1 How was it for you? Consumer engagement in the post office closure programme Andy Burrows and Colin Griffiths February 2010
2 About Consumer Focus Consumer Focus is a statutory body that champions the needs of consumers across England, Wales, and Scotland and, for postal services, Northern Ireland. We operate across the whole of the economy, persuading businesses and public services to put consumers at the heart of what they do. Our public services work seeks to improve provision by promoting high quality engagement in design and delivery of services. Consumer Focus has the power to take action where markets are failing consumers and to ensure a fair deal for all especially the vulnerable and disadvantaged. We want to see consumers central to business and Government decision-making, and we work at the European level, too, to make sure consumers needs are heard in Brussels. We don t just draw attention to problems we use a strong evidence base and work with a range of organisations to champion creative solutions that improve consumers lives. consumerfocus.org.uk 02 How was it for you?
3 Introduction consumerfocus.org.uk 03 How was it for you?
4 In May 2007, the Government announced that Post Office Ltd (POL) would close 2,500 post offices, and establish 500 new outreach services. The closure programme was part of a wider package designed to restructure the post office network and return it to a stable financial footing. It was clear from the outset that the closure programme was going to prove a difficult time for consumers: the post office network is a lifeline service for vulnerable consumers, including the elderly, those on low incomes and consumers in rural areas, where the post office is often colocated with the last retail facility in a village. Post offices are used by 23 million people each week to undertake essential transactions, including accessing pensions and benefits; accessing cash; undertaking postal transactions; and making bill payments. With the post office closure programme now over, Consumer Focus, the statutory watchdog for post office consumers, commissioned research to assess the effectiveness of POL s consultation processes. During the closure programme, POL consulted on each of its closure and outreach proposals for a six-week period, as specified by Government, and bundled proposals together to form area plans drawn from multiple parliamentary constituencies. Public consultations followed an eleven-week period in which local authorities and our predecessor body, Postwatch, had the opportunity to scrutinise and seek changes to POL s proposals. In seeking to better understand the consumer experience of the post office closure programme, Consumer Focus commissioned this research to explore the following key questions: zhow effectively did POL promote awareness of its closure proposals? zto what extent did POL encourage, and actively enable, consumers to respond to the consultations with evidence about the likely impacts of proposed closures? zwere consumers fully able to take part in the consultation process, and if not, what prevented them from doing so? zdid POL do enough to: - ensure consumers understood what was proposed - make sure consumers knew how proposals could affect them - promote awareness - offer suitable means to inform POL s final decision making? zwhat lessons can be learnt to ensure POL communicates and consults more effectively with its customers, including in the event of future or ongoing changes to the network? zwhat lessons can be learnt for other providers proposing changes in the provision of essential services more widely? The research consisted of the following strands: a telephone survey of over 1,200 consumers, focus groups in eight locations across the UK, and twenty in-depth interviews with key stakeholders including MPs, councillors and local authorities. consumerfocus.org.uk 04 How was it for you?
5 Key findings consumerfocus.org.uk 05 How was it for you?
6 Consumer engagement with the closure programme was significant, with 2.7 million consumers making their views known Post Office Ltd has previously reported that it received 190,000 formal responses to its consultation, with our predecessor body Postwatch receiving another 15,000 submissions. Our research suggests wider consumer engagement with the programme was significantly higher than this, with an estimated 2.7 million consumers making their views known, through a number of means including: zsigning petitions zattending public meetings zresponding to newspaper campaigns zwriting to MPs and other elected officials The post office closure programme received an unprecedented response for a consultation exercise in recent years. The research suggests that six per cent of consumers included in the survey made their views known about closure proposals in some form. This is particularly striking given that POL reports that only 8.3 per cent of the population saw the branch they used most often close as a result of the closure programme. It is, of course, encouraging albeit not surprising that such a high degree of consumer engagement with the programme was reported. This reflects the importance of the post office network as a means of providing essential services to a wide range of consumer groups, including elderly consumers and those in rural and deprived urban locations. The post office closure programme was also a totemic issue for many consumers who were directly affected by closure proposals, and for those who invested a strong emotional attachment in keeping post office branches open, even if these consumers were not directly dependent on post offices to access key services. POL s consultation and communications strategy was poor: communications were treated as a necessary evil POL had a crucial communications role to play during the programme, in ensuring that: zconsumers were aware of each of its closure proposals zconsumers knew how to respond to the public consultation for each proposal zcustomers affected by each proposed change had sufficient information to determine how it would likely affect their future ability to access post office services z consumers were aware of the framework for the programme, its timings, and the specifications laid down by the Government in respect of implementing closure decisions consumerfocus.org.uk 06 How was it for you?
