current
business model (as such was ruled out);
• IPS were approached about using the ION network offices for foreign national
biometric enrolment. Initial feedback was that it was not possible for UKBA to
use their office. However, the IPS reviewed this decision and concluded that it
was possible to share some accommodation with BRP. Plans to develop
enrolment facilities at selected sites in the ION network are being implemented
(to date four sites have gone live);
• We have investigated the use of Post Offices to enrol applicants’ biometrics.
We are advanced in the negotiation of an agreement to use their network. Its
extensive network across the UK, its developing experience with taking
biometrics for the DVLA and its role as a trusted source for government
business meant that it was a very attractive partner.
The IPS are developing a network of enrolment sites by creating a market with
leading companies / organisations with an extensive footprint across the UK. This
network is known as the Front Office System (FOS). It is highly competitive from the
point of view of UKBA affordability since it would not
• charge UKBA and would raise its income by charging applicants per
enrolment. However it wil not be ready until 2011/12.
Since UKBA does not have the capacity to provide the accommodation to process al
applicants and because the recording of ID biometrics is not part of the DVLA
business model we have based the accommodation / enrolment costs on the
assumption that the Post Office and IPS wil provide the capacity which UKBA lacks
until the IPS FOS starts in 2011/12, and that UKBA will utilise some of the FOS
solution. The costs are competitive especial y when compared to the alternative of
developing additional UKBA sites. Therefore we have used the latest indicative costs
they have supplied, although these are stil subject to detailed review and
negotiation. The FOS solution has no supplier set up costs that would be paid by the
Home Office – the assumption is that the market wil undertake this work itselfand
charge customers to make its money. The wider NIS business cases include the
costs of the wider work and UKBA’s requirements wil be included when developing
the standards that suppliers should use. UKBA does not own any of the POL
equipment and as such there would not be de-commissioning costs.
Therefore enrolment facilities will be provided through a mixture of sources. The
assumptions used in the business case model are summarised in the following table:
Estimated sourcing of Enrolment Capacity
% split per
UKBA
IPS Interview
POL
FOS
provider
Office Network
2009/10
60 25 15 0
2010/11
40 24 36 0
2011/12 onwards 20 0 0 80
In selecting the optimum distribution of the enrolment network we originally undertook
population density mapping of the foreign national population in order to ascertain the
likely locations where our applicants live and where our locations should be. This is
based on the 2001 census. The table below il ustrates the population densities that
were used. The census information for all non EEA foreign nationals was taken and
scaled down proportionately (the census covers over 3 mil ion non EEA foreign
nationals but only about 770,000 of them wil get a BRP each year in steady state).
Since the 2007 business case BRP went live in November 2008 we can analyse
actual addresses of applicants to date. From this we can work out their actual
geographical distribution.
The distribution works out as fol ows:
Region
2007 Business Case
Analysis of BRP Applicant
Assumption %
Addresses %
London and South East
56 59
Midlands and East of
21 5
NEYH
7
12
North West
7
10
Scotland and Northern
4
6
Ireland
Wales and South West
5
8
Total UK
100 100
This information has allowed us to review the number and select the locations of the
sites where we wil get reasonable and cost effective national coverage and work out
the social costs of applicants travelling to and from their nearest enrolment centre.
Contingency Plans for enrolment
If the FOS programme did not go forward or if the market could meet our
requirements then an alternative enrolment / accommodation strategy would be
required. This should be known by mid 2010. If an alternative was required it is
assumed that a competition or market test for continued use of the Post Office would
be required. This could impact ongoing costs of the service (if there was a charge to
UKBA for this service), but if the Post Office were to provide this service for greater
volumes there would be potential to drive down costs.
From 2011/12 we have assumed that 80% of our enrolment would be undertaken by
FOS. This equates to somewhere between 60 and 100 enrolment points at Post
Offices, depending on average throughput and peaks in demand (the pilot we will
have 17).
2.1.1 Refusal rates and cost sensitivity
Updated figures include a refusal rate of 6%. This more accurately reflects the new
processes. The refusal rate does have an effect on costs. As the rate reduces, costs
increase due to the production of more cards. The variable cost of a single card is
£5.93 relating to materials. There is a further variable cost element relating to
distribution. This will be approximately £3.52 for secure or recorded delivery. The
total unit variable cost is £9.42.
2.1.2 Enforcement for applicants whose biometric enrolment causes
concerns
The decision to refuse an application is linked primarily to the immigration decision.
