 Good morning. I would like to welcome everyone to the sixth meeting of the Standards, Procedures and Public Appointments Committee in 2024. I have received apologies from the convener, Martin Whitfield MSP. Our first item today is for new members to declare any relevant interests, so welcome Jackie Dunbar MSP as a new committee member. Jackie, do you have any relevant interests to declare? At this point, the only register of interests I would have would be that I was a former councillor for Aberdeen City Council up until May 22, because I believe that we are going to be discussing the elections further on. Thank you very much, that has been noted. Our next item is for the committee to agree whether to take items 4 and 5 in private. Agenda item 4 is consideration of the evidence heard in the evidence session of the commission for ethical standards in public life in Scotland. Agenda item 5 is consideration of the correspondence that the committee has received. Are members content to take these items in private? Our next item for today is for the committee to hear evidence from the commissioner for ethical standards in public life in Scotland. I would like to welcome Ian Bruce to the meeting, and I would like to invite the commissioner to make some opening remarks. Thank you, convener and members of the committee, for the invitation and the opportunity to talk to you about the work of our office. I am keen to ensure that the committee is fully informed about my offices and my own performance, so I will keep my opening statement very brief to allow as much time as possible for questions. I will ask the committee an informal briefing in September of last year due to a change in membership. I hope that you are all enjoying your new role. I trust since then that you have reviewed our last annual report and our annual report and accounts, and that those will have given you an indication of the significant progress that we have made in implementing the recommendations made to us by the Auditor General for Scotland. As the annual report testifies and as discussed with the committee in September, the intervening period has been extremely busy for us, but we are content and indeed have assurance from our auditors that we are operating effectively as an organisation. There has been no follow-up section 22 report, and Audit Scotland had no recommendations whatsoever for us, as will be apparent from the annual report and accounts that we laid with the Parliament in December. In effect, our office now has a clean bill of health. I am pleased to be able to report to the committee that we have now implemented all of the auditors' recommendations that we were able to, and we have also implemented almost all of the additional recommendations that our internal auditors had for us. We have successfully recruited and inducted the new staff that I spoke to the committee about in September, and they have completed their probationary periods, and they are already adding value across the work of our office. In particular, that is in reducing the number of complaints that require initial assessment. Waiting times have now reduced to four months, which was not easy to achieve in the face of what has been rising complaints and investigation numbers during the course of the year. On the progress made, we have included all of the detail on our website and in summary in our annual report, and I am happy to provide more detail during the course of the session. In terms of my plans for the future, I published a new draft strategic plan for 2024 to 28 November. It was subject to extensive consultation, including with this committee, and it sets out an ambitious pathway for our office for the next four-year period. I will be publishing the final version, which incorporates the feedback that we have received prior to the end of this month. I am now very happy to take any questions that the committee may have for me. I would like to go to Stephen Kerr for the first question. Good morning, Ian. Welcome back to the committee. First of all, well done on being able to comply with the Auditor General's list of recommendations. I think that there were, whether there were 10, I cannot remember. There were 22 to get all together. Can I ask you first of all about resource? That had been one of the aspects of the challenges that you had to deal with when you came to office. How is that going now? Where are you in terms of the complement? Fully staffed. Yes. There are now 20 members of staff overall, myself included. The final piece of the jigsaw puzzle joined us just recently, and that was a part-time governance and finance officer to provide support to the corporate services team. The entire investigations team completed the approbationary periods in October and November, because their start dates were staggered last year. I am very happy that we have the resources that we require. That is very good. One of the job descriptions that I would like to ask you to speak about, just to give us some background on, is the public appointments advisers, because that is not staffed position, that is a contractor position. How does that work and how is that going? It is going very well. We, on a semi-regular basis, go out tender for these individuals, their consultants. They work to us under what is known as a service-level agreement. Full-time equivalent, if you are concerned about the resourcing implications for us, sits at around 1.8 members of staff. They are recruited on the basis of their expertise in recruitment and selection, with a particular focus on equality and diversity. They are not the policemen in the corner, they are my representatives, but their role is to assist panels in order to achieve the best possible outcome on appointment rounds. How frequently is the refreshing of the contractors? How does