Official Report: Minutes of Evidence

The Chairperson (Mr Gildernew): We are joined this morning by Heloise Brown, who is the acting director of social housing policy and oversight; Sorcha Hassay, the acting deputy director of social housing policy and oversight; and Martina Campbell, who is the head of the local government finance team. Tá fáilte romhaibh uilig.

Thank you for attending the Committee. I think that you, Heloise, are going to make a brief opening statement, after which Committee members will ask questions.

Ms Heloise Brown (Department for Communities): Thank you very much for the opportunity to brief the Committee today on the Department's contribution to the Department of Finance's Administrative and Financial Provisions Bill. A written briefing on clauses 12 and 13 was provided to the Committee on 19 September, so I will give you an update on the provisions on social housing tenancy fraud, which come under clause 12,. Martina will speak to clause 13.

The proposals in clause 12 stem from recommendations in reports on tenancy fraud in social housing by the Public Accounts Committee in 2014 and the Northern Ireland Audit Office (NIAO) in 2013. Both reports recommended establishing a single tenancy fraud team to provide investigative services to the Housing Executive and the housing association sector in order to enable economies of scale and more effective investigations, as opposed to the requirement for each landlord to operate their own investigation.

Following the issuing of the two reports, a team was established in the Housing Executive to carry out tenancy fraud investigations for its tenants. Over the years, that team has built up considerable expertise in the investigation of tenancy fraud, although it has focused only on Housing Executive properties. Under 'Managing Public Money Northern Ireland', the Housing Executive has been unable to use its own resources to undertake investigations on behalf of registered housing associations, so the Department considered whether housing associations may be charged for that service by the Housing Executive. We were unable to identify a legislative provision already in existence that would enable the Housing Executive to recover the costs of providing such a service, so a need for legislative provision was identified. In addition, the PAC report mentioned strengthening legislation on data sharing. Clause 12 is a step to addressing that, allowing for an exchange of information between the Housing Executive and housing associations for the purpose of investigating a suspected case of tenancy fraud. The Department is considering further legislation to strengthen the data-sharing protocols further.

I will very briefly run through the subsections in clause 12. Members have a summary of what each subsection does, but I ask you to note in particular clause 12(2), which sets out the various types of tenancy fraud that the Housing Executive will be able to investigate on housing associations' behalf, including where "an application for a tenancy" or:

may be "false in a material respect"; where a tenant may have ceased:

where there is:

and where:

may be "false in a material respect".

As you will know, housing associations no longer operate the sale scheme, but there is provision in legislation for them to operate voluntary schemes, so the provision is in the Bill in case a voluntary scheme should come into practice in the future.

Clause 12(5) permits a housing association to disclose relevant information to the Housing Executive for the purposes of carrying out an investigation, while clause 12(1) permits the Housing Executive to report to the housing association as to whether tenancy fraud has occurred and whether any offence has been committed in connection with that occurrence. Clause 12(6) provides for the report to:

while clause 12(7) and (8) state that a disclosure will not breach data protection legislation where the powers in clause 12(5) and (6) are taken into account. There is therefore provision there, although there is also recognition that a breach cannot take place of the data protection legislation. Effectively, that enables the sharing of relevant data from a housing association to the Housing Executive and for the Housing Executive to report back to a housing association with any appropriate information on the results of its investigation. It is then for the housing association to determine its next steps, based on that information.

In preparing the clause, the Department undertook a targeted consultation with housing associations and other housing stakeholders, including Housing Rights, which was supportive of the proposals generally. The results from the consultation are being considered in order to inform a wider review in the Department of how to tackle tenancy fraud in social housing. The review will include whether additional powers are required through, for example, a housing Bill.

To sum up, we emphasise that the work is about ensuring that social homes go to those with a rightful entitlement, based on an assessment of objective housing need. The focus is on ensuring that the system is not manipulated and that homes are not misused for private gain. Ultimately, the purpose of tackling tenancy fraud is to help address housing need and to ensure that the best value for money is achieved from the Executive's significant capital investment in social housing.

