Minutes of the 79th Board Meeting

Minutes
Title of meeting	79^th GLAA Board Meeting
Date	17/11/2022	Time	10:30 – 15:30
Venue	Apex Court
Chair	Julia Mulligan	Secretary	Megan Bethell
Attendees In attendance Home Office attendees Observers	Julia Mulligan (JM) GLAA Board Chair Deep Sagar (DAS) GLAA Board Member (present to item 10c) Dr David Snowball (DJS) GLAA Board Member Pippa Greenslade (PG) GLAA Board Member Suzanne McCarthy (SM) GLAA Board Member Keith Rosser (KR) Board Member Phil Cain (PHC) Board Member Elysia McCaffrey (EM) CEO Justin Rumball (JJR) Head of Finance Samantha Ireland (SI) Head of Governance Megan Bethell Governance Officer Nicola Ray (NR) Head of Regulation (item 10 only) Emma Coxon (EC) Head of People and Change (item 10 only) Ian Waterfield (IW) Head of Enforcement (items 10, 11 only) Hannah Pooley (HP) Head Modern Slavery Unit, Home Office Simon Hookins (SH) Modern Slavery Policy Lead, Home Office Anita Bailey (AB) Home Office Sponsorship Unit, Khalil Souki Cap Gemini Lucy Batchelor Senior Consultant, Cap Gemini Charlotte Bogod Senior Consultant, Cap Gemini

Introductions

· JM welcomed everyone and invited introductions.

Apologies

· None.

Minutes of the previous meeting held on 18^th July 2022

· The minutes of the previous meeting, 18^th July 2022, were agreed as an accurate record.

Declarations of interest

· SM declared that she has been made a Panel member of the Labour Party Independent Complaints Panel.

Action Points

Action points closed – as agreed on the Board Action Points Paper:

BM74(4), BM76(11), BM77(1), BM77(4), BM78(1), BM78(2), BM78(3), BM78(4), BM78(5), BM78(6), BM78(7), BM78(8), BM78(9), BM78(10), BM78(11).

Comments:

· SM asked what the outcome on action BM74(4) was.

· JM stated the TOM project would hopefully resolve this action.

· EM and PG agreed there was an accounting piece of work to do that is normal cost centre management, which culturally is the way to move. But they were not able to do this yet.

· SM asked if actions were to be closed in between meetings, more explanation on the outcome is needed.

Board Development, Julia Mulligan

· JM stated her aim for shorter future Board meetings to allow time in the afternoon on specific areas like deep dives. DAS said he did not mind shorter meetings, but they had to be able to include all relevant important subjects.

· To improve timeliness on updates, the Chair will agree actions with the secretariat after board meetings.

· A Board Development Day is planned for March and the date will be confirmed.

· DAS asked for more scrutiny on enforcement and intelligence at the next Board. He said that he considered scrutiny by the board of intelligence, investigations and enforcement had not taken place for a year and had not been put on the agenda.

· JM stated the deep dive scheduled for 6 December and agenda item on Business progress report will give further scrutiny for objective 1.

· DAS said the update provided at the previous Board of 386 investigations did not reconcile with the 147 number published in the Partnership newsletter and no reason for the difference was available.

· PHC suggested there is a conflict within some of the systems due to the need for administrative support to close old investigation reports. An example of why the Cap Gemini work is important.

· JM asked Cap Gemini to give an overview of their previous work to provide assurance for the Board.

· PHC suggested there might be a capability gap in the organisation and thought should be given on where investment may be needed.

· JM wants fewer ‘updates’ at Board meetings and for colleagues to report on clear action plans that deal with specific issues.

· JM to review the 2023-24 Board Workplan considering the two extra dates.

· SM asked for sub-committee meetings to be considered in the 23-24 Board meeting plan.

· JM asked for agreement on the attendance of Board meetings; LT members to only present specific items as requested. Except for Dan Scully (COO), Sam Ireland (Head of Governance/Intel) and Justin Rumball (Head of Finance) due to their strategic roles.

· EM presented the paper ‘Strategy and TOM timeline and request for Board engagement’ and asked the Board to agree key consultation dates for the TOM and the GLAA Strategy approval.

