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Open Letter from Charles Plant, Chair of SRA Board re Online Processes

Online processes

In view of the concerns that have been expressed across the regulated community relating
to the recent PC renewals exercise, I thought it would be helpful to update Presidents of all
local law societies on progress we are making on the SRA’s IT systems and online
processes. I particularly want to share some details about what went wrong with last year’s
renewals exercise and what we are doing, as a result, to avoid future difficulties. I am
sending this letter to you by email in order that you can circulate to your members, should
you think it appropriate.

Background

You will be aware, as am I and the SRA as a whole, that the implementation of the PC and
entity renewal online processes, did not go well; nor as planned. Both Antony Townsend
and I have apologised on behalf of the organisation for the difficulties that this caused many
firms and individual members of the regulated community.

The SRA has reviewed both the implementation of this element of the programme and the
overall change programme, the SRA Enabling Programme, within which it sits. This is a
multi-year programme, which is replacing the infrastructure and the functionality of the
systems that support our regulation. It will enable processes to be moved online and away
from labour-intensive and extensive paper-based systems. It will facilitate the operation of
the processes necessary to license alternative business structures and implement principles-
based, outcomes focused and risk-based regulation.

The development and implementation of this programme was necessary in order to: replace
dangerously obsolete and fragile IT systems, which had not been updated for many years; to
increase efficiency, and to enable a more modern approach to regulation in the public
interest.

Implementation

The implementation of the online processes for PC and entity renewal was the second
implementation phase of the programme. The first phase – student enrolment – was
implemented in the Spring of 2011, not without some difficulties, but relatively successfully.

The second phase of implementation did not, as I have said, proceed so smoothly. In
particular:

. the renewal process was delayed and there was a lack of clear and timely
information about when it would be able to commence and be completed;
. the regulatory information held on firms and individuals was, in some cases, poor and
historic, requiring manual intervention by users to correct it;
. the system required a particular way of operating, which did not always fit well with
the management and operational structures in some firms, resulting in increased
effort being required and further delay;
. the system offered a poor ‘user experience’, for example it was at times necessary to
pass through a large number of screens to complete a task and input the same
information a number of times;
. the system was fragile with unacceptably long and frequent periods when it was not
available or was operating slowly; and
. it was often difficult to obtain help from the SRA when problems were encountered,
for example, because of overload at our Contact Centre.

I am sure that there are other problems that individual firms will have experienced, but I
believe that the above is a fair representation of the major issues experienced.

Work in progress

Working with our colleagues in the Law Society, we are implementing a programme of
enhancements that we are confident will improve the user’s experience for the next round of
renewals.

These include:

. improvements to the management of the third party organisations developing the
new systems and operating the infrastructure on which they operate;
. changes to the structure of the Enabling Programme, responsibilities, governance
and ways of working. This has included bringing a number of new individuals into the
Programme with the skills and experience necessary to move it from its current
position to completion through the implementation of further phases during the first
half of 2013. These changes include ones in the structure and management of Law
Society group shared services (which deliver IT services to both the SRA and the
representative Law Society);
. providing organisational contacts with access to individual employee accounts and
allowing them to process the applications on behalf of colleagues, thereby providing
firms with greater control over the way they complete the PC renewal and recognition
exercise;
. significant work on making the applications simpler and easier to complete, including
an overhaul of the flow and wording of questions and related guidance text;
. more robust support being made available via the Contact Centre;
. enhanced systems performance;
. resolution of outstanding defects;
. improvements to the payments module; and
. carrying out user testing and engagement.

A key part of this programme of improvements is working with a cross-section of those we
regulate to ensure that what we are doing addresses your concerns. We have already
undertaken an on-line survey, and are holding regular workshops with users to try to ensure
that that the renewal process in the autumn is as smooth as possible. With your help, we
are focusing our efforts on where we can make the most significant changes.

I hope that this summary will help address the concerns that you and your colleagues have
experienced. I am certain that, in time, you will recognise the benefits that the online
process has to offer.

With best wishes

Yours sincerely

Charles W Plant
Chair, SRA Board

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