CITIZENS ADVICE TEST VALLEY - Business and Development Plan 2018 to 2021

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CITIZENS ADVICE TEST VALLEY - Business and Development Plan 2018 to 2021
CITIZENS ADVICE TEST VALLEY

Business and Development Plan 2018 to 2021

                       At the heart of the community

   Company limited by Guarantee. Registered No. 08933947 England Charity Registered No. 1156829
   Authorised and regulated by the Financial Conduct Authority FRN 618853
   Registered Offices 35 London Street, Andover Hants SP10 2NU
BUSINESS PLAN 2018-2021

                                                  CONTENTS
       1. Introduction        ……………………….                                              Page 3

       2. Background …………………………..                                                     Page 4-6

       3. Funding       ………………………........                                             Page 7

       4. Community and Client Profile …………                                           Page 8-10

       5. Proposed Advice Service Developments                                        Page 11-13
       6. Summary …………………………….                                                        Page 14
       7. Action Plan ………………………….                                                     Page 15-23
Appendix A – Budget & Funding Strategy
Appendix B - Equality and Diversity Strategy
Appendix C – Organisational Structure
Appendix D – Business Continuity Plan
Available on request – Training Plan

This plan is rolling plan Year 1 will always be the current year each April the dates will change and the plan will be rolled
forward projecting a further 2 years ahead for activities and finance

                                                          2
Introduction
The Citizens Advice Service in Test Valley has been operating since July 2014 as a merger of Romsey District and Andover District
offices. A presence in both towns has been evident since the 1970’s. Our Mission is to provide wide access to information and
advice services, and to research and campaign to change policies and services that affect the community.

Citizens Advice Test Valley aims:
     To provide the advice people need for the problems they face and
     To improve the policies and practices that affect peoples’ lives.

The service it provides is free, independent, confidential, and impartial. It values diversity, promotes equality and challenges
discrimination.

Our Commitment

We will use all our resources to continue to improve the quality and accessibility of the Citizens Advice service, ensuring non-
discriminatory treatment within the service for clients, staff and volunteers and by outside agencies. We aim to become a stronger
champion for equality. Appendix B

The Citizens Advice service is a national service committed to the principle that all people from whatever background in every
community should have access to our information and advice. This principle requires us to maintain national standards of practice
and to hold firmly to the values that underpin everything we do – justice, equality and respect for the rights and dignity of every
person. These values and visions are our bedrock. Being inventive, responsive and generous is our culture.

We aim to attract and retain capable and dedicated staff and volunteers by support, training, development and good working
conditions. Making our service sustainable will be achieved by robust financial reporting and monitoring.

Our aims and mission fit with the aims of the Local Authority’s Corporate Plan 2015–2019 “Investing in Test Valley” in particular:
    To contribute to and be part of a strong community.
We will help our clients find a way forward
                                                                   3
Background

Local Citizens Advice

The Borough of Test Valley covers 62,758 ha and is situated on the western side of Hampshire. Test Valley Borough Council
consists of 48 elected Councillors representing 24 wards. It has 59 Parish areas and each Parish Council comprises a number of
elected Councillors.

Citizens Advice Test Valley serves Andover and the north of Test Valley down the valley to Romsey and the southern parishes of
Test Valley in Hampshire. The service is provided through the main offices in Romsey town centre and Andover town centre which
offer an appointment, drop-in, email and telephone advice service. Home visits are also undertaken if required.

In addition to general advice, the following specialist advice services are provided:
     Specialist advice provision for debt and benefit matters, including representation at tribunals and at court where necessary.
     We also have qualified intermediaries for Debt Relief Orders.

Telephone advice is provided during every session. We have adopted the use of a new telephone system called Adviceline - this is
a new single telephone number that has been rolled out throughout Hampshire. This has improved the telephony service
delivered in Hampshire and Berkshire.

The opening hours of each office are:
Andover office
Monday -Thursday                9.30am - 12.00      Drop in
                                12.30 - 3.30pm      appointments only
Friday                          Closed

Telephone advice is available Monday – Friday 9.00 am – 5:00 pm

                                                                 4
Romsey office
Monday –Wednesday               10.00am – 3.30pm Drop in and appointments
Thursday & Friday               10.00am -1.30pm Drop in and appointments

Telephone advice is available Monday – Friday 9.00 am – 5:00 pm

Outreach sessions
These are provided during the following times on a drop-in basis:

King Arthur’s Way        King Arthurs Hall Andover                     Monday       9.30am - 11.30am

Whitchurch Town Hall The Town Hall Whitchurch                          Tuesday      9.30am - 12.30pm

North Baddesley          The True Life Centre North Baddesley          Wednesday 10.00am – 1.00pm (every 1st and 3rd Wed)

Home visits are arranged by appointment for clients unable to access the office because of disability, care needs or access issues.

We currently employ 11 paid staff of whom 10 work part time (5.66 fte) and 45 advisers or gateway assessors. We also have 12
receptionists/clerical workers, and 3 trainees.

Our structure is described in the organisational structure at Appendix C.

       The Trustee Board delegates day to day management of the service to the Chief Officer who is responsible for shaping and
        delivering the strategic development plans for the service. Advice Service Managers are responsible for supporting and
        supervising the volunteers on a day to day basis
       Highly trained volunteer advisers drawn from the local community deliver the generalist advice service.
       We aim to recruit local people wishing to volunteer as receptionists and administration assistants giving them the
        opportunity to gain new skills and confidence.
       We aim to offer placements, wherever possible, to young people on work experience.

                                                                 5
   In all recruitment, both for paid and voluntary positions, equal opportunities in accordance with the stand up for Equality
    strategy are applied to our selection procedures.
   We aim to reflect the composition of the community we serve within our team.

                                                              6
Funding
Citizens Advice Test Valley is mainly funded by Test Valley Borough Council which has confirmed an unrestricted service grant of
£261,874 for 2018/19. The budget for providing services for the year is approximately £285,652. The extra funding will be sourced
through other grants and donations as well as fundraising.

                                         CATV Income                                        CATV Expenditure
                          Other
            Donations
                           6%                                                                 3%
              3%
                                                                                      13%

                                                                                 5%                                                Salaries
                                                          TVBC Grant                                                               Premises
                                                          Donations                                                                Staff Exp
                                                          Other                                                                    Office & IT
                                                                               18%                              61%                Other

                                  TVBC Grant
                                    91%

In addition to the main funding from Test Valley Borough Council we also receive funding from Basingstoke and Deane Borough
Council, Whitchurch Welfare Trust, Citizens Advice Hampshire and Citizens Advice. The Local Parish Councils and other
organisations will be approached for donations/grants throughout the year.