This will take place after the biometric event as part of caseworking processes. The
vast majority of our refusals (6% of applicants in total) wil occur in this way and
therefore any enforcement wil not be in scope of the BRP project, rather it sits in
business as usual for caseworking.
There will be a smal number of refusals that are based on a biometric “hit” which
cause concern. For example, a match to the biometric database that causes us to
refuse application e.g. a failed asylum seeker now applying for leave to remain.
Resource Set
-22,418
-20,131
2,287
Up
Capital Set Up
-455
-3,132
-2,677
Operating
-106,652
-114,365
-7,713
Resource
Operating
-641
-185
456
Capital
Total Present
-56,210
-58,234
-2024
Value Social
Costs
Total Present
138,971
156,256
+17,285
Value Quantified
Benefits
TOTAL NET
-47,404
- 39,791
+7,613
PRESENT
VALUE
2.1.1 General Conclusions
Some of the key points from the analysis cost and benefits are:
• The modified Option IV (Secure and Manageable) generates a higher Net
Present Value. The inclusion of the IDENT1, SMS delivery and Mobile
Enrolment capabilities and the use of the Post Office / FOS to record
biometrics in sum create a net present value to the economy, with the higher
costs of the enhancements offset by savings in the provision of record
biometric capability and forecast decreases in the number of applications
• The operational RDEL cost of modified Option IV is slightly higher than the
original Option IV, although the cost structure is very different. In short the
modified Option saves UKBA staff and accommodation and the purchase of
biometric recording equipment but adds the cost of Post Office and IPS
charges, IDENT1 checks and secure delivery and increased contact centre
charges.
• The modified Option IV generates a slight increase in social costs because
applicants have to travel a little further to their appointments to have their
biometrics recorded.
• This shows that the difference between the economic costs of these options
is driven by the number of people whose biometrics are verified.
• Card services costs have increased with the modified Option IV because
cards are delivered through secure courier delivery rather than through
ordinary postal services.
• We generate operational savings in the production of vignettes. These are
realised as card production ramps up and replaces vignette production.
The observation from this table is that Option IV Modified provides a slightly higher
level of economic cost then the original Option IV but generates higher benefits. In
the ‘Request for Remaining Funding’ paper of December 2007 the selected Option IV
had
a net present cost of £47m. Option IV Modified has a net present cost of £39 mil ion ,
providing an additional £8m of additional economic benefit.
This is because the more complete and secure the implementation, the greater the
benefits. In addition the Option IV modifications and greater understanding of costs
and suppliers have enabled costs to be reduced, particularly the use of the Post
Office to record biometrics; at the same time the inclusion of IDENT1 brings
additional benefits compared to the Option IV solution that was agreed in December
2007.
We have analysed the options on a very prudent basis, and have only quantified
benefits where we are satisfied that there is a sufficiently robust method available for
doing so. Details of the benefits we have quantified are set out in Annex C.1 and in
the benefits section below. We have worked closely with the NIS cards Business
Case team to avoid double-counting of benefits.
Use of the Post Office to record biometrics changes the cost profile of the different
options. The indicative Post Office agreement means that the UKBA avoid the need
to find additional accommodation and the purchase of biometric recorders. On the
other hand these savings are balanced by Post Office charges to applicants. The net
effect of these changes is to increase social costs by just over £2mil ion over the
whole of the project.
The addition of IDENT1 checks does raise the set up costs to develop the core BRP
system and will incur additional transactional costs. However this raises the deterrent
effect of BRP and so gains additional quantified benefits.
The other key change between the modified Option IV and the original Option IV is
the use of secure mail delivery. This raises operating costs by the extra cost of the
courier service multiplied by the volume of applications. However it secures modest
quantifiable benefits from the reduction of cards lost in the post and, more
importantly, makes the whole system more secure.
2.1 Recommendation
We recommend Option IV Secure and Manageable (Modified) as the preferred option
for implementation, for the following reasons:
• It has the best balance of costs, benefits (financial and non-financial) and
risks
• It al ows us to comply with the EU Regulation
• It has a positive NPV and delivers substantial intangible benefits.
• It delivers £156.3 mil ion in quantified benefits over the project lifespan
1.
Financial Case
3.1 Summary of budget profile and funding arrangements
The Financial Case is designed to ensure the preferred value for money option is
affordable when assessed in terms of the available capital and revenue resources,
and ongoing funding requirement.
The following tables show the breakdown of funding requirements for the preferred
option. We show the required and available funding fol owed by a surplus or deficit.