That concludes my opening remarks on clause 12. I am happy to take questions.

The Chairperson (Mr Gildernew): Thank you. I have a couple of quick questions. What is the current level of tenancy fraud in housing association properties, and is it higher than in Housing Executive properties?

Ms Brown: It is a little bit lower, because the housing associations have a smaller number of properties. The Housing Executive has 83,000 properties, while the housing associations have in and around 40,000 properties. In 2024-25, the Housing Executive reported 272 confirmed cases of fraud, while the housing associations reported 103 cases.

The Chairperson (Mr Gildernew): Does that represent a difference in percentage terms if you equate the number of properties that each has? In percentage terms, is tenancy fraud higher or lower in housing associations?

Ms Brown: Part of the variability, and this is why I often speak about consistency, is that there are 19 housing associations, each with its own procedures in place. The regulator ensures that they have tenancy fraud strategies in place, but they all have different levels of resource, because they operate on very different scales. We could look at exactly what the percentage is, but that would not give us a very clear picture of the level of tenancy fraud in housing associations. Some of them are quite large and have economies of scale, so their percentages may be better. Some of them are very small and feel that they are community organisations that know their tenants, so their percentages may differ again. If it would be useful, we can certainly look at getting that information for the Committee, but I would attach a few caveats to it.

The Chairperson (Mr Gildernew): I understand the caveats, but it would be helpful to understand the percentages.

In general terms, are you confident that the measure will increase the number of housing association properties that are recovered and made available?

Ms Brown: Yes. In order for people to see that landlords are serious about tackling tenancy fraud, there is certainly a sense that investigations must be taken as far as is possible. That will make sure that there is a clear message being sent that tenancy fraud is not acceptable and that more complex properties can be recovered.

There will always be cases in which it is shown that someone is rightfully occupying a property and has a right to be there, because it is their home. It will therefore depend on the circumstances. There may be more recoveries if a more consistent approach to investigation is taken. The Housing Executive team has built up a lot of expertise in that area, so we certainly expect there to be more recoveries. I say that with the caveat that some non-recoveries occur because people are rightfully in their home, and it is not a case of fraud.

The Chairperson (Mr Gildernew): That takes me on to my other point. Tackling succession fraud is important, but there seem to be a lot of cases of genuine succession rights being denied. How can we ensure that, while fraud is being dealt with, genuine cases are looked at and changes are made by planning for such cases?

Ms Brown: As you say, there is a lot of interest in that. The way in which to address it is through the succession policy. We speak to landlords, and they are applying the policy. In some cases, there are provisions in place for a succession that depend on the person in the property being aware that succession has taken place. Perhaps some of it is about ensuring better communication with everyone who occupies the property. There may be different ways in which to address that.

The Chairperson (Mr Gildernew): I appreciate that succession planning seems to be an area that needs some attention.

Finally, you touched on the review that is taking place and its scope. You mentioned that one of the issues being considered is introducing additional powers. Can you give me any further sense of the scope and remit of the review and of when it will be completed? When can the Committee expect to see the feedback from that review?

Ms Brown: We hope that there will be a consultation within months, so by the end of the calendar year. We certainly hope that the review will keep to that timeline. There is learning to be had from the PAC and NIAO recommendations in order to make the process more consistent when we talk about fraud, recovery or abandonment and to make sure that landlords are using those terms consistently.

So there is a bit of work there that is non-legislative; it is not just about how we monitor that practice.

For about 10 years, England has had provisions around legislation against subletting in particular, which makes it a criminal offence, and making something a criminal offence brings you into different levels of protection in the data that can be shared and the investigative powers. If there is a question, for example, around sharing information with utility companies, that becomes much more straightforward when something has been made a criminal offence. That is one of the things that we expect to look at in the consultation that is coming soon — whether making it an offence will enable better detection and more recovery than under the current system.