Citizens Advice Test Valley is reliant on the grant from Test Valley Borough Council to cover the vast majority of its’ annual
expenditure, the majority of which is salaries, and is very grateful for their continued support.

Raising the profile of Citizens Advice Test Valley in the future will be a priority, in particular our charitable status. A risk
assessment including financial implications is maintained and regularly reviewed.

                                                                       7
Community and Client Profile

Statistics from the Citizens Advice database revealed that in 2017/18, 5213 people from Test Valley contacted Citizens Advice with
11,475 issues

                                                     Top 5 Advice Categories
                                                Housing
                                                 12%

                       Relationships & Family
                                                                    Benefits and Tax credits               Benefits and Tax credits
                                13%
                                                                              41%                          Debt
                                                                                                           Employment
                                                                                                           Relationships & Family
                                 Employment                                                                Housing
                                    14%

                                                          Debt
                                                          20%

Age

         42% of these clients were male and 58% female, the highest proportion were aged between 30-54 (51%) and 22% being
          over the age of 65.
          Figures from the 2011 census estimate 18.38% of the population of Test Valley to be 65+
          Test Valley has an average age of population of 41.4 years the average age of our clients is between 45 and 49 years of age
          By 2018, it was forecast that Broughton & Stockbridge will have the highest proportion of over 60s followed by the Andover
          ward of Charlton.
          We currently only see a small percentage of clients from the Stockbridge and Broughton area so these statistics show we
          will want to improve our presence in that area over the next 3 years.

                                                                   8
Ethnicity

      Of our clients seen 7% were recorded as being from an ethnic group other than white British. Recent research classified
       93.92% of the Test Valley population as ‘White British’, which is average by National standards.
       In 2011, the White Gypsy or Irish Traveller population accounted for 0.1% of population in Test Valley. The vast majority of
       the population in Test Valley (97.2%) also spoke English as their main language. The most common other main languages
       were Polish (0.5%) and Portuguese (0.2%).

Housing

     We dealt with 607 issues about housing from 363 clients 22 of whom were deemed homeless and 46 threatened with
      homelessness.
      According to the 2011 census, there were 52,999 dwellings in Test Valley – a rise of eight per cent since 2001. There is an
      estimate that this will rise again to 57,291 by 2026. In 2014 the average house price was £244,000 making Test Valley 5th
      highest for average house prices in Hampshire.
    70.4% of Test Valley residents own their own home this is higher than the average for England
     Differences exist between the housing market in the Romsey area to that of the Andover area. The Romsey local housing
     market functions mostly for local people with a small number of incomers from Southampton looking to upgrade, and
     Winchester by those who cannot afford to live there. First-time buyers who can’t afford Romsey prices seek housing in
     Totton, Southampton and Eastleigh – although Valley Park has attracted younger buyers in recent years. In Romsey there is
     significant competition for smaller properties with private landlords looking for investments.

       Andover has comparatively low levels of owner-occupied properties, although more incomers are attracted to the area, as
       it is closer to Basingstoke, Salisbury and south west London and the housing stock offers incomers considerable value for
       money. There is a lot of landlord investment in Andover for lower-priced properties.

      Test Valley has seen over 1000 new homes built in the last few years half of which is affordable housing.

                                                                 9
Employment and benefits

     42.8% of residents in Test Valley are in full time employment with 2.5% actively seeking work.
      The proportion of advice issues regarding Job Seekers Allowance was 4.6%
     15.5% are retired ,
     2.4% are deemed sick or disabled - we saw 23% of our clients came in about Employment Support Allowance and Incapacity
      Benefit and 20% came about disability benefits.

                                                            10
Proposed Advice Service Developments

Aims and Objectives

The aim is to develop a financially stable service working in cooperation with our partner local authorities - to help more people,
particularly the more disadvantaged and socially excluded of our residents, by providing improved access to professional and
efficient generalist and specialist advice. This will be achieved face to face, by telephone, or by email as appropriate and by taking
the advice to those in most need.

The introduction of Adviceline into Hampshire has been hugely successful with most Hampshire offices now using it and
improving the phone service to clients within the area. The new system was adopted in 2016 by Citizens Advice Test Valley. The
introduction of Adviceline has improved access to telephone advice throughout the borough. With this comes the need for up to
date and efficient IT within the service. We have successfully upgraded all out IT and security in the last year.

We aim to maintain our excellent relationship with Test Valley Borough Council by continuing to work with our local authority, as
they are the key to future financial stability. We will demonstrate that we are working with them to achieve mutual aims and
objectives and we are working to improve our service, we will gain their confidence and their support for our activities. In turn we
expect this to lead to both the Members and the Executive wanting to ensure we are funded adequately to sustain our service in
the future.

We will continue to take on new projects that meet with our aims to help more people, we will also reduce the financial risk to the
service by adopting full cost recovery and will broaden our funding base. This, in turn, may increase the prospect of sustained
employment for staff and volunteers giving stability and continuity to the service.

      We have implemented email advice and will continue to provide a service to the community via our Outreach service, main
       office, telephone and home visiting where appropriate.
      With the trend of an ageing population in Test Valley, Outreach Sessions and home visiting will become vital to allow access
       for all.

                                                                  11
We are committed to providing a service that is accessible to everyone, both users and volunteers. We use data and information
gained from various sources including community profiles and client feedback to enable us to work towards providing services to
hard to reach people within our communities, including the most vulnerable and those who are, or risk being, socially excluded.

      We already provide outreach services at King Arthurs Hall, Whitchurch Town Hall and North Baddesley. With the population
       in St Mary’s ward set to increase especially for the age group 20-29 there is a real need for our Outreach service to continue
       to support that area.

      We already provide a home visiting service for those who are unable to attend our offices in both Romsey and Andover.

      We need to raise our profile in the Stockbridge, Broughton and Kings Somborne areas where there is the highest proportion
       of over 60’s living.

      We need to work in partnership with other community organisations to establish how we can best provide services to newly
       arrived migrant workers and their families, an ever increasing population.

      We look to purchase tablet computers to help carry out initial information gathering with clients when appropriate.

      We have achieved the Advice Quality Standard with Casework in debt and employment. This will strengthen our position as
       a key advice provider in Test Valley.