This is shown year on year and for the whole life of the project.
The following table compares the affordability between Option IV from the December
2007 submission to the GIB of the business case and Option IV (modified). These
costs reflect the functional specifications for the project, figures from market
analyses, experience from the pilot and other operational experience, and recent
figures obtained from our likely delivery partners in DVLA, the Post Office,
International Group and Home Office IT.
£mil ion
Option IV – Secure
Option IV Secure and
Option IV – Secure
and Manageable
manageable (Updated and Manageable
for the Sept 08 GIB
Modified
Update)
Whole Life
172
167
176
Costs
DP08 Costs
78
76
80
Total Setup
22
24
25
Costs
*These figures do not include £1.7 million of CDEL although it was reported as the whole life cost figure
in the December 2007 submission or £1.2 mil ion of CDEL in the DP08 figure. Therefore the Dec 2007
whole life cost figure should be £174million and the DP08 figure £79 million
Between the December 2007 business case costings and June 2009 there have
been a large number of changes resulting in a slight increase in whole life costs. The
main changes and cost impact are listed below:
Reason for Cost Change
£’000
DECEMBER 2007 TOTAL COST
174,160
Revisions in forecast volumes of enrolments and cards issued
-17,945
Increase in contact centre charges and average times per call
26,229
Switch from PEO provision of enrolment services to Post Office
-13,477
and IPS ION
Use of IPS FOS from 2011/12
-22,102
Operational Enhancements to BRP Capability (IDENT1 checks,
38,070
Mobile enrolment, secure delivery)
Reduction in verification costs due to revised biometric
-11,114
enrolment arrangements
Reduction in card col ection due to Secure Delivery operational
-3,928
enhancement
Increase in Corporate and Programme costs to deliver
2,904
enhancements and resolve issues
Adjustment for reductions already accounted for in baseline
4,600
(represents reductions reported in September 2008 submission to GIB)
Other changes (net)
-1,499
Revised Total Cost
175,898
These changes can be explained as fol ows (together with the drivers for the
changes):
•
Increase in Contact Centre Costs
These charges have increased because the average time of calls experienced to
arrange appointments in the pilot and in operation have gone up and we have
received increased charges per call from the provider. The assumptions used in
the original business case were incorrect.
•
Switch from PEO provision of enrolment services to Post Office and IPS
Interview Office Network The original business case assumed that UKBA would provide all
accommodation and staff costs for the enrolment of biometrics. Since there is
insufficient capacity in the existing estate new sites would have to be procured.
This is not cost effective so new arrangements have been established with the
Post Office and IPS. This means that payments to the PO and IPS have been
included but there have been significant overal reductions in accommodation,
staff costs for biometric enrolment and some capital expenditure since the Post
Office include recovery of their set up costs in their charges. This switch in
provision has provided a significant net saving. This solution provides a flexible
accommodation provision with a better nationwide network of centres than the
original business case.
•
Use of FOS from 2011/12
The use of the Post Office and the IPS ION for biometric enrolment is assumed to
stop when the NIS brings its enrolment service (known as the Front Office
Service) into operation. This is in line with the HMT review of the NIS delivery
model in 2008. The commercial arrangements for this are that the suppliers will
not charge the Home Office but wil recover their costs directly from applicants.
Therefore the only costs included are the increased social costs to applicants.
Again, this solution provides a cost effective and flexible solution for UKBA
clients. We retain the option of bringing in those of concern to a UKBA office as
required for follow up action.
•
Operational Enhancements
Three significant enhancements have been made to the capability and service
level provided by the BRP project. These are:
o Checking enrol ed fingerprints against the police and CT IDENT1
database which stores all fingerprints collected by the police / other
agencies. There is a charge for each check and an enhanced charge
for investigating any positive match. The inclusion of IDENT1 checks
in the scope was agreed with Ministers shortly before go live. Costs
were significantly lower than earlier estimates (which had ruled this
option out).
o Providing a mobile biometric enrolment facility for those unable to
attend a PEO, PO or IPS office (eg due to il ness or incapacity). This
Ministerial commitment ensures that UKBA does not discriminate. It
adds a small amount of cost onto the overall solution and provides a
platform for UKBA to charge for a personal enrolment service in the
future.
o The secure despatch of cards to customers by courier is included. The
original business case assumed despatch would be by post. However
Ministers considered this to be too insecure and a courier service
organised by DVLA is now provided to ensure cards are not lost. Each
card despatch costs £3.52 and so is a significant and variable
additional cost. It could be phased out over time once the scheme
has bedded in.
