CAPCA payment data anomalies with Barclaycard

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Dear Cambridgeshire and Peterborough Combined Authority,

Introduction
Each month Cambridgeshire & Peterborough Combined Authority (CAPCA) publishes supplier payment data in compliance with the Transparency Code.
One regular payee is Barclaycard – used as a purchasing card for smaller payments – such as travel, hotels, and stationery. The details of individual spending on this/these cards are shown in a separate purchasing card file each month. One record per month settlement payments are made to Barclaycard. Assuming the account is paid in full each month and no interest is charged, the Barclaycard payments should correspond to what was charged on the purchasing card(s) in the preceding month. Thus January’s purchase card details should add up to the total paid to Barclaycard the following month. Naturally small differences are expected between the two corresponding values if the Barclaycard month end date is not at the calendar month end. But such timing differences should cancel out over time.

Findings
After analysing the published data up to November 2018 the following issues were noted:
1) No payment to Barclaycard appears in the July 2018 Transparency Report
2) No purchasing card file for September 2018 is published on the documents tab on CAPCA’s website (http://cambridgeshirepeterborough-ca.gov...)
3) In addition to the above, differences totalling £3,177.60 exist between Barclaycard payments and the prior months’ corresponding purchasing card details. The overall gap is growing and cannot be explained by timing differences. It would appear that some purchasing card transactions may be omitted from the published files.

Questions
Incomplete published data is concerning. Even if only one or two omissions are spotted, they may indicate many more omissions that the public cannot detect.

Q1 Why does no Barclaycard payment appear in the July 2018 Transparency Report? Will it be published without delay and the amendment noted on the website, as required under the Transparency Code so that it does not go undetected by those monitoring the data?

Q2: Have other payments been removed from the Transparency Report? And if so, why? And will they be published without delay with an explanation?

Q3: Why was no purchasing card file published for September 2018? Will it be published without delay?

Q4: What explains the growing gap between Barclaycard records and the corresponding purchasing card details? What were the missing transactions? Will they be published without delay as a standalone file with an explanation on the website, so that the public monitoring payments can update their records easily?

Q5: If any Transparency Report payments or purchasing card details are removed prior to publication, what are the criteria for removing such data, what is the procedure, and how can the public be reassured that the Transparency Code data are not regularly censored on an ad hoc basis to hide dubious or inappropriate expenditure?

Yours faithfully,

Andrew Rowson

Contact Us, Cambridgeshire and Peterborough Combined Authority

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Dear Mr Rowson

 

Thank you for your email. Your request will be dealt with in line with the
Freedom of Information Act and its regulations. In accordance with the
Act, the Combined Authority aims to respond to all requests within 20
working days, in this instance by 25 February 2019.

 

If we require further information, clarification or a fee in order to
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Please quote the reference CA57 in all future correspondence concerning
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Yours sincerely

 

 

[1]Sue H Email Footer

 

 

 

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Susan Hall, Cambridgeshire and Peterborough Combined Authority

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Dear Mr Rowson

 

Please find attached the response to Freedom of Information request CA57.

 

Regards

 

 

 

Dear Susan Hall,

Thank you for your response dated 13th February to FOI ref CA57. I am requesting an internal review because in several places the details are incorrect or do not make sense. I shall deal with the problematic questions in order.
Q1. Thank you for acknowledging this. However, the authority has not made it clear to other data users that amendments have been made. One has to go into the July file itself to see that there has been an amendment. Users cannot be expected to open up every historical file each month to check for possible amendments. The best practice solution, which was included in the original guidance for practitioners is to add a new file whenever amendments are made (e.g. “July 2018 Version 2”) with the amendments highlighted. That way it is immediately apparent on the webpage itself if and where there are amendments.

Q2. The answer to this question does not make sense. If a payment has been made, it should already have sufficient details connected with it to feature on the Transparency Report. If it does not, then it sounds as though it should not have been paid. Nevertheless, the guidance in the Transparency Code itself (Para 23) instructs that payments should be published even if there are minor mistakes or omissions: "While errors may occur, the publication of information should not be unduly delayed to rectify mistakes".

The acknowledgement that omissions from earlier months are included in the December data does not make sense because if they had been paid in earlier months, those payments would have payment dates from those earlier months, and all the payments in the December 2018 file have December 2018 payment dates. Please can the authority clarify the number and value of historic payments that have been omitted, and confirm that they will be published in future amended payment files, as per the guidance in paragraph 24 of the Transparency Code.
A simple analysis of the published payments to date does suggest that there may still be quite a number of missing payments, especially in the early months.

Q5. The answer to this question makes no sense either. The first part conflicts with the responses given to questions 1 and 2 above, which indicate that historical payments were permanently excluded, at least until this FOI request. If publication of earlier omitted payments was simply delayed until a later month, then they would have shown up in a later month’s data file with the actual (earlier) payment date. But, apart from the first September 2017 file (which contained three payments from earlier months), there are no such payments with prior month payment dates. The delay explanation therefore does not appear to be correct. Please clarify whether or not there are still payments that were made since the beginning of CAPCA but which still do not feature in the published payment files. So far only the one Barclaycard payment from July 2018, and the purchasing card file from September 2018 have been admitted to.

The reference to GDPR rules also makes no sense. There is not a single redacted beneficiary name in any of the transparency payments published to date. If any published payment risks identifying an individual - either in the beneficiary name field or in any of the category fields - then the solution is to replace the identifying text with words like “redacted personal information”. The only category field that might conceivably identify an individual is the “purpose of expenditure” field, and here too not a single entry to date has needed redacting. Please explain therefore why reference to GDPR was made in the response.

One final point: the number of payments CAPCA publishes each month is minimal – ranging from zero to 65. There is no possible justification for delaying publication of any single payment or of the entire month’s file beyond the 30-day deadline required under the Transparency Code.

Yours sincerely,

Andrew Rowson

Contact Us, Cambridgeshire and Peterborough Combined Authority

2 Attachments

Dear Mr Rowson

 

Please find attached the response to your review.

 

Regards