that work? We need sufficient capacity across the entire team to ensure that, because we have any number of appointment rounds running at a given time, and I determine how much oversight of those should be provided based on a number of factors, you know the budget of the body, how its governance is at any given time. But we need sufficient spread to ensure that we can allocate to any number of appointment rounds simultaneously. The optimum number for us of advisers is around 12, which is where we are sitting at the moment. When it dips to 10 or so, we usually go out to tender again in order to ensure that we have sufficient complement. On this sort of chart, it says that looking for 14, that would be the top end, then, of what you require. There's about 100 nod appointments every year. So what about the profile of these people? There's a reason why I'm asking this, you will understand, in relation to the recruitment to public bodies, which is an important part of what you do. What's the profile of the sorts of people that are acting as public appointment advisers? Well, it varies, but primarily. Again, I'd be very happy to share the details with the committee, our tendering process and the attributes that we look for. In general terms, they have a background in recruitment and selection, with a particular focus on equality and diversity. Are they themselves quite a diverse group in terms of their backgrounds? Can you just give us a sample of the sorts of different backgrounds they have? Yes, so let me see. We have one individual who herself is an adviser to the CIPD on recruitment and selection, so that would give you an indication of the calibre of individual who's involved. We have another individual, well, I suppose two, who used to work as independent advisers for AUKPA, so that was the equivalent commissioner for England and Wales. One of them was herself the chair of an NHS trust in England, so has that particular background? I'll just get to the point at why I'm asking this. While I understand that protected characteristics, diversity is important, and I can see that a lot of effort goes into that. One of the aspects of the profile of those who serve on public boards is that they are all pretty much alike. Predominantly, those are people who are high-income people. The number of people who are serving chairs or on boards that are earning low-to-middle incomes is pretty small, compared with those that are earning over, say, 75,000 a year. The background of the people that are being appointed to public bodies, including chairs, is a predominantly public sector. Relatively few people from the private sector compare with the public, maybe about half as many. Even fewer when it comes to the voluntary sector. I'm asking these questions that you can gather. What is happening that there seems to be a replication of the same sorts of people joining those public body boards? That seems to me, on looking at it from an optics point of view, that seems to be somewhat less than optimal. I agree, absolutely. That's why we ensure that the Government gives us these figures and we report publicly on them. There is definitely more that can be done in terms of diversity. You're asked about the cohort of PAAs. They have a very broad range of backgrounds, and in terms of visible diversity, it is an exceptionally diverse group. Is that being visible as in apparent characteristics? Yes, indeed. Are they predominantly public sector people with high incomes? No, no, no. There is a range in there, so some have that background, others certainly don't. I don't think that it would be legitimate of me to get into the detail with you, because— I understand that you're asking that. Yes, yes. You do make a very relevant point, and that's why we need to refresh diversity delivers. There are things that can be done on an appointment round by appointment round basis in order to increase diversity, and that's what our PAAs are there to encourage. As long as that diversity is not just—there are specific targets that have been set for diversity by what I'm calling protected characteristics. I didn't read—unless I've missed it—that's possible—of any particular drive to see that the people that are appointed are coming from the diverse background in household income terms and also in terms of their work experience. No, I agree, and that's something we should see. I've spoken to the committee previously about the fact that the strategy that we should have, which should be, I think, national and regional, as opposed to on an appointment round by appointment round basis, the focus of that should change. It was last designed in 2008 and published, so all of the targets that were in it at that point in time did relate to protected characteristics, and it came back to what it said in the 2003 act and what it says in the Scotland act. That was the focus at the time. I think that you're right, our focus should move now, and we should be looking to bring on board people from a much wider range of backgrounds, so I absolutely agree with that point. You've brought the necessary discipline for any organisation, the public of planning. Is there anything in the plans that we've not seen that is going to move the dial in the direction that we're discussing? That's what's set out in my strategic plan for the next four years, which is a refresh of that strategy. Yes, there will need to be more focus on broader diversity. I think that it's worth saying, so it does happen on an appointment round by appointment round basis, and I'm going to use one example because it might help bring it to life, the Poverty and Inequality Commission. I think that this is a very relevant example when they went out to look for their members and convener initially. The criteria for selection were such that it was a very different