7 At the start of the closure programme, POL committed to a number of improvements to how they communicated with consumers compared to the previous Urban Reinvention closure programme. For example, POL committed to providing information on its closure proposals via its website, and consulted on the basis of once over the ground in each area that is to say, that each area would be subject to a single consultation period which enabled consumers to consider the impact of the closures in their areas during a single, consolidated period. However, our research found that consumers were strongly dissatisfied with how POL communicated information about the public consultations and closures: in our telephone survey, the average score given by respondents for POL s communications strategy was only 4.2 out of 10, with almost one in five of respondents (17 per cent) being totally dissatisfied with POL s communications strategy, awarding a score of zero. Throughout the closure programme, both our predecessor body, Postwatch, and the Business and Enterprise Select Committee repeatedly expressed concerns about the quality of POL s consultation materials, and how poorly POL consulted with its consumers. This research suggests that even at the end of the closure programme, POL had failed to develop a sufficiently rigorous communications and consultation strategy which incorporated the concerns of the Select Committee and other stakeholders, and had a built-in set of consumer-focused communications materials at its centre. Consumer awareness of and engagement with the closure programme was undoubtedly weakened as a result of POL s unwillingness to incorporate feedback from consumers, and to refine its communications materials accordingly. This resulted in a number of specific concerns, as outlined below. Despite high levels of consumer engagement, only limited activity translated into formal responses to POL s consultation As the clear experts on their communities, consumers were best placed to assess the impact of POL s proposals, and to provide the necessary evidence to determine whether closure proposals should go ahead. Despite the high level of overall engagement in response to closure proposals, it is concerning that only a relatively small proportion of wider consumer activity translated into formal submissions to POL s consultations: this is on the basis that evidence-based submissions to POL were arguably the most effective means for consumers to influence the final decisions on whether closures went ahead. As focus group recipients told us: I didn t know about the [formal consultation process] and now I do; I get the impression they deliberately did it badly so they didn t have to listen (Wrexham) consumerfocus.org.uk 07 How was it for you?
8 the fact that people responded to the consultation but felt their submissions weren t influencing anything, I think it made people a bit cynical about consultation (Belfast) Clearly, POL should therefore have done more to issue guidance to opinion formers and elected officials on the most effective means to channel consumer responses to the programme. For example, while POL were made fully aware of the strength of feeling indicated by local petitions or signature drives they received, as the consultation did not operate on the basis of who shouts loudest, such types of campaigning activity were always likely to be less effective than producing detailed and written submissions. Consumers and stakeholders did not necessarily understand this during the consultation and therefore may not have put forward evidence in the format that could have most successfully influenced POL s decision whether to proceed with a closure proposal. POL should therefore have provided guidance to stakeholders and opinion formers on the optimum forms of responding to the consultations, including the format and type and information most likely to affect its decision making in respect of each proposal. For example, POL should have developed best practice guidelines for stakeholders undertaking petition drives. These guidelines could usefully have suggested that petitions were more likely to be effective where they incorporated evidence-based submissions, in addition to signatory lists. POL should consider whether a template response document could have assisted consumers in generating more effective responses to its public consultations. For example, the Public Accounts Committee (2009) identifies that the most common reason for overturning a closure decision had been fresh information about transport links 1. More consumers could have highlighted pertinent evidence in this respect had they been provided with a template or checklist of factors they could usefully have considered when developing their consultation response. Instead, it was left to other stakeholder organisations, including Help the Aged and the Plunkett Foundation, to produce practical guidance to assist consumers and stakeholder bodies in developing their consultation responses. For example, Help The Aged developed a briefing pack for its membership base on how the closure programme would operate, and how local campaigners should most effectively respond 2. The Plunkett Foundation worked with our predecessor body, Postwatch, to produce guidance materials for communities that were considering mitigating against closures through community-based initiatives. Postwatch, also worked with members of its Post Office Advisory Group to develop guidance for local stakeholder groups responding to consultations. 1 House of Commons Public Accounts Committee (2009) Oversight of the Post Office Network Change Programme, p12. Nov Fifty-third report of session Help The Aged (2007) The Post Office Closure Programme: Briefing Pack for Local Campaigners consumerfocus.org.uk 08 How was it for you?