•
Reduction in verification costs
Costs to verify each applicant’s biometrics who have been enrolled before were
included as a separate item in the last business case. However it was decided to
re-enrol every applicant and to take their biometrics anew even if they have
previously applied for and received leave to remain. Therefore these cost are
included under the ‘record biometrics’ capability.
•
Reduction in Card Collection Costs
It had previously been assumed that some cards would be collected from PEO
offices. However with the use of courier delivery through for all card despatches
these costs are no longer necessary.
Therefore the project remains within the overall funding envelope approved by GIB in
December 2007 of £172 mil ion and the updated estimate of £167 mil ion provided in
September 2008, although there have been some significant changes in individual
cost items which broadly net each other off.
• UKBA wil only contribute towards to the operating costs of the facilities.
• The benefits of optimising the DVLA’s economies of scale offered a saving
to UKBA in excess of 50% on that originally budgeted for and positioned
the UKBA in a stronger position than if procuring the perceived ‘smal
quantity’ independently.
• The procurement route used by the DVLA was robust and Home Office
LAB determined there was only a low risk of challenge owing to the limited
level of market engagement, low quantities and low market expectations.
Front Office
An options analysis was undertaken to assess the best mechanisms for the
provision of front office services.
The main options assessed were:
• Provision of offices within the Public Enquiry Office (PEO) capability within
the UKBA estate;
• Use of Identity and Passport Service (IPS) – Interview Office Network
(ION) facilities;
• Use of Driver and Vehicle Licensing Agency (DVLA) enrolment booths in
Post Offices;
• External Procurement through OJEU.
Two options have been taken forward to implementation:
• Use of UKBA PEOs for the case working and premium services. However,
the PEO network capacity of 170,000 enrolments per year is insufficient to
cope with the expected growth in biometric enrolments which are predicted
to rise to over 770,000 a year by 2011/12. They were also considered not
to provide a sufficiently wide geographical coverage, being weighted
towards the south east of the UK.
• The IPS Interview Office Network (ION) was assessed to have a secure
network and cleared staff and was selected to provide additional capacity.
Some 17 enrolment booths have been implemented in five locations.
The Post Office was assessed to have the best geographical coverage and
already provides other services for government operations involving fee handling
and application checking capabilities such as passport applications, tax discs and
driving licences. It was also working with DVLA on the implementation of
enrolment booths to support drivers’ licence data and biometric capture at 750
offices. Accordingly negotiations commenced with DVLA and Post Office Ltd
regarding this possibility, this is further addressed under procurement strategy.
External procurement was estimated to take 12-18 months which was considered
too long a delay to meet predicted ICFN volumetrics.
Fingerprint & Image Storage
The IAFS system which serves to store biometric data, check fingerprints against
the asylum seekers database and initiate IDENT1 checks has a planned extension
to December 2011. As the contract was signed in 2000 it would be very difficult to
justify any further extensions. Currently it is planned to novate the agreement to
IBM who have been competitively procured by IPS to provide the National Identity
Assurance Service (NIAS). IBM wil replace the IAFS system as part of the NIAS
build. The ICFN programme wil engage with IPS to ensure an efficient transition
and protect the ICFN functionality.
PKISS
PKISS services are currently subject to service enhancements and the correction
of a serious card production issue (PKISS release 2.1) and a change in the service
management of PKISS from IPS to Thales from IPS requiring ongoing
engagement from the ICFN programme to ensure that the service continues to
meet ICFN requirements and remain affordable. It is also understood that PKISS
provision wil move from the current contractual arrangement to an IPS
competitively framework also won by PKISS, this contractual change wil align with
the replacement of the current PKISS systems. Again close ICFN Programme
involvement wil be required.
Card Production Services
Card production services are currently provided by DVLA using their delivery
partner IBM with its sub-contractors. The IBM contract is due to expire in 2012 the
ICFN programme will need to engage with DVLA and IPS in good time to explore
replacement options.
Front Office
The strategic solution for front office services will be met by UKBA PEO capacity
plus, providing the greatest volume of enrolments, the IPS front office solution
planned for delivery around 2011/12. The IPS are stil developing their front office
strategy and supporting procurement and commercial approach, the ICFN
programme team are engaged with IPS in support of this. It is anticipated that this
service will be supplemented by a mobile enrolment capability. The mobile
enrolment capability is in pilot at present, the long term business requirements and
associated procurement strategy are yet to be developed.