The Chairperson (Mr Gildernew): Thank you, Heloise.

Ms K Armstrong: Thank you very much for the work on this, and I appreciate that your time is tight to get a response back to the Department of Finance. The Housing Executive will be able to investigate tenancy fraud for housing associations and will be able to charge a fee. Are there any thoughts on how that fee process will work, or costs or anything like that, at this stage?

Ms Brown: It is still at a very early stage because, as you can imagine, that was an area where the housing associations had a lot of questions. The Housing Executive can estimate what its costs will be, so, for example, to achieve full cost recovery, what it needs to raise from housing associations. We are still in discussion with them. We are looking at different options about how the charges are scaled, as you say, for a very small association compared with the larger ones. It is a small amount when it is shared between a larger number of organisations. If it is proportionate; it would be a very small proportion of the annual rental cost of a property.

Ms K Armstrong: I am thinking down the line a bit. If tenancy fraud is found, for example, in a housing association property, how does that tie back to reporting if housing benefit is involved? I take it, then, it will be for the housing association to make right in whatever legal process, so there will be costs involved there and, obviously, costs involved with involving housing benefit teams. Has that been worked out yet?

Ms Brown: On the housing benefit side, there is good communication on fraudulent activity around tenancy fraud and housing benefit. Those lines of communication are there, because the Housing Executive is operating the housing benefit payments. For a housing association, when that information goes back to it from the Housing Executive to say what the investigation has found, it will then be for the association to decide what to do. It may be that it simply recovers the property, or it may feel that it has the evidence, with the support of the Housing Executive, to bring a prosecution. We have left that in to allow that because, if there is later legislation for a criminal offence, the Housing Executive can consider those whole costs, but it is for a housing association to determine whether it has the resources and the willingness to bring a prosecution forward if there is legislation. At the moment, any prosecution would be under the Fraud Act 2006, because there is no specific tenancy fraud offence.

Ms K Armstrong: I imagine that the Housing Executive will not be going into every housing association and testing all its properties and tenancies. If a housing association is bringing this to the Housing Executive, it knows rightly; it has done its own pre-investigations. What legal ability will the Housing Executive have to direct the housing association, or to remove the tenant from the property, if there is fraud?

Ms Brown: It will always be for the landlord — the housing association — to remove the tenants. The Housing Executive can have its own data sharing protocols in place with other companies, for example. It may be able to get more effective data sharing, as a public-sector organisation, than a housing association would. We envisage that a housing association will still do its preliminary investigations; for example, looking at somebody going in and out of the property and who that person is. At the point that it feels that it does not have the powers or the expertise to do that in a way that could ultimately support a prosecution if a prosecution were to take place, that would be the point at which it may decide to ask the Housing Executive to step in. The Housing Executive will have a team, quite often with very specialist backgrounds, so it can bring a standard where, if it came to court, it would be more likely to stand up.

Ms K Armstrong: Finally, I do not see what the potential penalties could be if a person is found guilty of tenancy fraud. Have you any thoughts on that?

Ms Brown: At the moment, because it comes under the Fraud Act, there have not been prosecutions, because it is difficult to prove. Under the legislation in England, it is basically a fine for unlawful subletting, and there can be unlawful profit orders as well. The legislation provides for that. If there is evidence that somebody has profited from subletting a property, that can be recovered by the landlord. There is that, and there is a fine if the criminal offence is established.

Ms K Armstrong: So the landlord has to recover that cost.

Ms Brown: Yes.

Ms K Armstrong: Although the Housing Executive may have found the person guilty, it will be for the landlord to recoup that loss.

Ms Brown: Yes, in effect, because it is their property. It will have been their asset that was misused. Again, the Housing Executive is still doing that on a cost-recovery basis.

The Chairperson (Mr Gildernew): Before I come to Maolíosa, I just point out that we are going to hear about clause 13 and then we will take more questions. Bear that in mind for timing. Anyway, we are OK.

Mr McHugh: Tá fáilte romhaibh anseo inniu.