      We are already working with Citizens Advice Hampshire who are committed to working together with us towards a fairer
       society, and to collectively deliver quality services with shared goals and priorities. This work will continue and together
       with other offices in Hampshire we will look to ensure best practice is adopted to make Citizens Advice the preferred advice
       provider in Hampshire

                                                                 12
Promoting the service in the Community

We recognise that we need to continue to promote the services we offer to the local community, our funders and other partners.
The idea of helping our local authority partners to meet the aims and objectives in relation to social cohesion as set out in their
community plans is the cornerstone of the strategy. We aim to be a voice that can be heard and trusted and that can help inform
the development of Research and Campaigns both locally and nationally.

We are very active in research and campaigning and reporting to our national office. At a national level Citizens Advice have been
very successful in changing laws and influencing new parts of legislation before it is formally passed - We have contributed to this.

In addition, we recognise the need to promote our services to the community, to funders and to partners particularly to those
groups we are not reaching for whatever reason - this will be achieved by use of the written word, broadcast and social media in
the local area.

Summary

The Business and Development Plan has examined the profile of the community, compared it with the profile of clients using the
service, introduced evidence of client need and produced an analysis of the service that we should be providing. The analysis has
taken into account the needs of the community as expressed in Local Authority plans and strategies and tailored our services to
help meet those needs.

The resulting aims and objectives have been clearly set out above as have the developments needed to achieve them.
Considerations of governance, finance, equality and risk have been taken into account to produce the plan.

Set out below is an action plan, in table form, to implement the developments needed to achieve the aims and objectives over the
period 2018 to 2021.

                                                                 13
3 year Action Plan

We have identified a number of Actions against which progress on achieving our Strategic Objectives will be gauged. These can be
categorised as:

Business as Usual – Maintaining and preserving what we do now

Service Development – developing our existing service experience

Innovation – looking forward to what we should be doing

                                                              14
1.     Developing Access to advice and ensuring quality of advice and information is maintained

No         Action                                          2018/19                       2019/20                  2020/21
1.1        Following the introduction of Adviceline        With the new platform in      By April 2019 – review   Continue to review the
           and Casebook we continue to participate         place establish a model       we are answering         percentage of calls
           in the Hampshire and Berkshire Adviceline       of working across both        50% of demand as         answered in our area to
           group.                                          offices to help us reach      per the signed SLA       ensure we remain on
                                                           our target                                             target with the group
1.2        Schedule 4 of the new Membership                Offer has been reviewed       Continue review with     Continue review with the
           Agreement with CA, looks at “What the           and increased by 10%          the aspiration of        aspiration of
           member will contribute to shared                new Schedule 4 target         improvement year on      improvement year on
           delivery”                                       1500 pa                       year                     year

1.3        Expand the service available by allowing        Look at recruitment of        Extend the service to    Embed and fully
           longer hours of access                          volunteers and invest         allow for an extra       integrate the new session
                                                           time into training to allow   ‘drop in’ session
                                                           for an extension to our
                                                           Adviceline hours
1.4        Continue to provide inclusive, quality          Full training has been        Review and embed         Report on any emerging
           services to achieve fairness and equality in    provided to raise             accurate case            issues around
           access to advice and non-advice services.       awareness with all            recording through all    discrimination
           We will do this by recording ethnicity and      volunteers. All volunteers    channels of contact
           disability. We will record numbers and          have received GDPR            with the client
           types of discrimination enquiries, include it   training
           in casework and represent it within
           Casebook
           We maintain awareness of Equal Opps
           issues and policies through training and
           staff and volunteer meetings

                                                                         15
1.5    Develop, implement and deliver accessible,   Quarterly assessment will    Ensure support and      Develop good practice in
       quality services to clients                  continue to be graded        training is readily     case recording to allow
                                                    green or yellow              available to help the   for continued green and
                                                                                 volunteers              yellow grades
1.6    Develop, implement and deliver accessible,   Timely assessment is         Embed a feedback        Develop good practice to
       quality services to clients and monitor      carried out through CA       process to the          ensure the client
       Client experience via CA                     ensure we check              volunteers and staff    experience is as positive
                                                    responses and respond                                as it can be
                                                    accordingly
1.7    Develop, implement and deliver accessible,   We have now completed        Continue to assess    Develop good practice to
       quality services to clients and monitor      the second survey and        feedback and explore ensure the volunteer and
       People Management via CA                     await results which will     any unresolved issues staff experience is as
                                                    be analysed                                        positive as it can be
1.8    Ensure all requirements of the Financial     At key times of the year     At key times of the   At key times of the year
       Health Management are reported               Green and yellow reports     year Green and        Green and yellow reports
                                                    are sent for submission.     yellow reports are    are sent for submission
                                                    We have designated our       sent for submission
                                                    reserves to help with this
                                                    process and make our
                                                    results around reserves
                                                    move out of red
1.9    Ensure all requirements of the Leadership    A revised Business Plan Develop good                 Develop good practice to
       assessment are reported                      was resubmitted as part practice to ensure all       ensure all requirements
                                                    of the LSA and approved requirements are             are assessed as complete
                                                    Site visit in August 2018
                                                                            assessed as complete         and up-to-date at critical
                                                                            and up-to-date at            times
                                                                            critical times
1.10   Promote Research and Campaigns as an         A cub committee has now Look to embed                Develop good practice to
       equal aim of the service’s work. A trustee   been established and we Research and                 ensure the R & C is part

                                                                  16
will be appointed to have responsibility for   meet 6 monthly this          Campaigns into all       of all we do with clients
         Research and Campaigns.                        includes a trustee           aspects of our work.
                                                                                     We continue to work
         We run effective, inclusive campaigns, and                                  together with
         achieve equality/fairness in coverage of                                    Hampshire in a local
         equality issues in national and local                                       cluster group this
         Research and Campaigning work in order                                      gives strength to our
         to promote equality and tackle                                              campaigning
         discrimination and disadvantage.
1.11     We resource our Outreach Service by            Funding is mainly by         Review the position of   Consider expansion of
         small grants and donations to ensure our       grants application will be   funding and costs        the Outreach or change
         service is as fully accessible as we can       made to ensure small         involved in delivering   of venue interrogate
         make it                                        grants are received          current Outreach         statistics to ensure best
                                                                                     services                 value for money
1.12     We invest in expert advice to make sure        Make sure all advice         Provide subject          Deliver specialist service
         our advice is accurate relevant and that       products are accurate        matter expertise         within the core service
         support meets users needs                      and relevant for clients     support that is          and look to receive extra
                                                        and advisers                 relevant for clients     funding for these service
                                                                                     and advisers and         to expand in the future
                                                                                     supports the wider
                                                                                     work of the national
                                                                                     service