9 Strong consumer awareness of proposals did not translate into awareness of consultation mechanisms Our research confirms that while there was a strong level of consumer awareness that closures were being proposed, this failed to translate into a high level of consumer awareness about these proposals being subject to consultation, or how to respond. According to our findings, while 85 per cent of respondents had been aware of closure proposals in their area, only around a quarter of respondents (28 per cent) knew that POL s proposals would be subject to consultation that was open for them to respond to. This indicates that while POL worked reasonably effectively to raise awareness of closures, there was a significant failure to promote consumer awareness of the consultations on each closure, or how to best respond. While the strength of feeling about post office closures meant that many consumers and opinion formers were able to identify that a consultation was taking place, and to respond directly to POL to set out their concerns, many more consumers were unaware that each proposal was subject to a formal consultation to which they could provide input. As one focus group participant reported: Half of that information I didn t even know about [the consultation processes]. The only thing I remember is that before they actually chose the post office, the branch had a Save Our Post Office Campaign which we all signed. That was the level I saw (Dumfries) Of course, Consumer Focus cannot predict whether increased awareness of consultations would have encouraged a significant increase in the formal response rate. Neither can we suggest that an increase in awareness would have generated additional evidence that could potentially have led to different closure decisions being made. However, it is no surprise the majority of consumers who made their views known about closure proposals did so through mass-organised means, for example through signing a petition, rather than submitting evidence directly in response the consultation because POL s failure to communicate the best methods effectively meant that the majority of consumers were simply not aware this was an option available to them. consumerfocus.org.uk 09 How was it for you?
10 Recommendations consumerfocus.org.uk 10 How was it for you?
11 Specific improvements should be made to POL s consultation and communications materials for ongoing changes to the PO network Even though the closure programme has finished, changes to the post office network continue to take place, for example in the event that a subpostmaster decides to retire or POL proposes to relocate a specific post office branch. It is therefore important that POL agrees to integrate a series of recommendations to improve its standard consumer-facing materials, drawing on the comments of consumers incorporated in this research. As the National Consumer Council (NCC) noted: by getting the mechanisms wrong or closing down one or another channel organisations run the risk of shutting down user voice 3. Specific recommendations include: zpol should commit to a re-design of its standard set of communication and consultation materials, seeking guidance from consumer bodies on content and presentation za Crystal Mark for Plain English should be sought to ensure that POL s communications materials effectively reach the range of consumer groups who rely on and regularly access the post office network. As one stakeholder participant told us, the language of some of the material produced by Post Office Ltd was not exactly accessible zpol should agree to involve consumers from the outset in designing its standard communications materials, and should test the materials out prior to use, using focus groups and other research strategies to refine as appropriate. One focus group participant told us, all right, they might say they put a notice up, but it s in such small print you don t even notice zconsumers should be able to respond to consultations through a range of convenient means, including by telephone using a freephone number if they choose to do so, with the range of consultation channels actively promoted on POL s set of standard consultation materials zpol should explore whether it could develop a toolkit for consumers that offers appropriate guidance to assist consumers in developing effective consultation responses POL should provide consumers with feedback on how their views were taken into account, and how this evidence informed closure decisions It was perhaps inevitable that consumer perception of the closure programme would be driven largely by the outcome of the consultation rather than by the process itself. The reality was that the closure programme was driven by an existing decision that up to 2,500 post offices would close, meaning that the basis of consultation was to determine which, not whether, branches would shut. This was not made clear to consumers. On this basis, it was entirely foreseeable that many consumers would express concern about whether the consultation exercise could be meaningful when there was only limited scope to reduce the overall number of closures in each area. It is therefore surprising that POL failed to take sufficient steps to build awareness of and confidence in the robustness of the consultation process, including widely communicating its rationale for closure decisions. Many focus group respondents felt that the closure programme was a fait accompli: 3 NCC (2007) Our Say: User Voice and Public Service Culture consumerfocus.org.uk 11 How was it for you?