· SM asked the Home Office (HO) for assurance on the strategy sign off.

· AB requested for the HO to be consulted during the strategy development to ensure a smooth sign off.

· JM and EM will meet with the new minister in early December and will share the vision for the organisation.

· PG asked if the organisation needs to be ready to implement the strategy when it is launched in April.

· JM stated the strategy should be agreed by the Board in February to ensure we are working towards an April launch. JM also suggested a need for internal work to ensure the GLAA is ready for the implementation of the TOM recommendations.

Action

· BM79(1) JM to review the Board workplan for 2023-24, considering the two sub-committees, and circulate to Board Members.

· BM79(2) JM and EM to sequence when Board members are sighted on the plan to implement the TOM project.

Decision

1. The Board agreed future Board attendance.

2. The Board agreed the questions outlined on the Strategy and TOM timeline and request for Board engagement paper.

Home Office, Update

[Official and Sensitive information has been redacted from this section]

CEO update, Elysia McCaffrey

· EM outlined the significant change projects underway that interconnect: TOM project, Phil Cain’s intel review, Phoenix Connect IT project and the new strategy. EM stated it is a lot of change for a small organisation.

· EM thanked Sam Ireland for her work to support this change.

· SM noted that the organisation has struggled with change and queried how the approach will be more successful in the future.

· EM explained that the TOM project is transparent and has fully consulted with every team. All leaders are undertaking a change management course.

· SM asked when people’s views are not taken forward how will it be managed?

· EM explained that staff have been advised in advance that not all suggestions will be taken up. EM is aware people have concerns, which is why transparency on decisions is so important.

· KS explained that Cap Gemini’s work will provide a rationale for recommendations and implications for implementation

· PHC stated the Board should actively support LT members driving the TOM project forward.

· PG noted the CEO’s current workload and associated risks and responsibilities

· EM shared PCS members have voted in favour of strike action, which potentially covers around half of the GLAA workforce. We are waiting for confirmation of when the strike will be and are working on contingency planning.

· AB suggested the HO are looking at doing a tabletop exercise to see how they need to lean into this.

· EM shared that the GLAA won an award with the Skills and Education Group for collaboration on the Level 1 Award.

· DJS asked if there was increased journalist interest into the GLAA.

· EM shared there has been an increased interest around the Seasonal Workers Scheme.

· JM suggested that there has been an increase in media interest when MS moved into the immigration portfolio.

Action

· BM79(3) For the Board to be given a substantive report on the progress of the TOM project at the next Board meeting.

Strategy Development – progress and plan

· Covered under the Chair’s update.

10.

Business Plan 2022-23 – progress report, Leadership Team

a) Objective One, Sam Ireland and Ian Waterfield

· SI outlined that tasking and coordination (T&C) will drive the implementation of the control strategy (CS).

· EM explained that the website improvement work is likely to be delayed until the next financial year and asked the Board if they were content for this.

· JM invited PHC to give an overview of his Intel review.

· PHC gave an overview, saying that the intel team were triaging information and making decisions inconsistently. The CS was not at the forefront of decision making. Part of the review is to embed a solid intelligence function in the GLAA, and change behaviours so the CS drives priorities through T&C. This would reduce silos.

· PG asked how comfortable SI and IW are in creating behaviour change and when will the Board see the impacts on performance.

· IW stated work has already started on this.

· PG asked how it will impact job descriptions (JDs).

· PHC responded that JDs are not changing, but objectives will.

· DAS asked how many pieces of intelligence have been dealt with and if information on their sources, subjects and outcomes could be provided.

· SI responded this level of data is not available, but work is ongoing to understand what is needed at each level e.g., Board, Leadership Team, and team level. SI stated that a performance analyst is still not in place.

· DAS queried how key deliverables (KDs) are assessed without knowing the numbers.

· SI replied that work is on-going, but it cannot be progressed until resource is in place. The business plan has performance measures that are reported to the Board and supporting KPI’s are collected and used. She said greens were based on a new performance analyst having been recruited.

· IW said that the Enforcement Deep dive should provide some of the detail being sought by DAS

· DAS stated his disappointment at greens being assessed without knowledge of achievement.