       2. Developing partnerships and good public relations

                                                                      17
No    Action                                          2018/19                     2019/20                2020/21
2.1   We promote the services we offer to the         Establish routine           Become more            Embed our knowledge
      local community, our funders and other          approaches to               integrated into        and influence and advice
      partners – we do this by                        partnerships so we are      partnership working    within these partnerships
           Forming trusted partnerships              more influential across     allowing access to
           Being involved in local media and         more issues.                our data and looking
              local publications                      Use our data to maximum     to shape policy with
           invite influential local people to        effect                      other organisations
              address the AGM
           produce an Annual Review to
              complement the Annual Report &
              Accounts
           through talks to interested local
              groups.
           network locally to help make useful
              connections and raise our profile
           Ensure we have great data and use it
              to improve the services we offer
      We use the information gained at these
      meetings and connections and review them
      each year to help ensure our Business Plan
      reflects the need and demand for our
      service
2.2   We continue to support and work in              CO involvement on various   To assist when         Use resources to help
      partnership with Citizens Advice Hampshire      projects and the CO sits    required with          expand our own service
      to make Citizens Advice the preferred advice    on the advisory panel       possible funding
      provider in Hampshire                                                       opportunities
2.3   We monitor to see if there is any gaps in our   Mapping exercise to         Good promotion of      Expand the home visiting

                                                                  18
service in the Stockbridge and King           ensure we are reaching        how clients can be in   service to extend
      Somborne area and put resources in to         the clients that need our     touch with us           accessibility
      bridge that gap if necessary                  service
2.4   Close working with other like-minded          We already work closely       Develop similar         Embed this partnership
      organisations                                 with Andover Charities and    working relationship    working across the
                                                    the Andover Advocates         with other small        network
                                                    and supporting them           charities where
                                                                                  possible
2.5   Hate Crime Reporting Centre for which we      Timely reporting is carried   We continue to          Embed into all aspects of
      have received funding we will continue to     out to ensure we check        embed all aspects of    client work
      provide this service beyond the life of the   responses to this add on      this work with our
      funding and adapt accordingly to ensure       service                       clients
      funding is available should it be required

      3. Developing sustainable services and ensuring we have an effective resource strategy (See Appendix A)

                                                                 19
No    Action                                           2018/19                      2019/20                  2020/21
3.1   We review our resources and structures to        As well as maintaining our   Develop volunteer        Embed digital inclusion
      achieve a financially stable office working in   established channels of      and staff experience     to all areas of work
      co-operation with our partner local              contact we will develop      and knowledge with
      authorities.                                     our digital offer to help    digital tools that are
      We provide great digital and advice tools to     meet user needs              available
      meet the needs of the user
      This includes taking on projects that meet
      our aim to help more people and reduce the
      financial risk to the service by adopting full
      cost recovery and broaden our funding base
3.2   Build on relationships with our local            Meeting regular targets      Working together         Work with the L.A to
      authorities and demonstrate that we are          driven by the L.A            with the L.A to          embed the roll out of
      working with them to achieve mutual aims                                      ensure clients           Universal credit
      and to improve our service.                                                   moving to Universal
      This is done by reporting on our                                              Credit are given the
      Performance Targets every 6 months                                            support that need
3.3   Work to new 3 year Partnership statement         Report on final data for     Work with L.A to set     Continue to monitor
      for funding from the Local Authority             2018/19 and meet             responsive               progress and look to
      Maintain a prudent level of unrestricted         required targets as per      achievable targets       develop new channels of
      reserves and provide a budget forecast for       new statement                                         funding for the core
      the future of the service                                                                              service

      4. Ensuring good governance

No    Action                                           2018/19                      2019/20                  2020/21

                                                                    20
4.1   We continue to meet the requirements for        Good reporting                  Calendar entries       Develop others
      the Charity Commission, Companies House,        procedures are paramount        ensure key             knowledge into the
      Data Protection and the Financial Conduct       to the service reputation-      reporting times are    reporting process
      Authority                                       all requirements of these       adhered to
                                                      governing bodies are
                                                      completed on time to
                                                      ensure compliance

4.2   We annually review and recruit, if necessary    A skills analysis is carried    Develop train and      Embed the knowledge
      Trustees to ensure we have the optimum          out on a bi- annual basis.      impart knowledge to    so trustees can and
      number to provide good governance and           Gaps in skills are identified   the trustee board of   influence others in the
      ensure they are engaged and effective. A        and recruitment to fill         the work we do as      course of their daily life
      rolling re-appointment will take place at the   these missing roles is          national and local
      AGM. A succession plan is now in place with     undertaken                      charity
      the appointment of a Vice Chair
4.3   The Health and Safety Committee will            Continue to work in close       Monitor and make       Embed good and Health
      ensure that safe and secure services for        partnership with TVBC           changes as             and Safety awareness
      volunteers, staff and clients at both offices   with regard to the Romsey       appropriate to both    with all paid staff and
      are provided                                    premises.                       working                volunteers by training
                                                                                      environments
4.4   We review and maintain policies and             Review is carried out           Training and           Adherence to the policy
      procedures annually as per our Bureau           annually at board level         knowledge sharing      is paramount to our
      Management Information System                   where required                  amongst the staff
      recommendation                                                                  and volunteers is an
                                                                                      important part of
                                                                                      this review

4.5   The Trustees have negotiated via TVBC a     See sight of the new lease          Look at negotiating    If no premises available
      new lease running from Jan 2017 for 6 years and sign if approved                new premises for       develop a better working

                                                                    21
at the current premises in London Street –                               post 2021              environment at 35
      Yet to be received                                                                              London Street for
                                                                                                      volunteers and staff
4.6   We will make adequate provision for crises This provision is contained   Training and           Embed good practice to
      and emergencies, and ensure that major the Business Continuity           knowledge sharing      ensure invocation of
      risks have been identified and reviewed, and Plan attached at Appendix   amongst the staff      Business Continuity Plan
      that systems have been established to D                                  and volunteers is an   can be avoided
      mitigate them.                                                           important part of
                                                                               this plan