demographic that came on board there, and when I changed the code as well, perhaps it might be helpful to point this out, I'd made it clear to ministers it's not just skills, knowledge and experience that you're looking for, because that tends to mean that you're fishing in the same pool. Think more broadly about it. There are other attributes. You can be looking for things like lived experience. In terms of the Poverty and Inequality Commission, we were looking for people with lived experience. I say we, it was the ministers, and the process was designed to deliver that, so you ended up with a cohort of new board members who look very different. It does happen on an appointment round by appointment round basis, so NHS boards might be looking for people with lived experience of inequalities when trying to access health services, but I do think that we need to look at it on a more national and regional basis, and that's why the plan to refresh that strategy is in my strategic plan. Do you expect, as a result of the refresh, and it's obviously in focus because it's in your report? Yes. First of all, that's good. The reason I can ask those questions is because you've provided us with the information in your report. Do you expect, over the next what period? The dial will move the next year or the next two years? It will take time. I mean, these things always take time. There's 100 appointments on average a year, so we might see some. Well, I'll continue the report to this committee, and we'll be able to try to progress in that way, but I would expect—we're starting our research in July, and that's basically just to do the same job that we did in advance of 2008—what are the issues and how do we address them? That will require not just desk-based research but focus groups and that type of thing. There needs to be a considerable amount of awareness raising as well with the public because I'm not sure that people necessarily see themselves in those roles, and you're not going to address that on an appointment-round-by-appointment-round basis. Territorial health boards, you know that they do some outreach themselves, so that's helpful, but I think that we need to look much more widely so that there is going to have to be some sort of national campaign, I think. But let us do our research. I agree. I think that a few more people, particularly with private sector or voluntary sector backgrounds, need to be a little nudged to make themselves well because they may not see themselves as you're absolutely right, and they may not see themselves in the context of that sort of a role, and yet their experience is a critical—if they're not there—a critical missing piece. Absolutely. When I refresh the code, I said as much in the introduction, these boards should be reflective of the communities that they sell, and that's a very broad Yes, it is. Do you want me to carry on? Please carry on. So, I'll wait for the convener to tell me to be gone on. You just cover what needs to be covered. That's a fascinating question. Can many members all come in as appropriate? I'd like to talk a bit more about the strategy that's included in the report. You talk about—in fact, it's your top objective at the beginning of the report. It talks about creating an effective—it's quite difficult because it's black on green, so it might be age, but we will operate an effective complaints system. It does go on to talk a little about what that means. Would you just expand on what you see as an effective complaints system? How would you define that? In general terms, my office is committed to continuous improvement, so we already have what I would describe as an effective complaint handling system in place. We still have a queue, but it's reduced significantly. We need to get that basically down to the lowest possible level. We've got a comprehensive investigations manual in place that's been published, but it's not set in stone. Every time we get feedback from anyone who comes into contact with our office, it may be witnesses, complainers, respondents. We take that on board and we discuss it as a team, and we'll revise our procedures as necessary in order to improve effectively what is the service that we provide. I'm not saying that what we do at the moment is ineffective. What I'm saying is that there's always room for improvement and we do improve our practices on an on-going and regular basis. We refresh that manual quarterly, so the next refresh is due in April. It was published after a last gave formal evidence to the committee last year. It's been updated since that time, and the measures that we've introduced since that time reflect what we heard from the people who came into contact with us. So effective, one of the key elements of effectiveness for anyone who's involved in the system, the process is going to be speed of decision making? How critical is that? So speed of decision making is important, but also quality of decision making. So it has to be both. It's pointless getting through complaints very, very quickly if the decisions aren't right, if they aren't well supported, if people don't understand why those decisions were made. Those things are very important to, investigations need to be thorough. It's important that we gather all the evidence that we need in order to reach sound conclusions. We need to be able to demonstrate to those who are either complained about or those who've made a complaint that we haven't gathered everything relevant, and that the conclusion that we've reached is a sound one. To be absolutely clear, and I'm aware of this convener, that this committee's jurisdiction doesn't encroach in the area of councillors. But with your permission, I'd like to illustrate the issue of speed of decision by reference to what's in the report about councillors. So stage 1, a stage 1 