12 it s a sham the consultation period, you know: what are your views, thanks very much, we are closing it anyway. They have gone through the process and gone through the sham, but they listened to no-one because they had already made their mind up (Dumfries) it was quite a difficult process in that the consultation and the closure process had been set up with little room for manoeuvre [...] there was a general consensus this was a fait accompli (Devon) This view was also widely expressed by elected representatives, for example Richard Bacon MP (South Norfolk), who responded to the Public Accounts Committee report with the concern that: because the number of closures had already been fixed, the few people who knew about the consultation period saw it as little more than giving the closure programme a thin veneer of legitimacy While POL prepared a decision document that set out its rationale for proceeding with its closure decisions, and made this available online and to key stakeholders after these decisions were announced, it is disappointing that this was not issued as a matter of course to consumers who had formally responded to the consultation, or to those who had organised or attended public meetings. Many consumers were therefore unaware how and consequently whether POL had taken account of the evidence received during the consultation, and how this evidence was used to reach its eventual decision. As one stakeholder told us: it s good practice in consultation work to go back to respondents and explain how their key points have been followed through one way or another. However, we got no detailed feedback at all, and at the very end of the process, when we were consulting on one specific branch, I didn t know they had decided not to close the branch until I read it in the local newspaper. Given that we had put a lot of work into making a submission and so on, that was poor. consumerfocus.org.uk 12 How was it for you?
13 In the event of future closures, POL needs to change this approach. Consumers may still disagree with the decision to close, but are more likely to understand and adjust to those decisions if it is clear that the consultation process to determine this decision was sufficiently robust, and if the rationale by which the decision was reached is explained clearly to them. A comprehensive summary of POL s decisions should made available to consumers in branches, rather than having to access POL s decision document online. At the very least, this would promote confidence in the robustness of POL s consultation process, as well as allowing the 40 per cent of households that do not currently have internet access 4 to access the information. A summary of how POL reached its decision should be made available to every consumer who responds to the consultation; be issued to attendees at public meetings; and also form part of the in-branch communication materials used to communicate the closure. In the event of a future closure programme, the length of consultation should reflect the needs of communities Before the closure programme, our predecessor body Postwatch argued strongly for a twelve week public consultation period. While it agreed to work within, and to do the best it could to promote consumer engagement within the six week period decided by Government, our research confirms that a significant proportion of consumers (48 per cent) felt six weeks was an insufficient period to respond to the consultation as effectively as they would have liked. According to the research, 53 per cent of respondents consider that between 11 and 12 weeks is the optimum period for consumers to be consulted on closure proposals, with 20 per cent favouring a consultation period of between eight and 10 weeks. Only one per cent of respondents favoured consultations lasting only six weeks. The six week period for consultations during the closure programme underlined the importance of POL deploying effective communications materials, to ensure consumers readily understood the closure proposals and could make the most of the six week period to prepare their response. POL s failure to do so therefore exacerbated the problems caused by a limited consultation period. As stakeholder participants told us: it was a challenging timescale, which meant that the consultation was curtailed we have a monthly schedule of meetings and the consultations normally go the full council meeting. If the consultation had come in say the week before, it would have missed our deadline for the agenda going out, and then it would have been the following month 4 House of Commons Business and Enterprise Committee: Post Offices Securing Their Future. June P.4 consumerfocus.org.uk 13 How was it for you?
14 Consumer Focus has two concerns about the length of the consultation period: firstly, that a six-week period risked consumers believing that decisions had been taken in advance, and that the consultation was not being undertaken in good faith. Secondly, six weeks was undoubtedly a challenging timeframe for consumers and stakeholder groups to respond, particularly those who intended to submit the detailed submissions which were more likely to result in changes to POL s proposals. Consumers needs should have primacy in determining the appropriate length of consultation on proposed changes to the post office network. In the event of a future closure programme of such scale and complexity, Consumer Focus therefore strongly believes that a consultation period of longer than six weeks and ideally 12 weeks is necessary for consumers to plan and prepare an effective consultation response. The framework of the programme was sound, but the purpose of and changes achieved during the pre-consultation phase should be communicated more effectively There were several stages to the post office closure programme, with local authorities and our predecessor body having the opportunity to scrutinise POL s proposals and seek changes as part of an eleven-week period prior to public consultation. Over 240 of POL s original proposals were changed during the pre-consultation phase as a direct result, the proposals entering public consultation had consequently already been amended in the consumer interest. For example, many proposals were withdrawn, or POL agreed to undertake capacity or accessibility improvements at other nearby post offices if closure proposals went ahead. The framework of the programme, with the pre-consultation period designed to ensure the optimum plans entered public consultation, arguably led to better decisions being taken, but equally restricted the scope for widespread changes as a result of public consultation. Our research suggests that stakeholders welcomed the introduction of an information gathering stage prior to the public consultations getting underway, but consumers were cynical about whether this meant that POL s decisions had already been taken before public consultation had started. In the event of a future closure programme, and to avoid the concerns expressed by the Public Accounts Committee (2009) that the whole process of consultation will be brought into disrepute if key questions [such as the total number of closures] have already been determined 5, POL could seek to better communicate the purpose of and changes made in the pre-consultation phase at the constituency level, in order to: zincrease understanding of and support for the pre-consultation process zreduce consumers concerns about the value of the consultation process zencourage responses during public consultation to be focused on the specific proposals, rather than on the perceived shortcomings of the programme as a whole POL should have also communicated more effectively the consequences of a closure decision being overturned: that is to say, that it was possible that another post office could be proposed for closure in its place. Many consumers were not immediately clear of this from the outset, and this consequently damaged the perception and standing of the closure programme. 5 House of Commons Public Accounts Committee (2009) Oversight of the Post Office Network Change Programme, p12. Nov Fifty-third report of session consumerfocus.org.uk 14 How was it for you?
