Overview
Respondents were in overall agreement with the proposals set out in the
Code of Practice. Most felt that the Code offered a sensible set of
principles from which to operate. Many felt that introducing it would do
much to improve standards in consultation exercises across Government.
Respondents welcomed the Code's emphasis on key issues, such as clarity
of purpose for consultations, ensuring accessibility, timing and feedback.
Although respondents agreed with the main points of the seven criteria,
many suggested further issues to be taken into consideration.
Several respondents suggested that the criteria should form a part of a
good practice guide, rather than a binding Code of Practice, to point
flexibility when dealing with different styles of consultation, whereas
others felt binding criteria would ensure uniform standards.
Concern was raised about consultation fatigue. But the overall emphasis
of respondents was on ensuring that consultations were built into the
policy making process and took place at an early stage. It was thought
that the Code would do much to improve perception and effectiveness of
public consultations.
The issue of presentation was seen as important in improving
accessibility, but some concern was expressed that brevity of documents
might lead to issues being misinterpreted or overlooked. Respondents
welcomed the focus on accessibility, but some wanted further clarification
on specific points such as disability and language formats.
The issues of weighting of responses, time for consultation exercises
and feedback featured prominently in the comments. Effective evaluation of
consultation exercises was seen by respondents as being useful in
promoting best practice: respondents did however offer further comments
which they thought would improve the process.
Summary of responses to specific questions
General comments
Enforcement was a regular theme, along with the status of the
document: many respondents from the private and voluntary sectors said
that the Code should be binding on departments, as they thought this would
ensure high standards by those conducting consultation exercises.
Some respondents supported the idea of a central register of key
stakeholders to be contacted for specific areas of consultation.
Respondents felt that an important element in ensuring the success of the
consultation exercises was changing departments' "mindset", and
so that they become more consultation-orientated.
Criterion 1: consultation should be built into the planning
process for a policy or service from the start, so that it has the best
prospect of improving the proposals concerned, and so that sufficient time
is left for it at each stage. [The criteria set out appear here as they
appeared on the draft code].
The focus on making consultation an integral part of the policy process
was welcomed. Some respondents supported alternative methods of public
consultation, including pre-consultation and focus groups. Respondents
supported the importance given to ensuring that public consultations have
an adequate time scale.
Criterion 2: It should be clear who is being consulted, about
what questions, in what time scale and for what purpose
Respondents supported the focus on the issue of clarity: The importance
of setting out a clear timetable for the whole policy and consultation
process was supported.
Criterion 3: A consultation document should be as simple and
concise as possible. It should always summarise in no more than two pages
the questions on which views are sought. It should make it as easy as
possible for readers to respond, or make contact.
Voluntary and private sector respondents in particular stressed the
importance of ensuring consultation documents are as brief and clear as
possible and that they are inclusive and effective. A small number of
respondents highlighted the dangers of over simplification of complex
issues and the possibility of restricting information available to
respondents by using a summary format.
Criterion 4: Documents should be made widely available, using
electronic means as far as possible (though not to the exclusion of
others), and effectively drawn to the attention of all interested groups.
A majority of respondents felt that easy access to consultation
documents was an issue of particular importance. Although respondents saw
the Internet as an increasingly important medium of communication and
strongly supported its use, the point was made that not all organisations
have access to the necessary computer facilities and hard copies of
documents should be readily available. The availability of consultation
documents in languages other than English, in particular Welsh, needed
emphasis. Some respondents thought that accessibility of formats suitable
for use by those with disabilities was particularly important.
Criterion 5: Sufficient time should be allowed for considered
responses from all groups with an interest. Twelve weeks is preferable,
and eight weeks should be regarded as a general minimum.
There was strong support for 12 weeks, but some government departments
and agencies draw attention to the difficulties that would cause. Many
suggested that eight weeks was too short for large scale representative
organisations to consult and respond effectively: others that, when
consulting a small group of key stakeholders on a technical area, the time
frame suggested would be too long and may not comply with other deadlines
/ commitments, such as EU legislation. Respondents also suggested
consideration should be given to allowing longer periods when
consultations were carried out over holiday periods.
Criterion 6: Responses should be carefully and open-mindedly
analysed, and the results made widely available, with an account of the
views expressed, and reasons for decisions finally taken.
A majority of respondents agreed with principles set out in criterion
6. A number specifically identified feedback on the decisions taken as an
important issue to ensure that consultation exercises are seen as
worthwhile by consultees. The "weighting" of responses was also
an important issue. Early consultation would help more inclusive
discussion, as respondents would be able to offer comments on the feedback
from the consultation exercises.
Criterion 7: Departments should monitor and evaluate
consultations.
Respondents generally agreed with criterion 7 with some suggesting further
amendments, such as providing reasons for decisions to respondents and an
independent body, such as the Cabinet Office, to evaluate consultations.
No respondents disagreed, but some did suggest that evaluation of
consultations should include a flexible, qualitative approach as well as a
statistical element.
Annex A
List of Respondents
Action with Communities in Rural England
Barking and Dagenham Council
Barrow in Furness, Borough of
Boleat, Mark
British Chambers of Commerce, The
Campaign for Real Ale Limited
Charity Commission
Chartered Institute of Taxation, The
Church of England-Diocese of Liverpool, The
Citizens Advice Bureau, National Association of
Confederation of British Industry
Consumers in Europe Group
Council of Civil Service Unions
Council of Ethnic Minority Voluntary Sector Organisations
Council on Tribunals
Councils for Voluntary Service, National Association of
Crown Prosecution Service
Culture, Media and Sport, Department for
Director General of Fair Trading
Directory of Social Change
East Riding of Yorkshire Council
Education and Employment, Department for
Education Forum
Educational Institute of Scotland, The
English Heritage
Environment Agency
Environment, Transport and the Regions, Department for
Federation of Small Businesses
Food Standards Agency
Foreign and Commonwealth Office
Forum of Private Business, The
Further Education Funding Council
General Council of the Bar, The
Government Office - East Midlands
Gwent County Borough Council
Health, Department of
Hillingdon, London Borough of
Home Office
ICAEW :The Tax Faculty
Inland Revenue
Institute of Personnel and Development
Institute of Trading Standards Administration
Intervention Board
Kent LEA
Law Society of Scotland, The
Legal Services Commission
London Regional Passengers Committee (L. R.P.C)
Lord Chancellor's Department
Maritime Coastguard Agency
Ministry of Agriculture, Fisheries and Food-
NAPE Council
National Consumer Council
National Federation of Consumer Groups
National Federation of the Blind of the United Kingdom
NHS Confederation, The
Northern Ireland Office
Office for National Statistics
Plain English Campaign
Royal College of Nursing
Royal College of Nursing - Scotland
Royal Society for the Prevention of Accidents, The
Royal Statistical Society
Royal Town Planning Institute, The
Scottish Funding Councils for Further & Higher Education
Scottish Trade Union Congress
Select Committee on Public Administration - Wright, Tony
Small Business Service
Social Security, Department of
Society of Public Information Network
South Norfolk Council
TMA and The Society of London Theatre
Trade and Industry, Department for
Trades Union Congress
United Kingdom Atomic Energy Authority (UKEAEA)
Wales Council for Voluntary Action
Welsh Funding Councils
Welsh Language Board
Windsor & Maidenhead Council, The Royal Borough of