complaint, the average stage 1 complaint currently is about, I can't tell you, I mean it's some 50s. It looks like it's about 160 days before someone's either going to stage 2 or is having the complaint against them dismissed effectively. But then it's a further, maybe 170 days in stage 2, so it's quite possible that a complaint against an individual, and I'm only using it for illustrative purposes, not because, and I do appreciate that there's another committee that'll talk to you about councillors, but that's the best part of a year. I know it's not good enough, and so that was in our backlog situation. I gave a commitment, a firm commitment, to this committee the last time I gave formal evidence that we would show waiting times on our website. We've had a banner up since that time, so January of last year it was 12 months. Let me think, by the time March had come around when I gave formal evidence it was 9, it's now 4. So that is an improving picture, and the firm commitment I gave was to provide also average waiting times for people. So if you've, and this is all on the website, anyone who visits that website will see the banner. It says now, and it was just refreshed last month, waiting time at the moment for complex complaints, and I think I need to explain something about triage as well because this may be helpful, but for complex complaints where it looks like, yes, there may well have been a breach of the code, and we're going to have to engather evidence, interview witnesses, et cetera, for those four months at admissibility. I committed to showing the average waiting times on the website, so there's a link from the banner, and people can go and see, and it's for different complaint types. So waiting times for MSP complaints is considerably shorter simply because of the way in which admissibility for those works. But you can see how long it takes for us to investigate complaints about councillors and members there as well, and again, it's much lower than in the annual report, which obviously is historic. Okay, so obviously we've got the numbers from the report, and you're right, this is a dated report, the one that we're working from now. You've been hard at work at this, you're making progress. I've illustrated one example, which is really to councillors, and you may refer to this one, or the MSP one, or the public body's one. How much of an improvement, I guess, is in your KPIs for the report that we'll be looking at a year from now? Well, considerable. So since that last annual report, as I've said, and as you've pointed out, it was taking far too long to investigate complaints, but you'll understand from the staffing that I've brought on board that, obviously, we've brought that waiting time down. We're reporting on that quarterly, we're now sitting at four months, and we've also set out the average time for stage two, which I think currently sits at, for councillor member 127 days. There are always outliers. We've also undertaken to publish progress against our KPIs, so the manual itself includes how long it should take for each stage of an investigation, all the way up to 100 per cent of complaints. We'll be publishing all that in our annual report, so you can see how we're doing against the targets that we've set for ourselves. And let me say, as a feedback, that I appreciate your willingness to, you know, in terms of accountability, the fact that you're willing to publish KPIs and progress to KPIs. I think that that's exactly how public bodies ought to work, so you're modelling the kind of behaviour that we would hope to see from other public bodies as well, so can I thank you, sincerely, for that? I'm looking... If we could... Stop there. Thank you. Excellent questions. I've got some more questions, but I... We shall come back to you. If there's time. Absolutely. May I briefly just mention to the convener if that's possible, because I don't want people around this table to feel that someone who's complaint is going to be dismissed quickly, has to wait a long time to hear about it. They don't, because we have a chair system in place, and if we know something isn't admissible, say a service complaint, you know, my councillor doesn't deal, or my MSP isn't dealing with my concerns in the way I would like them to. Those are dismissed pretty quickly. You know, they're identified, those are dismissed, and we have a database that will signpost people to other agencies that can help them, so it's really only the ones where we are actually investigating that have to wait to hear about my decision. Okay. Great. Thank you. Jackie Dunbar. Okay, thank you, and I'd like to follow on. You were saying that just now about today that it's only the cases that you have got to investigate that are taking a long time, but you've still got to investigate the cases that you don't think are going to take a long time to realise that they're not going to take a long time. So do you have a timescale for that? I know you said pretty quick, but that could kind of mean anything if I'm being honest. Sure, so for the ones that might help just to discuss how we work as an office, so the entire investigator team meets every week, senior management team meets monthly. We look at all of those statistics weekly and then monthly, and we have a system whereby complaints at the triage stage are allocated a different colour, so red, amber and green, and those are then allocated to the team of investigating officers. The ones that are green are basically the ones that are readily admissible, so those are taken off the list and dealt with, and I do mean very quickly. It would depend, we're talking about a matter of weeks, but it would depend on whether or not some additional information needs to be engathered in order to dismiss. That could be things like minutes of a council meeting or it