· PG is expecting clear data in the four areas of the CS.

· PHC shared he is working with intelligence on KPIs linked to an accountability framework. But the organisation does not have a performance analyst and the team is doing their best.

· KR found some qualitative KDs difficult to assess and asked how we know what success is. KR said he is content for the website risk to be red (unless there is financial difficulty) to ensure the website reflects the strategy and TOM.

· JM requested that the Board have milestones against KDs.

· IW stated that enforcement activities and tasking are at similar levels to last year, but the GLAA is leading on more operations compared to working in partnership. The teams are focused on more disruption outcomes such as Slavery and Trafficking Risk Orders (STROs). The GLAA has been invited to offer a master class on STROs to other law enforcement bodies. However, there are legal costs associated with STROs for which there is no budget allocated.

· IW shared work is being undertaken to tidy data, which will be relayed to the Government Internal Audit Agency (GIAA) to support the annual opinion.

· IW said work is ongoing to improve victim support and shared the Victim Navigator Evaluation data.

· DJS asked for clarification on when the tasking group meets to discuss the CS.

· IW said there is business as usual work, and the CS is there to help prioritise if there’s a clash of resources.

· DJS asked what is business as usual?

· By way of example, IW said police force requests for support outside control strategy priority areas would be refused.

· PHC stated the CS should be shared with partners for synergy and understanding.

· PG said it is not just priorities for the enforcement team and that compliance needs to be considered when it comes to the CS.

· DAS said IW’s report was useful but suggested it be in written form in future and include total investigations and main breakdowns by region, subject, industry, outcomes of investigations and enforcement.

· JM suggested that clear departmental action plans would aid reporting on the delivery of the business plan.

· EM said there needs to be more work to quantify success.

· JM asked for proxy measures to be considered, that would help the Board better understand business plan delivery.

Decision

3. The Board is content to progress the new website in the next financial year.

b) Objective Two, Nicola Ray

· NR shared the Gold Group meets monthly to review progress against targets, barriers, and management issues. But a challenge is moving resources around the organisation to process work.

· NR stated work on fees takes time from business as usual activities, but they are focused on improving the process.

· Regulation will have a difficult start to the new year due to resource changes so is trying to make decisions to mitigate this now.

· One thematic inspection recovered £50k in holiday pay for workers.

· EM explained the pressure on deliverables and asked if the Board would be content for fewer enforcement investigations, in order to meet regulation’s demands, by allocating some of their staff to Licensing/Regulation temporarily.

· SM said there was no assessment on the impact of this request and did not agree with the suggestion to change the virtual AI target to 65%.

· PHC questioned whether reducing the measure could lead to a risk of averse practices.

· NR stated that is was not possible to predict the demand of business applying for a licence, and it is important that new officers are trained by undertaking physical inspections.

· PHC asked what the benefit would be of changing the target.

· NR shared it would give the Board a better understanding.

· JM said this suggested that we did not understand demand when the goal was set.

· DAS said it should not be the job of the Board but the CEO on allocating staff temporarily within the budgeted structure ..

· JM questioned if the purpose of the Gold Group was to still to address performance issues and to reduce the black risk.

· EM said that she chairs the Gold Group and that a lack of benchmarking is a major issue as is knowing how long inspections should take.

· JM asked how this work feeds into the compliance strategy and if the Board are assured on the delivery of the compliance strategy

· NR said high-risk business are dealt with through T&C.

· DJS asked for clarification on what constitutes a high-risk business.

· NR replied that a high-risk business is one that has potentially breached the critical standards or has a serious allegation concerning being fit and proper.

Decision

The Board did not agree to review the performance targets in relation to Objective two.

c) Objective Three, Emma Coxon

· EC stated overall KDs are on track and key processes such as PDRs and one-to-one meetings are taking place, but further work to embed them is required.

· EC shared that KDs on learning and development are off track, but now an L&D officer is in post they will hopefully be achieved.

· EC highlighted the People and Change team has been without two members and hopes by January to be back to strength.

· PG asked if EC was starting to see cultural change being discussed.