                                                               22
Appendix A

Budget                                         2018/19   2019/20   2020/21
Income                                         £         £
TVBC Grants (inc Salaries, rent and revenue)   261,874   264,196   266,551
Basingstoke and Deane BC                       3,000     3,000     3,000
Whitchurch Welfare Trust                       600       600       600
Rental Income                                  490       490       490
Healthwatch Hampshire                          4,000     4,000     4,000
Donations & Fund Raising                       10,400    10,400    10,400
Other Income                                   4,399     4,399     4,399
TOTAL INCOME                                   284,763   287,805   289,440
Expenditure
Salaries, Rent and Parking permits             168,344   168,344   168,344
Other Staff Costs                              5,050     4,850     5,150
Volunteer expenses                             16,950    17,150    17,350
IT Costs and Citizens Advice                   11,700    11,700    11,700
Premises Expenses                              53,742    54,804    55,393
Office expenses incl postage                   27,142    27,862    28,462
Admin expense incl government costs            1,812     1,900     1,900
TOTAL EXPENDITURE                              284,740   286,610   288,299
Surplus/deficit                                23        475       1,141

                                                                                          23
Funding Strategy

   1. The purpose of the funding strategy
The purpose of this strategy is to ensure that the organisation has the funding needed to deliver a quality advice service which achieves
our statement of purpose, and which meets the priority needs identified in the organisation’s business plan and the community advice
needs analysis.

The strategy will consider the income required to meet the priority needs, identify the gaps between existing and required funding and
set out an action plan for obtaining the additional funding required.

The strategy is informed by the project review carried out in November 2017

This strategy is designed to be a living document and will be reviewed and updated by the business manager and chief officer on at least
a six monthly basis.

    2. Our priorities
Our most important priority is to maintain our current service in Test Valley ensuring that clients can continue to access advice at both
offices through pre-booked appointments, drop-in, telephone, email and letter. It is essential that our opening hours in both locations are
maintained.

Our remaining priorities are focussed on specific advice areas, particularly vulnerable client groups and on maintaining and developing
our strategic position. The detail on this is outlined in the advice needs analysis in the business plan, which has been informed by the
community and client profiles. They reflect the projects that we are delivering in 2018/19 as well as the aims to develop the service up to
2021 and beyond.

                                                                                                                                            24
2.1.         Enquiry type
Specialist welfare benefits advice
It is clear from the community advice needs analysis in our business plan, and from the advice provided in 2017/18, that benefits advice is
a major need in our community. As welfare reform continues, it is essential that we continue to provide welfare benefits advice, not only
at generalist but also at specialist level, focusing particularly on supporting clients through mandatory reconsiderations and appeals.
Specialist debt advice
Our community advice needs analysis identifies that some of our local individuals and families are living on low incomes or in poverty.
Ongoing welfare reform, including the changes in the Benefit Cap and the rollout of Universal Credit is likely to exacerbate the situation
for low income families. In 2017/18, debt was the second highest enquiry area for the organisation and it is essential that we continue to
provide a specialist debt advice service.
Financial capability support
Through the services above we will offer support to families and individuals during the rollout of Universal credit in July 2018. (Andover)
our Romsey office has already seen the roll out and is helping clients when needed.
We have already seen an increase in demand for our service to help clients transfer from DLA to PIP and we will continue to support this
work up to a specialist level

        2.2.          Our client group
Long term sick and disabled
It is our responsibility to make sure that people can access the advice they need. In general, most people are able to use our core service
through telephone, email, and letter or face-to-face. However, for people who are disabled or who have a long term health condition, it
can be more difficult to get advice and support. Therefore it is important that we provide a more targeted service in order to meet their
needs.
Mental health
People with mental health problems can find it hard to access advice through traditional routes and generally need more support to get
the help they need. Evidence shows the clear link between debt and financial difficulties and mental ill-health. Therefore, it is important
that we continue to provide a service focussed on this client group.
People living in rural areas
The geography of Test Valley is such that we have two major towns one in the north and one in the south with a number of rural villages
in between. The town of Andover is urban and growing in size and more development is being put in with little infrastructure. We already

                                                                                                                                         25
offer an Outreach at one of the main social housing estates on the edge of Andover town and offer a home visiting service to clients who
are resident in more rural arears and are unable to access any of our services

   3. Summary of our priorities

Our priorities within this funding strategy are as follows:
  1. Maintaining the core service
  2. Providing a specialist welfare benefits service
  3. Providing a specialist debt service
  4. Providing an Outreach Service in Whitchurch King Arthurs Way and North Baddesley

   4.         Funding opportunities
Local offices traditionally depend on a mix of funding sources and the trend is for more commissioned services rather than more flexible
grants. This mix of funding can be positive, minimising the risk to financial stability. However, receiving short-term pots of money from
multiple funders brings an increase in demand for resources, both in maintaining relationships and reporting requirements, as well as the
continual need to seek new funding.

4.1. Our existing funders
Our existing funding streams are a mix of local authority funding for our core services and project funding, some of which is channelled
through Citizens Advice Hampshire who take responsibility for communicating with the funder and reporting on performance.

Funder                          Type of funding                  Comment/Risk
Test Valley Borough Council     Core Funding                     Possible future cuts
Basingstoke and Deane           Project Funding                  Confirmed to 2020
Borough Council
Test Valley Community Svcs      Project Funding                  Ended Mar 2018
Hampshire County Council        Through consortium               Expected to continue
Hate Crime                      Through consortium               Ended Mar 2018
Healthwatch                     Through consortium               Expected to continue

                                                                                                                                           26
4.2    Previous funders
Big Lotteries – Advice Service Transition Fund – project finished 2016 Legacy service still continuing – North Baddesley Outreach – extra
funding through small grants has been received to maintain service.

4.3    Other opportunities
Traditional funding streams range from very small local trusts to very large national bodies and it is essential that we keep abreast of
developments and opportunities from all of these.