could be a webcast of a council meeting. Sometimes people make an accusation that something inappropriate has been said, but actually when you go and have a look at the meeting, what you've suggested has occurred is not in fact occurred. The amber ones take longer, the red ones take longer than that, but the team of IOs has got a case mix. In terms of prioritising them, we do that in date order because it's so that the most aged ones get looked at first unless they're readily dismissible, but we spoke about making changes to our processes. One of the changes that we made was at the triage stage if it looks as though someone is in harm's way. We may get a complaint and it might relate to bullying and harassment. Now that sort of conduct can have clearly a really serious impact on someone's health and wellbeing. Those get pulled out of the queue and prioritised, they go to the top of the queue whereas something like failure register or declare an interest, fine. It will just be dealt with in date order along with the others, but we don't want people to be in harm's way because of an action on the part of our office or delayed action on the part of our office. I totally agree with that. I think that there's a duty of care to both sides. Until you've reached the end of your investigation, you don't know what the outcome is going to be. What correspondence is undertaken with both sides of the complaint during the process? Sometimes there's nothing worse than being left and not being responded to. Sometimes that can be worse for both sides. Absolutely. Both complainers and respondents are regularly updated, but I mentioned how cases are allocated. Each investigating officer has their own set of cases. They provide, so it's basically an individual, and they carry the case from beginning to end. Their contact details are provided to complainers and respondents, and both complainers and respondents are advised. We'll keep you up to date on a regular basis, but if there's anything that you ever want to find out, please get in touch with the office, and we're more than happy to have a discussion with them about case progress, and we do that as well. If I can go back slightly, you were saying that the waiting times is published on the websites. I'm going to be a bit rude here and forgive me, but that's just figures. How does someone know if that's a reasonable amount of waiting time or if it's not a reasonable amount of waiting time? Waiting for four months for your case to be dealt with, would that be reasonable, and are they told that that's reasonable? That's an interesting question. I'm not sure they're told that that's reasonable, what we have been doing in all of our letters, and that's including up to this date. Other than the ones that we are dismissing, I apologise for the delay in explaining why there is a delay. I've already said that I didn't feel that waiting for a year to have your investigation investigated in full was good enough. I don't feel that the current four-month time is good enough either. All of our letters say that we are sorry that it's taken longer than we'd like to investigate your complaint. It was due to basically a lack of investigatory capacity in our team. We've now addressed it through recruitment. That's that standard wording in our letters, so I agree that we can still do better than we plan to. One further question, convener. In regards to that, I realise that this is historic numbers, and I'm pleased to hear that you're still not satisfied with four months. On the whole, do you feel that it is in a better place than it was, but you're still striving to get there as quickly as possible? What would you be content with for waiting times if that's not an awkward question to ask you? It's not, and again, we've been very clear about this. We've got published key performance indicators for every stage of an investigation, and we will report to you publicly on how well we're doing against those. If it looks as though we're doing better than we thought we were, or we're going to, we'll make them harder. That's the reality. We'll include more stretching targets and welcome the views from the committee. As I did when we consulted on the manual and the KPIs previously, if you feel that we should be doing better, please let us know. For what it's worth, we do compare pretty favourably with other administrations because there was a benchmarking exercise done. Even as things stand, we were ahead of the curve, but that doesn't mean that we shouldn't be much better. There's a human cost attached to this. You said that it's just numbers and I get that, but I know that a complainer wants their complaint to be dealt with quickly, but equally, if you're a respondent, you don't want a complaint hanging over you for a long period. We absolutely get that. The entire team does, which is why we've made that firm commitment to improve. I do want to see the times come down in terms of how quickly we should or could be doing that. It's amazing to me just how fast time passes, but the additional resource that we got in, the only just completed their probationary periods, autumn of last year, they've bedded in now. They're already making a difference. They'll continue to make more of a difference, but the stuff that we're dealing with, if you'll excuse the term, it's quite complex. Even though they've all come from investigator-y backgrounds from different organisations, it's quite niche, but they will get quicker over time. What I think I'm hearing from you, and I don't want to put words in your mouth, is that you're content that you're moving in the right direction, but there's still more to do. Absolutely, yes. Thank you. I was just going to touch briefly on the strategic objectives for 2024-28 and how those were developed and what assessments were made of the