From reading the presentation today, I have a sense that the greater responsibility is with the Housing Executive and that the housing associations have a duty to provide information. It is nearly as if they have been included incidentally. To what extent are they actually expected to be proactive in identifying tenancy fraud?

Ms Brown: They certainly are expected to be. They will all have tenancy fraud strategies in place, and the regulator, as part of the Department, will check that they do so in the procedures that they are required to have in place. Where we will see a benefit will be in more consistency so that the thresholds for when the associations feel that they need to push on a particular area are more consistent and for when they refer a case to the Housing Executive, once they can do that, are more consistent. I think that we can drive a bit more consistency with those kinds of measures in place.

Mr Durkan: Thanks for the presentation. I am glad to see that steps are being proposed and being taken to improve and make more consistent the approach to tackling tenancy fraud. I think that you said that there are about 400 cases in total — 270 Housing Executive cases and 130 housing association cases. Have you a breakdown of what percentage of them were succession fraud and what other fraud types were in that mix? Further down in our documents, I see that, in the last financial year, the Housing Executive had 752 new cases of suspected tenancy fraud. It would be good to get a breakdown of how many of those are succession fraud, how many are to do with the likes of subletting, how many are others and what others there are. I think that this is maybe just the tip of the iceberg. On succession fraud, the standard of investigations seems very high. It is a prolonged procedure with a lot of resource put into it. It is like 'The Wire' or something, with the depth that people go into with those investigations. A problem with that, as the Chair said, is that often it is innocent people making a succession claim. They are all treated with equal suspicion.

Another issue is that this should remove inconsistencies, but there are huge inconsistencies in how the housing associations and the Housing Executive tackle fraud where people are not necessarily subletting their property but are not occupying it either. People are allocated a house, we have a waiting list approaching 50,000 people or families, and those people do not take up occupancy. They just want a separate address for whatever reason. Others will occupy it every now and again if they are having a party, and the level of investigation of that is in stark contrast to the standard of investigation into succession fraud. A housing association or even the Housing Executive will just write a letter to the tenant and, if they get a reply, they will say that that is confirmation that the tenant is living there, when other people who are living in the street will rarely see anyone going in and out of the property.

The Chairperson (Mr Gildernew): Kellie, do you have a wee supplementary question to that?

Ms K Armstrong: No.

The Chairperson (Mr Gildernew): It is separate? Go ahead, then.

Ms Brown: We can certainly get you a breakdown of the tenancy fraud types for the Housing Executive. I am not sure that we would have exact classifications for abandonment and succession, but we can provide a bit more information about the breakdown.

The focus on succession is partly an element of the fact that sometimes the person trying to succeed to the tenancy is not already an applicant. They may be on the waiting list or they may be homeless, but they could also be somebody who the Housing Executive has no knowledge of. Therefore, it has to follow the due process and make sure that there is entitlement there. If it is a statutory succession, that person can have a right to it, but the Housing Executive has to check. The same applies to policy succession.

Non-occupation can be one of those areas where a property may be perceived to be empty. If somebody is working abroad or they are in hospital for a period of time, a property can rightfully be empty. Those circumstances may not be known to people who are reporting. That is why, again, it is really important that we have a consistent approach across the social sector to looking into those and reporting on them. The drive for the review that is coming up is to make that process more consistent. We can get you the information that we have on the breakdown of the different types of fraud that are currently recorded. However, I suspect that it may be more around whether a property has been abandoned or whether it has had to be recovered and the level that it has had to go to in order to recover it. It might be that kind of information, rather than the cause. Hopefully, that will be helpful to you.

Mr Durkan: Thank you. Kellie touched on a point around penalties. I am thinking of the likes of one of those non-occupation cases, if we put it like that, and what the penalty might be, because the property will be recovered from that person. They will have been awarded the property in the first place by virtue of being top of the list, and now they will have homelessness points again because the property will have been recovered, so they will be awarded another new property.