There a number of ways in which we can keep up to date, either through regularly checking websites, or by signing up to receiving
notifications of new funding. These include:

   ● Citizens Advice
   ● The Big Lottery Fund (including Awards for All and Reaching Communities)
   ● Test Valley Fund Finder/ Grants Online

                                                                                                                                            27
Funding our priorities

1. Maintaining the core service
Status
Existing funding position                            Test Valley Borough Council - £260,000
                                                     Funding to 2021. Further funding expected: new partnership
                                                     statement entered into April 2018
Existing staffing                                    5.66 fte
Additional funding required to maintain existing     £0
service beyond 2021
Potential funding                                    n/a
Action required                                      CATV to maintain relationship with funder
                                                     CATV to meet reporting requirements

2. Providing a specialist welfare benefits service
Status
Existing projects                                    Part of core
Existing funding position                            As above
Existing staffing                                    Caseworker x 3 (1.1fte) volunteer basis
Additional funding required to maintain existing     £1000 would help us extend our service more to the community by
service beyond 2017/18                               operating benefit surgeries
Potential funding                                    Simply health
Action required                                      Approach Simply Health
                                                     Seek additional funding.

                                                                                                                       28
3. Providing a specialist debt service
Status
Existing projects                                   Part of core
Existing funding position                           As above
Existing staffing                                   Caseworker x 2 (1fte)
Additional funding required to maintain existing    0
service beyond 2017/18
Potential funding                                   Registered social landlords
                                                    Money Advice Service
                                                    Local authority (response to new Housing Bill re preventative
                                                    services)
Action required                                     Maintain communication with CitA re MAS
                                                    Maintain communication with local authority housing department
                                                    Approach social landlords
                                                    Seek additional funding: smaller trusts and charities.

4. Providing an Outreach Service at three locations
Status
Existing projects                                   North Baddesley
Existing funding position                           £3,600 rec’d for Whitchurch – grant funding
                                                    £1200 rec’d for North Baddesley – donation
                                                    £0 King Arthurs Way – funding through core
Existing staffing                                   Caseworker x 2 (1.1fte)
Additional funding required to maintain existing    £0
service beyond [current financial year]
Potential funding                                   Councillor Grant, Small trusts and grants, donations
Action required                                     Seek additional funding smaller trusts and charities.

                                                                                                                     29
Equality and Diversity Strategy                                                                                          Appendix B

It is the intention of Test Valley CAB to ensure the Citizens Advice equality strategy, Stand Up for Equality (SU4E) directly influences
our Service Delivery and HR work. The following indicates the key areas within the core Business Plan where activity will be
focused, and where existing work is already taking place to progress the following three SU4E target areas.

Target area 1: Challenging discrimination through advice

We will use all our resources to continue to improve the quality and accessibility of the Citizens Advice service ensuring non-
discriminatory treatment within the service for clients, staff and volunteers and by outside agencies. We aim to become a
stronger champion for equality.

The Citizens advice service is a national service committed to the principle that all people from whatever background in every
community should have access to our information and advice. This principle requires us to maintain national standards of
practice and to hold firmly to the values that underpin everything we do – justice, equality and respect for the rights and dignity of
every person. These values and visions are our bedrock. Being inventive, responsive and generous is our culture.

See Action Plan points 1.4, 1.5.2

Target area 2: Promote equality through advocacy

We are committed to providing a service that is accessible to everyone, both users and volunteers. We use data and information
gained from various sources including community profiles and client feedback to enable us to work towards providing services to
hard to reach people within our communities including the most vulnerable and those who are, or risk being, socially excluded.

We need to work in partnership with other community organisations to establish how we can best provide services to newly
arrived migrant workers and their families, an ever increasing population.

                                                                                                                                      30
We have invested in a kiosk at the Andover office to allow easy access for clients without computers at home or for use at busy
times. The kiosk service translates into 64 languages

We are committed to providing translation and interpretation when required for clients including British Sign Language.

We are a 3rd Party Hate Crime Reporting Centre and also advice on Restorative Justice

Action Plan Points 2.1, 3.4

Target area 3: Value diversity through our roles as employer, volunteer agency and contractor.

We provide training in Equality and Diversity, which is open to all workers to undertake and is part of the Volunteer Certificate
training

Equal opportunities are at the heart of everything we do and are reflected in our service provision, recruitment procedures and
the work we do in partnership with others.

Action plan point 1.4, 4.2

                                                                                                                                    31
Organisational Structure                                                                                   Appendix C

                                                                                Finance Sub Cttee
                                              Trustee Board                         Health & Safety Sub cttee

                                                                                       Remuneration Sub Cttee
                                                 Chief Officer
                                                                    Admin
                                                                    support

                                               Operations Manager

                         ASM*
                                                                                          ASM*
                          (A)
                                                                                           (R)

            Volunteer ASS**
                                              Training
                                                                                         Volunteer ASS**
                                              officer

                                                                        Outreach
                                                                           co-
                                      Admin                             ordinator
               Volunteers                                                                     Volunteers

*ASM – Advice Services Manager
** ASS – Advice Services Supervisor

                                                                                                                        32
Appendix D

                                 BUSINESS CONTINUITY PLAN
VERSION CONTROL

        Issue         Date         Issued by       Reason for Issue
         No.

         0.1        01/04/2016      A Moon                 Draft

         1.0        24/01/2017      A Moon                Updates

         2.0        13/07/2018      A Moon                 Audit

Distribution list

        Copy        Issued to                  Position

                 All members of
        1            Business                Chief Officer
                Continuity Team
                     Board of                Chief Officer
        2
                     Trustees

                                                                              33
The full service business continuity plan is distributed to all members of the business continuity team as a hard copy and these are
kept off-site. Trustee board members are also sent an email version. The on-site hard-copy version is kept on the network and in
Chief Officers’ office.

Introductory page

Citizens Advice Test Valley is a registered charity which provides free, independent, confidential and impartial advice to help
resolve problems. The service is open to everybody regardless of race, sex, disability, sexuality or nationality. All offices operate as
separate entities but are members of Citizens Advice, the national charity. Citizens Advice provides support, information and
training which allow offices to provide an advice service directly to the public through a range of community settings, e.g. the high
street, libraries and GP surgeries, and increasingly by telephone, via the internet, by email and through the media. If Local Citizens
Advice were unable to prove their resilience during a disruption, and were unable to provide the service to their clients over an
extended period, this could seriously jeopardise the potential for repeat funding.

The office has two locations from which it operates all of its services
35 London Street, Andover, SP10 2NU
Former Magistrates Court, Church Street, Romsey, SO51 8AQ

The Andover Office is currently occupied under a lease with TVBC – who in turn have a lease with Langdowns the head landlord.

The Romsey Office is occupied under a lease directly with TVBC and is currently due to end in October 2028.