key milestones around reaching them. We were developed in extensive consultation. As a first step, I and the entire team discussed what we'd had in the prior strategic plan, and you may recall that I had to introduce that as acting commissioner because I thought the one before that wasn't fit for purpose. It didn't include values and so on and so forth. So we had to look at that and what progress we'd made against it. We published progress annually against the strategic plan and the business plan, so we had to look at that and thought, where can we go further? That's why an awful lot of what was included in the revised plan was about improving the service that we provide as opposed to just providing the service. We've had a number of internal audits as well, and they've made some recommendations for us, so you need to have a communication strategy. You need to be much more visible, so we've got plans in place for that. The communication strategy was published last September, so internal audit has informed our plans for the future as well. One of the other points that was made to us, we consulted with other organisations prior, so pre-consultation, including the Standards Commission, prior to publishing for fuller consultation. We asked them what they felt we could be doing better than we were doing at the current time, so I would suggest that this particular plan is more ambitious than the one that sat before it, and that's where the objectives have come from. We've also had quite a few responses to the consultation itself, so I've been looking at those recently and thinking about what more could we be doing in that area. Quite a lot of it really is about visibility of the office, which I think potentially the office may have shied from previously, but I am committed to doing more in that area. Public confidence in the work of our office is quite important, not just for appointments, because clearly you want people to put themselves forward for those roles, but also in terms of public life more broadly. This is one of the discussions that I've been having with the local government committee. If conducting public life isn't great, it does put people off. They don't want to come forward for roles. They may leave roles that they otherwise would have enjoyed fulfilling, so I think that I need to step more into that particular space. You mentioned the local government committee. Obviously, there's a locus roundabout in relation to councillors, but there's also a desire and a desire to engage more thoroughly with other subject committees in the Parliament where they're relevant. Can you give us a bit of background on how that works, proceeding and what interactions you've had there to help transparency? My discussions with the local government committee, a lot of it has been around how do we improve the profile of local authorities. We had a question earlier about diversity, and I think that we're in the same place there. My view is that governance has always improved when you have more diversity around the table. Those have been the discussions that I've been having with the local government committee. I haven't put them in touch with other organisations, although I know through discussions with them, because I contributed to some of the work of the Scottish Local Authorities Remuneration Committee. The committee may be aware of the report that it brought out, but it's looked at things like whether or not people are being treated appropriately in public life, the impact of that and people's willingness to apply for roles. So there's been an interaction there, and I understand also that they've been interacting with the local government housing and planning committee. Okay, but not with any other subject committees in the Parliament? I think that would be a matter for the local government committee. I haven't sought to put them in touch. If you feel that I should, that's certainly something I'd be happy to consider. Okay, thanks. Stephen, there are more things you want to come in on? Yeah, I did. Thank you, convener. Just on the point that was raised by Jackie Dunbar about delay, I mentioned it as well, what consideration do you make of the wellbeing of the people who are on the receiving end of these complaints? Because we're operating here from the background of knowing some of the stresses that the colleagues have gone through. In fact, in one case, I don't think I'm saying anything that hasn't already been said in public by this person, but the effect of the left public life, which I think was a disaster because that person had so much to give, how much consideration do you give to the wellbeing of the people who are subject to these complaints? A huge amount, and that's no understatement. One of the first things I did when I took up the role as acting commissioner was include values on the face of our strategic plan. Those weren't just words on a page, and they applied to every member of staff, and they featured in our recruitment of new staff as well. It's not as though I didn't consult the staff I did, but we agreed them collectively. You need to take people along with you, but when we were recruiting new people, these were absolutely paramount. You need to share those values. They're about respect, yes, which you'd expect, and good stewardship, but also about kindness, about empathy for people. These things are really, really important. They're so important that we are now surveying, so we've rolled out that survey. We are now surveying complainers and respondents on the extent to which—and it's anonymised, so they can give us honest views—the extent to which we have adhered to our values and our dealings with them. We're the people who dealt with the kind, we're the respectful, we're the empathetic. It's absolutely fundamental, and we're going to be publishing