Prior to the implementation of the strategic front end solution the demand for
enrolment is met by the established PEOs and ION offices, it is planned that the
shortfall in their capacity as the ‘student surge’ commences in September and new
categories of foreign nationals are brought into the ICFN scheme, wil be met by
the use of a new enrolment service based in Post Offices.
The extent of use of the Post Office capacity has been substantially reduced
following concerns over compliance with the procurement regulations. It was
originally planned that a pilot of around 25 offices would be undertaken fol owed by a
roll out to some 750 offices. This would give the capacity necessary to meet the
predicted volumetrics and an excel ent geographical coverage. The intention was to
use a contract let by DVLA for the provision of enrolment booths and the associated
services to support drivers’ licence registration and renewal. This also
had the benefit to UKBA that most of the implementation costs would be covered
by DVLA. However, DVLA had not advertised their requirement but acted single
tender with the Post Office which occasioned concern over compliance with the
procurement regulations.
The procurement regulations require, with a few exemptions such as national
security, that al requirements with an aggregate value over £90,000 must be
advertised in the Official Journal of the EU (OJEU). Assuming that the Post Office
undertook half the predicted volumetric at the proposed rate of £13.50 per enrolment
this would represent well over £5m per year (the enrolment cost shared between the
applicant and UKBA1). The justification that DVLA used for their award, and which
UKBA had relied upon, was that their requirement falls into a class of goods and
services, ‘Part B’, that are exempted from the need to advertise in the OJEU. Part B
goods and services are generally those which EU considered would largely be of
interest only to bidders located in the Member State where the contract was to be
performed. Part B also includes a catch all group called ‘other services’ and it is this
upon which DVLA rely. However further consideration of the ICFN requirement
questioned whether the services were not in fact covered within part A (e.g. IT goods
and services, fingerprint scanners, digital cameras and photographic services and
registration). An additional argument in support of the unadvertised use of the Post
Office, that it is essentially another government body and hence part of the indivisible
Crown body was dismissed in the light of the Teckel decision2.
IPS have arrived at similar conclusions and have engaged widely with the potential
enrolment system and service providers (equipment suppliers such as Steria and
Cogent, potential service providers such as the Post Office, banks, supermarket and
pharmacy chains). While IPS are stil developing their procurement and commercial
approaches, an open competition through the OJEU is likely.
Assessing the legal risks3 against the potential benefits it was determined that,
subject to technical and commercial agreement with DVLA and the Post Office, the
pilot should continue, but that the roll out to the 750 should not continue. This
supports the student surge but does not address the anticipated growth in volumetrics
prior to the strategic front office provision. This also avoids the difficulty in
demonstrating VFM without competition.
The ICFN programme team are considering options for making good the capacity
shortfall occasioned by the reduction in Post Office use. Options include extending
the PEO usage or coverage, extending ION provision and greater use of the
mobile enrolment capability.
Call Handling
The current IPS originated agreement with Teleperformance expires prior to the
provision of the strategic front office solution. The ICFN Programme Team wil review
its ongoing cal handling requirements and the use of Teleperformance (no formal
contract has been concluded, there are issues around disputed invoices and
applicable service levels). Additionally because the ICFN service is stil being
1 which also adds the complication that this is both the award of a concession and a procurement.
2 This case addressed the issue of whether a public body could make an award to another public body to provide
services without openly advertising those requirements. Essentially the ‘Teckel Test’ stipulates that it is not
necessary to advertise provided that the selected body is controlled by the awarding authority in a manner “similar to
that which it exercises over its own departments” (structural control), and at the same time carried out the essential
part of its activities “with the controlling authority” (economic dependency).
3 LAB have expressed the opinion that while there are legal arguments in defence of single tender action these are
not strong and there is a risk of a challenge, albeit such a challenge would be most likely to be made to DVLA.
On-Line Booking
The cost and quality issues with cal handling led the programme to consider the
provision of an on-line booking alternative. The cost benefit from avoided
Teleperformance call costs and lost premium enrolment fees is estimated at around
£5m per year (assuming 200k on-line bookings and 25% premium enrolments lost)1.