15 Outreach consultations must be consistent and detailed In the early stages of the closure programme, POL consulted on the principle of installing outreach post offices, but failed to provide key operational details for example, the opening hours, location, and range of services to be provided. Following the intervention of our predecessor body, and on the basis that it was important consumers fully understood the changes POL proposed to make, POL consulted on specific proposals instead. Our research finds that since POL has moved to consulting on specific proposals, consumer understanding and awareness of outreach services has increased significantly, with 39 per cent of respondents aware of outreach services, compared to only 17 per cent of respondents when Postwatch undertook similar research earlier in the closure programme. In the event that further outreaches are deployed in response to ongoing changes in the network, it is clearly important that POL makes further improvements to its consultation materials, which in turn will allow consumers to engage much more effectively in the development of these services. Consumer Focus therefore calls on POL to assess the effectiveness of the outreach consultation materials as part of its wider examination of the introduction of outreach services. It is encouraging that a number of stakeholders interviewed for the research reported that consultation in respect of outreach proposals proved to be genuinely constructive: I think that [a number of the villages which were proposed to get an outreach service] were to have a twice weekly mobile van, and that is another thing... the Post Office and Postwatch turned up at one village... and they said, oh we will park the van at such and such a place, and local people said you can t park it there, it s a bus stop!. Well. We will park it across the road then... you can t park it there, that s parking for the council houses... There was a certain value in that just for the Post Office turning up and hearing local people say well you can t do that, you can t do that. They listened and I have no complaints about that Wider lessons for consultations on the delivery of essential community services The consumer experience of the post office closure programme represents an important opportunity to identify improvements in the event of future consultations on proposed changes to the post office network. It should also be used in respect of consultations on other proposed changes to the delivery of essential community services. It is seemingly inevitable that severe pressures on the public purse will translate as cuts to public services in the coming years. It is therefore vital that the consumer voice is both present and listened to in any debate over the nature and level of cuts, especially in decisions over how and where changes will be made at the local level. Our findings offer important and timely lessons in this respect, and offer a number of lessons for effective large-scale consumer engagement. consumerfocus.org.uk 15 How was it for you?
16 Consultations on future changes to service delivery should be designed to channel consumer views effectively consumers should have the chance to respond on the issues that matter to them The post office closure programme operated on the basis that the Government had already consulted on proposals that up to 2,500 post offices were to close. As such, the purpose of local consultations was to determine where as opposed to whether closures would take place, and to ensure that POL could implement these changes with consumer detriment being minimised. However, it was clear that many consumers would inevitably respond to closure proposals in their area on the basis of wanting to contest the principle of the decision, rather than the basis of consultation as set out by POL. The effectiveness and consumer experience of consultations would likely be weakened as a result. In the event of a future closure programme, or other proposed changes in service provision, the Government and/or service provider should ensure that the design of local consultations reflects and is fully geared towards the range of consumer responses that are likely to be generated by the consultation taking place. As public consultations during the post office closure programme set out only to capture responses on the impact of discrete proposals, rather than the principle of whether these closures should happen the starting point for many consumers there was always bound to be some disconnect between the design of the consultation and the range of responses this was likely to generate. Indeed, in its report into the handling of the post office closure programme, the Public Accounts Committee (2009) concluded: one of POL s aims in the consultation had been to establish that the facts on which it had based closure proposals were correct [...] If respondents showed that the proposals were based on factually incorrect information, then changes were made to the plans. However, while much of the campaigning had been made about the principle of closing post offices at all, the consultation had been around whether the facts on which individual decisions had been made were correct 6. 6 House of Commons Public Accounts Committee (2009) Oversight of the Post Office Network Change Programme, p12. Nov Fifty-third report of session consumerfocus.org.uk 16 How was it for you?