the results of those surveys in our annual report so that the committee and the public can see whether or not we are upholding those values. Further than that, our training. For example, if it's a case involving bullying, sexual harassment or training, we've repeated just recently on handling cases of that nature previously, and we'll be running this again. We got rape crisis Scotland involved to ensure that our staff handled cases with a trauma-centred approach, but that informs not just those cases but all cases in which there's been an impact on the individuals involved. Further than that, I wrote to the responsible cabinet secretary to say, and also to the clerk, chief executive of the Parliament, to say that we feel that there should be an independent support service in place that members, councillors, members of public bodies and also complainers, also witnesses can access in order to obtain the sort of pastoral support that we feel that they need. So I feel I've done my part in terms of running my house, but I've also highlighted, I think, you have a responsibility here to provide a service so that people have the support that I feel we need. That's a very strong suggestion, and I think that something is badly needed based on the experience of colleagues, and we probably all have colleagues who've been through these experiences and has left them feeling diminished, which is exactly the opposite of what we've been talking about for the entirety of your evidence, which is trying to create an environment in terms of public service that people want to come forward and want to give of themselves, because that's what, frankly, our country needs. So I appreciate what you said, and returning to the strategic plan and strategic objectives, I hope you won't mind if I say, I hear what you say and I accord with everything that you say about prioritising complainants and complainers and all the rest of it, but I was a little perturbed, I suppose, of the nine specific strategic objectives that are in the plan. None of the first three related to any of that, the first four, or you could say three at least, relate to internal things. That seems a bit strange to me, and I'll tell you why, because when you did your, I think, very honest assessment of the key risks, key issues and risks that you were dealing with in your report, the number one thing that you put, and I think correctly, was loss of stakeholder confidence, but yet in responding to those key issues and risks in the way that plans laid out, and I suppose I'm giving you an opportunity to say that the way it's laid out is not necessarily a prioritisation, but it comes across as if it's very inward looking, as opposed to what the risk is, which is about what's happening in terms of your stakeholders. Does that make sense? It does, and so perhaps I didn't articulate it particularly well, but that's kind of the feedback that I've had on the plan, which, you know, that there should be more of a focus, I think, on encouraging good standards in public life, so when I publish the final version, you will find that higher up. That's fine, because one of the things that you've mentioned, which is really good news, is that you're surveying almost customer satisfaction survey, which I very strongly believe in, but I think also what would be very interesting is whether or not you're conducting, have conducted or are conducting or will conduct surveys among these stakeholders, because you talk about loss of stakeholder confidence. Am I wondering whether or not that's something you've done and just haven't published or maybe I haven't seen it, or is that something that's in the works? So we certainly haven't surveyed them, and that's not something that I currently have planned, and it's certainly something that I can consider, because I suppose what it does is it provides them with an opportunity to, I don't know, make anonymous commentary on the work of my office. If I'm being honest, the nature of my stakeholders is such that they're not backwards and coming forwards, and I have been engaging much more significantly with them again since I was acting commissioner. I'm sure they won't mind me saying, but so Kozla invited me along to their conference, and because things hadn't been going well in the office, that was a tough day for me, but I felt I had to be there in order to answer, you know, what were challenging questions and rightly so, and I hope, I trust and hope that I gave them a measure of confidence in me, and that's a standing invitation to any public body, basically. I am more than happy to go and talk to you about any concerns that you may have, and that can be in a public forum, or equally they can be in touch with me at any time, and quite a few of them are to let me know what they think about how we're getting on, and again, you know, that just feeds into our improvement practices, so if, you know, if I agree that we're not doing that sufficiently well, we'll change our practices in that particular area. So in terms of you bringing your good office to bear and, you know, your presence to bear in respect to stakeholder confidence, I think that's all, that's all good, but I do think, given the fact that it's the number one, and I reckon, I reckon, you could correct me if I'm wrong here, I reckon that these were listed in terms of importance to you as the commissioner, but number one was loss of stakeholder confidence, and I think going beyond, yes, you know, I take your point that none of us are very backward in coming forward with our points of view, et cetera, but I think it would be terribly useful. I really do. If there was a regular, you know, once every two years or something, some kind of a survey that actually brought you data sets in an organised way that you could measure and plot going forward in