As at the 13 July 2018 we have 11 paid employees whose hours range from full time (40hrs) to 15 hours a week.
We have a team of 9 trustees including a Chair, Vice Chair and a Treasurer.
We have a team of 12 volunteers who are receptionists or clerical workers.
We have 45 volunteer advisers.

                                                                                                                                      34
Our main funding is received from Test Valley Borough Council and we also have partnership working with Test Valley Community
Services and Citizens Advice Hampshire. We provide our service at 3 Outreach locations – King Arthurs Way, Whitchurch and
North Baddesley.

The purpose of this document is to prepare the service to cope with the effects of any disruption and to implement broad, widely
acceptable measures which could be used to address a number of scenarios.

Objectives of this Plan

   1. To ensure the safety and well-being of employees and volunteers.
   2. To minimise the likelihood of impacts and risk of interruptions.
   3. To ensure that maximum possible service levels are maintained during disruption and establish good communication links
      with employees, trustees, funding bodies, customers, suppliers and stakeholders.
   4. To ensure that the service recovers from interruptions to the organisation as quickly as possible.

Following a disruption to the business it is likely to be impossible to provide all the business-as-usual services and functions.
Therefore it is necessary to decide which are related to the survival of the organisation (and is therefore mission-critical) and
which can be sacrificed if absolutely necessary. This analysis takes into account the employees required, important locations,
special equipment needed and time-sensitive processes. A list of business-critical activities can then be identified. These activities
should continue, even at a reduced level, during a disruption. To establish which products and services and deemed critical, the
following criteria can be used.

Failure to provide this service will:

      Have a serious detrimental effect on human welfare
      Result in breaking obligations expected by funders
      Involve a serious loss of credibility, reputation and public perception

                                                                                                                                   35
The Business Continuity Team

A Business Continuity Team (BCT) has been established. This team includes senior members of the service whose involvement will
be critical to dealing with an interruption to the business and arranging a successful recovery. This team includes The Board of
Trustees, Chief Officer and Operations Manager and Advice Service Managers.

The team exists to:

      Make swift, informed decisions.
      Provide direction to managers.
      Provide direction to staff.
      Issue internal and external communications.
      Be easily accessible and contactable.

The continuity manager with delegated approval from The Board of Trustees is responsible for invoking the Business Continuity
Plan.

Invocation

The Business Continuity Plan will be invoked by the Chief Officer with the backing of The Board if it looks likely that work resources
(buildings, people or systems) could be out of action for over 48 hours unexpectedly.

This may be caused by large-scale natural disasters (hurricanes, flood, storms), power cuts, malfunctioning software, server
malfunction, office fire, computer virus outbreak, terrorist attack or pandemic disease outbreak. (This is not an exclusive list).
Following any unexpected incident which has an impact on work resources, the Chief Officer should be informed immediately.
He/she will contact the Business Continuity Team and The Board to invoke the Business Continuity Plan. Following invocation, the
office contact tree will be used to contact all stakeholders. (See Appendix A).

                                                                                                                                   36
In the case of invocation and the offices being unusable in Andover, I will look to locate myself at Test Valley Borough Councils’
offices.

In the Romsey area I will locate myself at Costa Coffee in The Hundred.

                                                                                                                               37
Role                 Position and Post Holder   Contact        Main Areas of Responsibility
Continuity Manager   Chief Officer              01264 355090      Being responsible for invoking the plan
                     Ange Moon                  (Home)            Directing the BCT in an emergency and
                                                01264 723641        co-ordinating the Business Continuity
                                                (Work)              response.
                                                07988 689434      Notifying the emergency services.
                                                (Mobile)          Ensuring the continuity planning is
                                                                    adequate.
                                                                  Leading the BCT update meetings (6
                                                                    monthly/annual cycles).
                                                                  Managing the roles and output of other
                                                                    BCT members and delegating.
                                                                  Determining who should undertake
                                                                    which roles and deciding which roles (if
                                                                    any) may be combined in one person.
                                                                  Ensuring protection and security of
                                                                    people and property during and
                                                                    following a disaster.
                                                                  Being responsible for emergency shut-
                                                                    down and evacuation of the facility.
                                                                  Instructing     and    leading    relevant
                                                                    professionals to appraise the physical
                                                                    conditions following a disaster and
                                                                    overseeing the salvage operation.
                                                                  Ensuring that the insurance company is
                                                                    notified.
                                                                  Leading the recovery process.

Communications       Operations Manager         01264 354307         Activating communication with the local

                                                                                                                38
Manager              Angela Kemp   (Home)             newspapers, local radio stations.
                                   01264 723645      Supervising updates on the website and
                                   (Work)             any local authority websites.
                                   07812 681183      Supervising all update emails.
                                   (Mobile)          Using internal communications to help
                                                      embed business continuity in the
                                                      organisation.
Staff Communication ASM                              Responsible      for    contacting    each
Manager             Julia Shaw     01794 517268       volunteer or staff member to let them
                    Sue Collinge   01794 519431       know the situation. Initially by telephone
                    Tom James      07872 490318       with email as the last resort
                    Laura Ivey     01256 896805

                                                                                                   39
Business critical activities

Products and services

        Name of product
                                        Description                                     Impact time frame
          or service

                                                                                                   Up to 1
                                                                    24 hrs         24-48 hrs                   Up to 2 weeks
                                                                                                    week

       Advice systems,         Websites to provide offices       Inability to     Minimal        Closure of   Closure of service.
       i.e.AdviserNet,         with information, resources       operate          help           service.
       Adviceguide             and policy to manage their        gateway          provided
1.
       (product / service)     clients’ problems.                assessment or    for clients.
                                                                 general
                                                                 advice.
       Gateway                 This interview is the initial,    If premises      If continued Closure of     Closure of service.
       Assessment               time-sensitive, assessment of    not available,   issue,       service.
       (service)               the clients’ problem and          unable to take   Outreach
                               situation. It is not to provide   place unless     service
2.                             ‘quick advice’, but is designed   set up by        could be
                               to determine the next step        phone (more      provided
                               that needs to be taken in         unusual).
                               particular circumstances. Each
                               appointment should take no

                                                                                                                                    40
more than 20 minutes

     CRM Software        This is a software tool (run on    Paper records   Continue to    Continue to     Continue to
     (product)           Citizens Advice IT system)         can be kept.    operate        operate face    operate face to
                         which holds all client records                     face to face   to face         face meetings
                         and details and is vital for:                      meetings       meetings        using paper
                                                                            using paper    using paper     records, consider
                               production of statistical                   records,       records,        getting extra help
                                information.                                consider       consider        to input
3.                             case recording and case                     getting        getting extra   paperwork into
                                checking.                                   extra help     help to input   CRM when
                               submission of Bureau                        to input       paperwork       recovery
                                Evidence Forms.                             paperwork      into CRM        complete.
                               specialist case                             into CRM       when
                                recording.                                  when           recovery
                                                                            recovery       complete.
                                                                            complete.
     Specialist advice   Client meetings which take         These usually   Consider       Consider        Consider
     (service)           place on specific issues, often    take place      transferring   transferring    transferring to
                         with specific funding attached,    face to face.   to phone       to phone        phone based and
4.                       with conditional obligations.                      based and      based and       contacting clients
                                                                            contacting     contacting      with advice.
                                                                            clients with   clients with
                                                                            advice.        advice.

