I can give you an example. PayPlan, which is a private company, is one of the largest free providers of debt solutions across the UK. When the SFS 2017 was introduced in April 2017, PayPlan adopted the tool and trialled it for a few months. My understanding is the company has stopped using it for over a year because it felt that it produced overgenerous results in favour of the debtor. We will not be able to do that. Once the regulations are passed, we do not get to cancel them—they are in place whether or not we like them and whether or not the tool works. In England and Wales and in Northern Ireland, agencies have the option, because the use of the tool is voluntary, to turn it off and say that they are not using it until the system is fixed or staff are given more training. We do not get that option.
My big concern is that, once the regulations are passed, Scotland will, rather than joining the rest of the UK in using those figures, be used as an example to push the use of the figures across the rest of the UK. If the regulations are passed, the figures will be accepted and used uniformly across the whole of Scotland, which has not been the case so far across the UK, where they have been widely used but not uniformly adopted. If we in Scotland turn the figures into legislation, their use will basically become uniform.
I also have concerns about accountability. For example, the gentleman from the Money Advice Service who gave evidence last week spoke about comparative studies that were undertaken with the Joseph Rowntree Foundation’s minimum income figures, which were not as bad. I was on the common financial tool working group, but I have never seen that report because it has not been circulated. People will say that, as Money Advice Scotland sits on the governance body, along with the Accountant in Bankruptcy, Scotland is being represented. However, I sat on the Money Advice Scotland management committee—as Nicola Birrell currently does—and its social policy committee, and I did not see the report to which I referred; neither did I see it as a member of the common financial tool working group.
I requested at the common financial tool working group that a study be done into the public visibility of the trigger figures. A study was commissioned, and months and months went by. Eventually, I asked what had happened to it, and I was told that it had been done. I asked to see it, and was told that it would be shared only with the SFS governance group. Again, I stress that, as a member of the common financial tool working group, a Money Advice Scotland committee member and a member of the MAS social policy committee, I did not get to see that study. Although Scotland is represented by certain organisations, I believe that those organisations are restricted with regard to those to whom they can circulate information. What sort of a voice do we really have?