· EC shared that previously unchallenged problematic behaviour is beginning to be challenged, resulting in more Employment Relations cases.

· PHC asked about the biggest cultural difficulty.

· EC responded that the way leadership deals with difficult issues is important, but there is a positive attitude overall.

· PHC shared that this suggests a need to have a critical mass that is pulling in the same direction.

· PG suggested ER cases escalate quickly and there is a need to build a culture where people can give constructive feedback.

d) Objective Four, Justin Rumball and Elysia McCaffrey

· KS presented the TOM project plan.

· LB shared they are halfway through the consultation (‘as is’) phase and everyone in the organisation will have an opportunity to engage.

· LB informed that Board that some of the key themes include a lack of focus, mission creep, poor accountability, IT issues, leadership challenges including a lack of quick decision making and cohesion, and people protecting their own interests.

· LB shared new ways of working will be developed in a ‘sprint’ and that demand, performance and leadership will be the next focus.

· KS said that before they had started, they hadn’t fully appreciated the requirement of the demand analysis.

· PHC said the demand analysis should not be based on the work that is being undertaken now, but what the GLAA should be doing.

· JM agreed and said that we need to be future proofing the GLAA.

· PG suggested that as we are moving at pace, Board members might be better directed.

Action

· BM79(5) To report to the Board the action plan for delivering the business plan, including specific milestones, quantify key deliverables and proxy measures for progress

· BM79(6) To liaise with the Board on how they can feed into the TOM project.

· BM79(7) For the People and Culture Committee to link into the TOM project on the organisation’s cultural change work. To be reported as a paper to the next Board (this could also be linked to the TOM presentation at the next Board meeting).

11.

Control Strategy (CS)

· DDU stated the Threat Assessment is informed by pooled analytical products and it is important officers are aware of intelligence gaps so they can help fill these gaps. The CS can be amended based on horizon scanning.

· JM stated the Board’s purpose is to understand how the CS shapes the work of the organisation in line with its strategy.

· DDU highlighted shellfish gathering is a priority area despite the reduction in referrals.

· SI highlighted that shellfish gathering has been on the CS for a long time but as the CS has not been fully utilised previously, this is a chance to properly assess shellfish and the impact of our work.

· DDU shared the risk for shellfish gathering is likely to increase due to the EU exit.

· EM explained that the purpose of the item was to explain the process of the CS to the Board so it can understand how resources will be prioritised.

· SI discussed the MoRiLE scoring process, which allows analysts to understand the highest threats to help direct resources.

· PG asked how the CS aligns to organisation-wide resources.

· PHC reiterated that a purpose of a CS is to help remove silo working. For example, if NR is feeling resource constraints under a priority area, then the Chief Operating Officer has the power to redirect resources to support this priority work.

· Board agreed they were content with the MoRiLE approach.

· JM queried why the care sector is included in the CS

· DDU said it was due to the increase in allegations in this sector.

· KR stated that regulation seems second best in the CS.

· DDU highlighted that there remain data quality issues.

· JM stated the organisation needs to have a CS and it is an approach law enforcement partners understand.

· KS gave his observations on the importance of having a tool in place that helps the organisation prioritise their work.

· SI stated three of the four CS areas interact with the regulated sector.

· SH shared that he was encouraged by the sectors on the CS and that the care sector was understood to be an issue

· DJS asked if the CS ensures we have the biggest impact on reducing labour exploitation.

· PHC responded by saying yes as it reduces the risk of highest harm.

· DJS asked if there was an opportunity to do an after action review on the care sector and asked why wasn’t construction on the CS?

· DDU said there has been a drop off in reporting allegations in the construction sector.

· PHC highlighted the importance of MoRiLE scoring to enable us to review the impact of our work. The finance team have been asked to apply a cost code to each priority area to allow evaluation of expenditure on each priority.

· SI stated that the CS is a ‘living’ document, which will be reviewed.

· SH said that having a cost code linked to the priority area of the Seasonal Workers Scheme will be helpful when discussing issues on the SWS.

· PG asked who will be championing the new ways of working.

· SI stated this is the COO’s responsibility to hold the organisation to account.