Scoping and costing work with AtosOrigin under the IPIDS agreement indicated a
delivery time around 18 months and a delivery cost near £2m which was considered
excessive. Consequently EzGov were selected as a potential delivery partner. EzGov
specialise in on-line services on behalf of the Public sector, in the UK they provide
the on-line self assessment for tax and PAYE services and have worked with UKBA
on aspects of the ICW programme. Contractual arrangements were put in place
under the terms of the HMRC ‘Sprint’ framework agreement through which EzGov
sub-contract to the Sprint supplier, SCC. The agreement with runs up to 2 ½ years
for a total cost (delivery and operating) of £1.2m with delivery planned for October
2009. This includes a £60k contingency premium which reverts to UKBA if not used.
Mobile Enrolment Pilot
The mobile enrolment pilot systems have been delivered and trialling and
deployment is commencing. The further procurement and commercial strategy wil be
derived from ICFN business requirements once developed.
External Resources
The programme is actively replacing its external resource. The Tribal agreement,
which provides a number of key resources, is anticipated to expire within six months.
It is essential to the ongoing success of the ICFN programme that there is effective
skil s transfer. If internal resource of the necessary calibre cannot be acquired it may
be necessary to look for alternative consultancy and contractor frameworks.
Training
The programme training requirements wil continue to be provided on a ‘train the
trainer’ basis calling down specialist training from the ICFN element suppliers or
external specialists as appropriate.
Miscellaneous
Other ongoing requirements wil be assessed as identified. Although outside the
scope of this case it is noted that 12 mobile biometric card readers have been
procured from Bundesdruckerei for piloting. Two devices wil be supplied to IPS for
their assessment, liaison with the SECUREID programme is proposed.
4.1 Commercial
Risks
This section identifies key commercial risks around the current and ongoing provision
of the ICFN services. Commercial risks are categorised as:
Implementation Backlog: As noted at the outset, the ICFN service was
implemented very rapidly between Treasury approval in March 2008 and its
1 On-Line Booking Business Case
• ‘go-live’ in November 2008 by using existing dedicated UKBA resources and
assets supplemented by a wide range of existing commercial arrangements.
It should also be noted that implementation was achieved by the programme
team members’ ‘heroic endeavours’ to meet their deadlines. This has resulted
in several risks where it was not possible to conclude the supporting
commercial arrangements:
o Significant work, particularly on the core CID/ICFN systems and
services, was undertaken on a time and materials basis, making cost
control and VFM establishment difficult. For example there are stil
outstanding disputes around the CID/ICFN invoices.
o It was not possible to conclude al Memorandum of Understanding and
agreements. For example the Teleperformance agreement is not
completed or signed and there are disputes around invoices, the MoU
for PKISS services is stil to be agreed and no payments have yet
been made to IPS. Annex F.3 provides details of agreement and MoU
status.
The ICFN wil require to deploy commercial and programme resource to
finalise outstanding commercial arrangements.
•
Insufficient Commercial Management: The ICFN has no dedicated
commercial management. Annex F.2 indicates the support, provided largely
from Home Office Commercial Directorate, over the past year. This is now
reduced to one Commercial Directorate G6. Given that the business case
indicates a potential spend of £260m, the backlog of MoU and contract
finalisation, current initiatives such as on-line booking and the significant
service and commercial changes over the period until the establishment of
the strategic solution, this is inadequate. Commercial Directorate are in
discussions with the programme regarding commercial resourcing.
•
Legal Challenge under Procurement Regulations: The issues around the
single tender use of the Post Office have been considered at length. Limiting
the Post Office provision to a pilot is considered to minimise the risk of
successful challenge. There are also risks around procurements post pilot
where the pilot (Post Office and Bundesdruckerei) provider may be seen to
have an unfair advantage. The programme has engaged with IPS around
ensuring that any strategic front end procurements minimize the risk of
challenge. There are provisions in the Bundesdruckerei contract limiting their
use of any expertise gained through the pilot.
•
Expiry of the Biometric Capture Device Agreements: As noted above, if
International Group do not replace these agreements a new route to acquire
the biometric capture equipment could be done through OGC framework
agreements with general ICT resellers such as Computacenter or SCC.
AtosOrigin might agree to provide the equipment directly under the IPIDS
agreement; direct purchases would be possible for a limited period subject to
the EC threshold (currently £90k) or the ICFN programme could undertake its
own procurement if there were benefits to a bespoke service
Pre Strategic Front Office Capacity Shortfall: The issues around the lack of
capacity given the decision not to proceed beyond the Post Office pilot have been
rehearsed above. Similarly it is noted that the Teleperformance call handling and
SCC/EzGov on-line booking agreements expire before the strategic front end