Ms Brown: If a property is recovered because they are not the rightful tenant, they can still be on the list. On that person's individual right, you would still come up against whether something has been proven against them. Again, that comes back to whether it goes to court and whether we can say that there has been misuse of the asset — of a home, in that case. If somebody is not the rightful tenant, they could be on the waiting list. They could be homeless, and they could have points and be waiting to access a property while they are also not fully accessing it.

Mr Durkan: Sorry, there are crossed wires here. I mean the actual tenant. Although they might not reside in the property, the person who has been allocated that home and does not make use of it, if not necessarily for financial gain, is far from victimless when we have tens of thousands of other people desperate for homes.

Ms Brown: Again, that is where that stronger process and that consistency in being able to follow through and establish the facts along the lines of a criminal investigation, even if it does not proceed to taking somebody to court, will be helpful. That will inform decisions that the Housing Executive can make around eligibility for social housing and whether that person can rightfully access a tenancy or whether they have been involved in behaviour that makes them unsuitable to be a tenant. There are actions there, but this is a first step in us getting our house in order to have a new and more thorough approach to it.

The Chairperson (Mr Gildernew): Heloise, there has been some really good engagement and answers, but, in the spirit of an earlier discussion that we had, I point out the question mark around the categories. I would have thought that that was a fairly basic one that officials would have thought of in advance. I am very keen to hear that information about the categories. That is really important. It is just to point that out.

Ms K Armstrong: I know that there is a review ongoing of tenancy fraud procedures. That becomes very important when we think that the Housing Executive is going to be marking its own homework on this. What processes are being considered to test how the Housing Executive is looking at its tenancy fraud? It feels to me like quite an expensive process for landlords if they have to evict tenants and have to go to court and things like that. When are we expecting that review of tenancy fraud? Does it deal with the Housing Executive marking its own homework?

Ms Brown: The Housing Executive will learn, because it is a member of the UK-wide Tenancy Fraud Forum and will be involved in local tenancy fraud forums. It is learning from and feeding into some of those national-level discussions on things like the methodology of calculating the cost of tenancy fraud, and there has been quite valuable information coming from the Housing Executive. The Housing Executive is operating at a very strong level and has a good reputation at UK level with those tenancy fraud forums. I expect that the Housing Executive will contribute quite well in helping the housing associations and providing support to develop their processes. We are looking at things like making more standard data protection impact assessments and sharing information. That is led by the Housing Executive because it has that economy of scale.

Ms K Armstrong: I have a little bit of a concern about it being led by the Housing Executive, which is the biggest landlord in Northern Ireland. When the Housing Executive is checking its tenancies for fraud, it is checking its own tenants. I know that there is supposed to be a brick wall between the two sides of the Housing Executive, but is oversight going to be put in to make sure that the Housing Executive is being as rigorous with itself as it is with housing associations?

Ms Brown: We can look at that. It is essentially a landlord function, so it is on the landlord side of the organisation, but it will certainly appear in things like the Housing Executive's quarterly and annual reporting and its business plans. It certainly reports on that, so it is open to scrutiny and, in fact, is open to more scrutiny because it is a public-sector organisation. That is one of the things that we will be keen to focus on as part of our oversight.

Ms K Armstrong: Thank you.

The Chairperson (Mr Gildernew): It is a valid point.

Mr Bradley: I will be brief. Kellie mentioned — she must be reading my notes — the length of time that it takes the Housing Executive to deal with tenancy fraud. A property may be empty and the tenant may have a partner in another council area and be living out of the area. There are all sorts of reasons why a house can become vacant. However, it takes a long time, and the Housing Executive has to go through a lot of hoops to prove that the tenant is not actually living there. Will that be addressed as part of the review that will streamline the process? It is the process that makes it difficult. It is not the people who are not living there; they are easily identified. It is the process of getting that property back into the Housing Executive.