                                                                                                                                41
General advice      Conducted as an appointment      Gateway           Referral to    Service         Service closure
      (service)           following the Gateway            could             other office   closure
                          Assessment.                      substitute this   or draft in
5.
                                                           service.          staff from
                                                                             another
                                                                             office.

                                       BUSINESS CONTINUITY RISK ANALYSIS MAP

Risk Category          Identified Key Risks          CA Comments/Actions                                     Risk Rating
                       and Issues                                                                            Low/Med/
                                                                                                             high
Finance                The service needs to close    Funded by TVBC who have traditionally provided          Medium
                       or reduce and/or its’         good support for the service. An application was
                       services due to financial     submitted to secure a 3 year SLA. This ends in
                       difficulties or insolvency.   2018. Draft budgets have been prepared and will
                                                     be reviewed against projected development needs
                                                     as business planning progresses. Reserves are
                                                     currently healthy.
                       Projects have a material      Current projects are all run on a full cost recovery    Low
                       negative impact on the        basis.
                       financial stability of the
                       service due to withdrawal of
                       funding and/or ability to
                       meet funder requirements.
Governance             Ineffective governance leads Most founding Board members have now retired             Low
                       to organisational service    and new members to The Boards have been
                       delivery and reputational    recruited. The Board is small with 9 Trustees

                                                                                                                              42
risk.                           including the Chair, Vice Chair and Treasurer. We
                                                   have 1 TVBC reps.
                   Inability to plan               A business plan has been written and Business           Low
                   effectively/make key            Continuity Plan has been produced.
                   decisions when needed
                   leads to inability to
                   complete effectively.
Management         Ineffective management          The Chief Officer has worked hard to ensure the         Low
                   leads to organisational,        new management structure works effectively.
                   service delivery and            There have been a number of issues to overcome.
                   reputational risk.              The service is working well as one unit – both
                                                   offices have slightly different working practices but
                                                   with the same outcome.
                   Poor handling of                Further changes to staff in the Romsey office have      Medium
                   employment of equality          been made successfully. New relationships have
                   issues is risking damaging      been formed with the paid team and volunteers.
                   the reputation of the service
                   or the wider service.
Service Delivery   Service delivery is adversely   Initial service delivery planning has ensured that      Low
                   affected due to lack of         service levels and quality have been maintained
                   planning, being ineffectively   throughout the merger process. Both sites and
                   staffed or poor accessibility   outreaches are suitably staffed and service has
                   and appropriateness for the     been success in continuing the outreach in
                   local community.                Romsey.
                   Equality and Diversity          The service reflects the needs of the local             Low
                   principles are not met.         community and Stand Up for Equality tools have
                                                   been used in building the business plan.
                   Premises and/or staff           The Business Continuity Plan will be invoked.           Low
                   become ineffective due to

                                                                                                                    43
terrorist attack/pandemic or
                         natural disaster.
                         Service fails to comply with   The Performance Quality framework is the              Low
                         membership agreement of        indicator used to assess membership.
                         Citizens Advice
                         Service perceived as           The service is valued by the local community and      Low
                         ineffective/inaccessible by    LA funders and new opportunities have been
                         funders/partners/clients       developed to improve access for rural areas.
                         leading to loss of
                         opportunities/threat to
                         current and future funding.
                         Service reputation reduced     Client surveys in both offices show good levels of    Low
                         by on-going poor treatment     satisfaction. No significant complaints received in
                         of clients/low professional    the last year.
                         standards.
                         Information Assurance      All staff and volunteers (incl Trustees) undertake        Low
                                                    the civil service information assurance training on
                                                    line annually and this is recorded centrally – levels
                                                    of training are undertaken depending on role
Premises             Premises not compliant with Current premises fit with requirements –                     Low
                     Equality Act requirements.     consideration will need to be given if and when
                                                    Andover moves. Care over Information Assurance
                                                    and confidentiality issues is vital
                     Reputation adversely           Current premises are accessible and well                  Low
                     affected due to lack of        presented. Recent rebranding has been effective.
                     professional public image.
Research & Campaigns Ability to influence policy on Evidence forms are produced at both sites and a           Low
                     behalf of clients is adversely new co-ordinator has been allocated and is
                     affected by lack of            working to improve this area.

                                                                                                                    44
engagement with national
                        and social policy.
Stakeholder Relations   Failure to adapt to changes    Partnerships are active and relationships with the    Low
                        in user demand and             local authority are positive and supportive. The CO
                        stakeholder expectations       has highlighted the need to build on relationships
                        leads to missed service        with agencies in the Romsey area. Plans to raise
                        development opportunities.     profile through continued networking.
Engagement with         The Service and clients fail   The office supports national initiatives. The CO is   Low
Wider Service           to benefit from the            currently involved in Hants Strategic Managers
                        advantages of being part of    Forum and the office is active in consortium work.
                        the Citizens Advice service.
ICT/Systems             Lack of ICT/Systems            Following a catastrophic IT issue in January 2018 he Med
                        effectiveness leads to         systems have been totally rebuilt with a much
                        inability to complete/adapt    higher level of security A new company now
                        to opportunities for           oversees our IT.
                        different ways of working.
Equalities, Diversity   Reputation and image           Stand Up for Equality tools to be used in business    Low
and Dignity at Work     adversely affected groups in   planning to ensure services and structure reflects
                        greatest need of advice not    local community needs.
                        catered for.
Legal Action for        Only 25% of work is checked    CATV have the recommended level of insurance to       Low
Negligent Advice        on a daily basis.              cover any complaints or legal action.

                                                                                                                   45
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