The challenge
A government agency administers a public licensing scheme across a range of licence and permit categories. It needed to be able to say which of the requirements it publishes come from the Act, and which are its own, and could not answer from its own documents.
Requirements had settled over the years into application forms, published guidance and website content rather than into policy. The only internal manual was decades old, ran to about five hundred pages, had never been formally rescinded, and cited provisions that no longer lined up with the current legislation.
The solution
- Every public-facing document checked against the legislation that governs it, in two phases: first the forms and guidance the public sees, then the operational policy officers work from.
- Each finding recorded with the passage it was found in, the provision it was checked against, and a severity.
- Findings placed as native comments inside the agency’s own files, rather than delivered as a separate report to transcribe.
- Findings that could not be matched to a specific passage handed over as document-level observations, with the reason recorded.
The impact
How serious the 163 placed findings were
| Series | Value |
|---|---|
| Critical | 7 |
| High | 23 |
| Medium | 76 |
| Low | 57 |
Critical and high are where a member of the public was being told something the law does not require. The long tail below them is what a document estate looks like after years of maintenance by people working in the time available.
A dozen or so were agency requirements written as though they came from the Act. An applicant reads those as a legal obligation, so they do not get questioned and cannot be waived by anyone who does not know the difference.
A quarter of the findings eligible for placement could not be matched to a specific sentence, because the guidance was paraphrased or spread across several places. Those went across as separate observations with the reason recorded, rather than attached to whichever line looked closest.
Delivered as the agency’s own documents marked up, a manifest of every comment and the provision behind it, and a full audit covering everything considered including what was not placed. Phase one led directly to phase two. Both are complete.
Only counts are published for phase two. The findings themselves stay with the client.