Ms Brown: We expect that. If the proposals for the Bill make a public statement about taking tenancy fraud more seriously, that will open doors for better information sharing with utility companies and telephone companies — the other information that will standardise it and make it a bit quicker and easier to get the information that they need. It is about getting support behind it and the weight of legislation behind it.

Mr Bradley: That will be important.

The Chairperson (Mr Gildernew): Back to yourselves, Heloise. We are moving on to clause 13.

Ms Martina Campbell (Department for Communities): That is me.

The Chairperson (Mr Gildernew): Be quite brief, and then we will have some questions. Thank you very much.

Ms Campbell: Hopefully mine is a bit more straightforward than Heloise's.

One of the recommendations of the recently published review of the role and responsibilities of councillors in Northern Ireland was that responsibility for setting the amount of the basic allowance paid to councillors should be removed from councils and instead passed to DFC. At the moment, the power, as it stands, allows DFC to set the maximum level for the basic allowance, and councils then decide the amount of the basic allowance to pay up to that limit. This results in councillors being paid different allowances depending on the council that they serve. This amendment will remove that flexibility for councils to pay less than the maximum. It is implementing one of the recommendations of the independent review and will ensure fairness for councillors so that they are all paid the same rate for doing the same job, irrespective of which council they serve. The Minister, with Executive agreement, accepted that that was a reasonable recommendation and agreed to implement it as soon as possible. The Administrative and Financial Provisions Bill was identified as a suitable legislative vehicle because it is, strictly speaking, a technical amendment. It is not a new power.

I am happy to take any questions.

The Chairperson (Mr Gildernew): Thank you, Martina.

Mr McHugh: Martina, as an ex-councillor, I have always been of the opinion that, for those who do their job, it is never enough, and for those who do not do their job, it is always too much. Will the Department consider developing a body that is totally independent of government, such as the independent financial review panel, to oversee what is paid to councillors and to standardise that throughout all the councils here in the North of Ireland?

Ms Campbell: Yes. Strictly speaking, the review was independent; it was conducted by an independent chair. There are powers in the Finance Act to set up a remuneration panel. Certainly, in looking at implementing all of the other recommendations, that is one of the issues that we will be considering.

Mr McHugh: The independent review panel would then, in fact, have the power to say, "This is what councillors should be paid", as opposed to it actually being a decision taken within the Department itself.

Ms Campbell: The panel made a recommendation which the Minister, in trying to strike a balance in the current economic climate, did not feel was a fair reflection of public-sector pay across the board. The panel recommended an increase in the region of 28·8%, whilst other public-sector pay was in the lower range, so, in striking that balance, the Minister decided that a 5% pay rise was appropriate.

Mr McHugh: The point that I keep making, to come back to it again, is this: is it possible that they might consider arriving at a situation whereby you take it out of the hands of the Minister himself from making the decision and that it is actually a decision taken by the independent review panel?

Ms Campbell: I suppose that we could consider that, but it would probably require an amendment to the legislation at some point in the future. We will certainly consider it, yes.

Mr Bradley: Chair, I will be brief. I have no issue at all with the councillors getting a raise, but Maolíosa has touched upon a point there: there are some councillors whose allowance is not enough for the work that they do, and there are others for whom, quite rightly, it is far too much for what they do. It is a part-time role, so what checks and balances are in place in local councils to ensure that the people who are elected and are paid are actually doing a job? There are no checks and balances; it is the only part-time role that I know of where there are no criteria for how you do your job.

Ms Campbell: That is certainly not something the Department can intervene in. It is obviously for the electorate to decide whether a councillor is fulfilling the role that they elected him or her to. I do not think there is anything that we can do. Certainly, the review found that almost 80% of councillors had either a full-time job or a part-time job, which confirmed that the role is a part-time role. I will have to come back to you on whether there are any other checks and balances, but nothing is coming to mind other than the parties and the roles of the Whips, party leaders and constituents.

Mr Bradley: And the people who are not in parties. We will leave it there.

Ms Campbell: Oh, yes. OK.

