COVID-19 pre-visit letter and vulnerability identification phase

All enforcement visits were suspended by Excel on 23 March 2020. All other activity, such as issuing Notices of Enforcement, sending reminder letters and making outbound calls was greatly reduced. CIVEA members have agreed and fully accept that to simply restart enforcement visits once the Government eases restrictions would not be acceptable.

Therefore, prior to recommencing any visits to customers, all CIVEA members will implement a pre-visit letter and vulnerability identification phase. This will involve issuing a light touch reconnection letter or arrangement default letter based on wording provided by CIVEA, plus follow up communication e.g. by text, email or telephone where possible.

The letters seek to engage consistently with customers to understand how they have been affected by the COVID-19 crisis and respond as appropriate. Each case will be offered support as applicable, including signposting to the Money Advice Service and debt advice charities.

Resumption of enforcement visits

Under current regulations, enforcement visits will recommence from 24 August 2020, and individuals will be given 30 days’ notice of a visit by an enforcement agent, unless the local authority has specific requirements. This is to provide sufficient opportunity for engagement with debtors prior to the attendance of an enforcement agent, which could prevent additional fees being added to the outstanding debt.

Excel proposes:

• To send reminder letters on default arrangements between 6th and 10th July giving debtors at least 44 days before taking any further action or adding any additional costs
• To send re-connection letters on all other cases between 13th and 24th July giving debtors at least 30 days before making any attendance

Training

All Excel’s enforcement agents have undertaken additional, mandatory training through our remote learning platform on protective equipment, social distancing, protecting themselves and the community, as well as refresher training on vulnerability and mental health awareness.

The newly designed training programme includes: the effective use of protective equipment and social distancing requirements, how to protect themselves and those that they encounter in the community. This will be supplemented by refresher training on supporting the vulnerable and recognising mental health issues.

Pre-visit assessment

Where a telephone number has been sourced, and if appropriate to do so, Excel will make outbound calls in advance of enforcement visits to identify any vulnerabilities or changes in circumstances.

Post-lockdown visits

The Government’s intention is for enforcement visits to restart from 24 August 2020.

Excel’s enforcement agents have undertaken refresher training on how to identify any vulnerabilities or changes in circumstances. Excel has unique training and qualifications regarding vulnerability including:

• Level 2 Award (CILEx endorsed) in Understanding Mental Health
• Level 3 Certificate (RQF & CILEx endorsed) in Vulnerability & Mental Health Awareness in Relation to Enforcement Practices.
• Vulnerability & Mental Health Awareness Workshop (CILEx endorsed)
• Mental Health First Aid (MHFA England training)

Visits will be contactless in line with CIVEA safe working practices guidance

Enforcement agents will not enter dwelling houses to take control of goods, unless there are exceptional circumstances and it is deemed safe for the agent and members of the public. This restriction will be reviewed and agreed with you on a regular basis

Where appropriate vulnerable people or those who have been severely impacted financially by the pandemic, e.g. loss of job, Statutory Sick Pay, will be referred to debt advice agencies for additional support

In these circumstances, the case will be placed on hold to be monitored, with contact by welfare staff, as appropriate, prior to proceeding. The fees incurred will remain in place

We will notify you of vulnerable debtors in the usual way

Data collection and recording

All CIVEA members will collect and record details of debtor vulnerabilities in line with data protection requirements e.g. debtor consent, and develop support plans that reflect CIVEA’s guidance on assessing the impact of COVID-19 on households.

Provision of protective equipment

The majority of enforcement payments are made by telephone before an enforcement agent is required to visit or after a letter has been left. When visits are necessary, Excel will provide workwear and hygiene supplies to protect and reassure staff and members of the public.

Enforcement agents will practice social distancing, comply with enhanced hygiene techniques (including disinfecting their kit) and be issued with hand sanitizer. This is in full compliance with Government and Public Health England/Wales advice.