Mr Bryce is the 'author' of the 2012 edition of Protecting the Public Purse.
In this he refers to the NFA publication 'Fighting Fraud Locally'. We have met the NFA before. Their person in charge of local government said she hadn't read any council tax law, which may explain why she believes that the electoral register if 'up to date' is a reliable guide to entitlement to a 'single person discount'.
However you define this, this belief is wrong and unjustifiable. So thanks Mr Bryce for referring us to a bad source. The NFA's ideas on good practice are limited and in places positively harmful.
On your Masters they will have taught you to take 'grey literature' with a pinch of salt. In a position of power and authority working for a government agency, similar principles should apply.
In respect of council tax, this publication includes a 'case study' which repeats the false assertions about 'single person discounts' which the Audit Commission Legal Department scotched some years ago: namely that certain people are receiving a discount on the basis that they live alone. This is probably an Experian based exercise or a clone, such as those run by Capita, Northgate and so on.
According to Mr Bryce's own figures, data from over 25, 000 people was sent to the agency with this legally inaccurate information.
Well done Mr Bryce: not many people can make false statements about as many people as you did all in one fell swoop. The case study goes on to state that cases where there was an indication that there was dual or multiple occupancy were contacted. Why? It is perfectly proper to receive a discount if more than one adult is resident. Some people are said to have admitted to no longer being liable, and , on the usual but legally false allegations used by the NFI these people will be counted as 'additional income' though most of them will have been entitled to their discount. It's just that when the NFI sticks a different label on them it counts them as 'not entitled' or as a case of fraud or error.
Mr Bryce praises Gravesham Council. If he bothered to read the documentation provided to taxpayers within that council, he would note that it conflicts with the legal briefing on council tax law which he uses as a reference: you know, the one that was produced in response to complaints and which was circulated for future reference. Or perhaps nobody bothered to give young Mr Bryce a copy of that legal briefing? Has it been hidden where nobody can see it and put two and two together, perhaps?
Whereas that briefing points out that there is no duty to report changes in circumstances per se, Gravesham tells people that there is and that they may be liable to pay a penalty of £70 if they don't. Well done Mr Bryce for once again encouraging malpractice in local government.
Well done Mr Bryce. This sort of praise proves the point made over and over that the NFI actively encourages bad practice. Well done. Who want the rule of law anyway? Who wants due process and privacy and all that tosh! Spread misinformation and suspicion about innocent entitled people. Climate of mistrust. You can't trust anybody, especially government agencies: they're the worst for not getting their facts right.
This sort of thing isn't good practice, Mr Bryce. Far from it. Please obtain the legal briefing on council tax discount law provided for the information and future reference of your own department and read it.
Failure to do this would be unacceptable, as, it seems to me, you ought to be familiar with the laws governing the legal frameworks around local government finance, whereas this report strongly suggests that you are not.
Thank you.