The Chairperson (Mr Gildernew): I could go further than that, Maurice. [Laughter.]

Mr Bradley: I will leave it there. Thank you very much.

Ms Mulholland: I welcome any opportunity to get a bit of consistency across council decisions on this. No public representative should be involved in setting their own pay, whether they are MLAs or elected representatives. The disparity between councils over the past nine years has been evident whereby some have elected to take a pay rise and others have not. We have then ended up with councillors in different boroughs being paid different allowances, so we absolutely welcome this.

We are also interested in the proposition that Maolíosa put forward about taking the decision out of the Department, akin to the remuneration board that MLAs will have. There is merit to taking it out of the political realm. I am my party's local government Whip, and the feedback that we have had over recent weeks and months has been clear in that this should not and cannot become a full-time role, because it would eliminate quite a few people from taking on the role. You have just said that 80% of people have other jobs, and that is the joy of having different levels of government and different approaches to levels of government. As a party, we supported the Minister's recommendations at the Executive in what he took on board from that independent review, which was to look at an equitable increase for councillors in line with other public service bodies. That was a fair decision. Like others, though, we cannot underestimate the work that goes into being a councillor. Quite a few of us on the Committee have been in that position. We support Maolíosa's suggestion of looking at proposals that take it outside the Department, make it independent, and we also support a consistent approach across councils.

Thank you so much for this piece of work. It is really important, and it speaks to the heart of equity across our local government.

Ms Campbell: Thanks.

The Chairperson (Mr Gildernew): Thank you, Sian. Thank you, members, for that useful discussion. I agree with Maolíosa on the idea for an independent body. Also, Sian raised an important point about people who are doing other things being able to be involved with local government in our democratic process. I am keen that remuneration should ensure that we get a diverse range of representation — that we get people with disabilities and support them properly to allow them to be councillors and represent people — people who have caring responsibilities, people who may live in rural areas with poor public transport. Whatever remuneration we come up with should ensure that this is reflective of community and society, as all levels of government should be.

This is useful work for the future. It is great to see the Committee putting forward proposals and to see yourselves taking account of those and looking at how they could be worked into future work.

Mr McHugh: You said that 80% of councillors had some other source of income. That is because council income in itself is not adequate. It does not mean to say for one second that they are not doing a full-time job as a councillor. Very often they are, and they have to look to some other source of income to complement what they receive at present.

Ms Campbell: That is quite true. The independent review survey had a high response rate — 62% of councillors — so the results have some degree of credibility, I guess. A lot of them indicated, as you rightly said, that out of necessity they had to look to some other source of income. Also, the Chair spoke about attracting people from manual labour-type jobs, whose employers are not as flexible as those who maybe work in white collar-type jobs. There was a lot of useful information in the survey that we are looking at as we move through implementation of the recommendations.

Ms K Armstrong: I have a very quick one. Any future decisions on councillors' pay will have an impact on local rate-setting. Is there potential to clarify in guidelines or regulations that the decision should be made by September, for instance, to allow the councils to include that as part of their rate-setting process?

Ms Campbell: We are very much aware of that, but the problem is that, in general, the yearly increase to councillors' allowances is tied to the settlement of the National Joint Council pay scales for council staff, so it depends on when that pay settlement is —.

Ms K Armstrong: It makes it difficult for a council to backdate. Having been a recipient of that, I know —

Ms Campbell: We hear all about it. [Laughter.]

Ms K Armstrong: — that it makes it difficult.

Ms Campbell: I fully appreciate that, but the finance officers will be able to look around to see what the general average public-sector pay settlements are, when trying to input to the planning document that they will provide to council, and use that as a guide. It will not be perfect, but it will be close, unless there is a review or something like that, which would give something that would not be the norm, if you like. We have committed to doing an independent review in seven years' time.

Ms K Armstrong: Thank you.

The Chairperson (Mr Gildernew): Thank you, Martina, Heloise and Sorcha. I appreciate that, and I look forward to seeing further work in this area.