terms of confidence levels, because I think that that is rightly identified as a critical issue for the success of your role and of your office, and therefore I think it's worth it being measured. Any comment? Yes, I think that's a good suggestion, and I always take on board good suggestions from this committee and change what I do as a consequence. So, based on what you've said, I think probably the ideal way to do that is just write it onto the face of my communication strategy. There'll certainly be scope for us to set something additional up on the website so that people could submit anonymised comments on the work that we do. I just think that if it's an event as well, then you've got snapshot moments at which you can plot progress, because that's fundamental. It's one of the things that, if you can model from your office, it will be a wonderful thing to see replicated across all sorts of different public bodies and governmental organisations. One last point, if you don't mind, and that is about the issue of, in the report, you talk about, I forget the phrase now, was it super complaint, or am I getting confused with super Tuesday, that the mega complaint that you had with hundreds of complaints? Have I correctly described it? That's right. One of the things that I'd like just to hear you talk about is the level of what I would describe as vexatious or partisan, vindictive sort of complaints at our county. Is that on the increase, or is that, I mean, how would you describe that trend? Because clearly you referenced the super complaint in your report, is that a burgeoning area of focus and activity and resource that you could else better? We've done a bit of research on this, actually. That was a blip, if I'm being honest, and you'll understand I can't talk about the detail, but that was a bit of a blip. The numbers of councillor and member complaints, councillor in particular, are such that we can readily draw some conclusions about them, because there are a lot of them in comparison with the other complaints that we deal with as an office. So I did do a bit of research towards the end of last year, just to have a look at trends, because anecdotally it does feel as though there are more complaints about discrepancy and disrespect. And our research demonstrated that in comparison with other complaint types, yes, there has been a steady rise in those. Anecdotally, again, it's probably worth saying, so I cannot form a view on whether or not a complaint is valid based on the motivations of the complainant. The conduct is either compatible with the code or it isn't, and that's the decision that I'm obliged to make. But there is no question in my mind that, yes, there are complaints that are politically motivated, quite a lot of them. It's absolutely evident from what I see. It's one of the things, and the strategic plan is that I actually plan to do a bit more research just to try and get behind some of this, but you'll have gathered that there were relatively few complaints in that reporting year in comparison with prior years. The numbers are way back up again. Over the time December came round, we were double what we've been looking at in that year, so there may be a link between when there's an election and you get new members on board and what goes on just prior to an election. On occasion, the code is used in order to gain political capital. That's just the reality of the situation. Again, you're right. I think there's more, and the other stakeholders are right. There's more that I can do. There's more that we can all collectively do to encourage better conduct in public life. I'm going to quote Professor Adam Tomkins, a people leader reporter about him some time ago, but he said, notwithstanding the fact that he wasn't in breach of the code, it's very important to play the ball and not the man. I would like to see more of that, which is fine. It's fine to criticise your opponent's policies. Please don't be personal about it. Yeah, assisting about being able to disagree agreeably, which is something that is proving to be more and more of a challenge in our public life, which is in itself a disincentive for people entering public life, which is to the end of days to the detriment of our country and its people. Just one last question about would you ever be able to break down the nature, the source and the nature of those types of complaints, because one of the things that I think I pick up is that, particularly from colleagues that are maybe in councils, is there are more complaints being made from people that are in public office about other people that are in public office? Are you able to comment on that at all? Yes, you actually find the figures in the annual court already. Yes, yes, they are. No, we disaggregate. Here I thought I'd read it properly. No, no, I'm sure you did, but most of our complaints do come from members of the public, but then you do have councillors complaining about other councillors. Is there a trade in terms of people in public office complaining about other people in public office? That's again research. We need to have a look at that and delve into the figures in much more detail, and that's definitely on the cards. I'd like to be able to predict, if I can, what the work of our office is going to look like going forward. I think that that will be helpful. I think that you'll understand from the annual report what I've said today. I do like to be transparent, and it's important for the public to know what's going on, so the more research we do, the better informed we'll be. That's fine. Thank you very much. Anybody, any other interventions, questions? Thank you very much, commissioner. I've enjoyed the session and I'll see you again. It was fascinating and thanks again for the opportunity. I'll now move the session into private.