· PG asked how the organisation is going to manage this change.

· SI responded that they are aware of this leadership challenge.

· JM said the board will want to see how the CS is embedded and how it impacts the work of the organisation. Particularly at a time where the organisation is in a state of flux.

· PG said we should be proud of this change, but we need to be confident.

· PHC says there needs to be a clear plan for launching the CS and that IW is working on the threat reduction plan template. The group working on this is meeting on the 6 December.

· SM suggested that the CS needs to be cross-referenced with the strategic risk register.

Action

· BM79(8) Board members to receive the review on the Albanian risk profile.

· BM79(9) The Board to receive a progress report on how the launch of the Control Strategy and Tasking & Coordination Group has progressed with a particular focus on the impact of this work.

· BM79(10) The Control Strategy to be elevated onto the strategic risk register.

Decision

4. The Board agreed they are content with the approach of the Control Strategy.

12.

Finance, Justin Rumball

[Official and Sensitive information has been redacted from this section]

· JJR raised a risk around spending the accrual.

· JJR has started high level scenario planning and there are key variables to consider including inflation and potential reductions in budget. This is to provide a sense of medium-term planning notwithstanding that we have not had a multiyear agreement.

· JJR asked to be involved in the strategic assessment early to allow for resource planning.

· JJR raised the uncertainty around potential reductions in funding and the issue that the resource model was based on the historic GLA rather than the GLAA. The work on the TOM and the intel work will hopefully support this work.

· JM shared that TOM provides an opportunity for us to develop a strategic plan.

· AB stated they need more detail on capital spend for period 8, as they moved into the next financial year. The HO is hoping to be able to provide a multiyear budget settlement and will be expecting a capital reduction.

· RDEL – it was noted that a ‘flat cash’ settlement will be a real term cut.

· AB suggested the GLAA should not forget the public body review, which will require more than a 5% cut. AB confirmed that anything cut before the Public Body Review would be included in the cost cutting required.

Action

· BM79(11) For the Board to receive a paper on strategic financial planning that incorporates work from the TOM project.

13.

Risk Management Report, Sam Ireland

· SI raised the risk of data retention and destruction and that JJR has been in touch with a data base administrator to help with this. SI stated it has been agreed at Programme Board that anything pre 2016 can be bulk deleted in line with MOPI rules.

· SI shared that the Data Protection Impact Assessment is a requirement but highlighted resource pressures in IT has been challenging.

· SI raised the risk of not having in house subject matter experts, especially as some people have left who were single points of failure. SI is expecting this to be resolved with a new IT system.

· PHC asked how legacy data will be managed.

· EM stated the organisation is going to buy in some database admin support to review and clean legacy data before data is moved onto a new IT system.

· SI stated that an Information Management Strategy is needed, the risk appetite needs to be set which then creates an assessment framework.

· It was reported that some officers cannot currently be deployed as their personal safety training is not up to date.

· PHC suggested that West Yorkshire Police offers ‘Use of Force’ training which may be suitable.

· KR suggested the issue of personal safety training is not for the Board as it is not strategic.

· JM recognised that capacity and capability to influence change has been discussed at length in today’s meeting and should be picked up by the Chair and the CEO.

Action

· BM79(13) JM and EM to discuss the risk implications of big change at their next one-to-one.

14.

Governance, Sam Ireland

· SI explained there has been considerable effort on internal reviews, but only two will be delivered this year.

· The outcome of the GIAA audit on Business Plan delivery is likely to be limited.

· SI shared that other demands on her time have meant her focus on governance has shifted.

· SI said that the capacity of the governance team has been impacted as it is currently without a performance analyst or secretariat – although a new secretariat has been recruited.

· SI suggested she present a governance reset plan at the next Board.

· PG raised concerns on turnover, which has a significant impact on workforce, particularly in a small organisation. PG also raised a concern about the ability to fill jobs.

· SI shared there is no resilience in key areas e.g., performance analyst.

· JM added that single points of failure have been identified and are being looked at as part of the TOM project.

Action

· BM79(14) SI to provide the Board with information on the work of the governance team, along with plans for future priorities.

15.

Any other business

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