Economy, Energy and Fair Work Committee

Meeting date: Tuesday, October 1, 2019

Official Report 722KB pdf

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Consumer Scotland Bill: Stage 1

Agenda item 4 is on the Consumer Scotland Bill. We are joined by three witnesses: Norman Kerr, director of Energy Action Scotland; Thomas Docherty, head of public affairs, nations and regions, for Which?; and Jonathan Lenton, an ombudsman at the Ombudsman Service. I thank you all for coming in today.

I declare an interest as the honorary vice-president of Energy Action Scotland, but that does not mean that I agree with Norman Kerr on everything.

I have a simple question to kick off with. Do we need consumer Scotland? I am curious to know how it could provide any additionality over the work of the existing consumer bodies.

The simple answer is no. It would not add much to the landscape. Others have said that it would tighten the landscape, but we are not convinced about that. The bill provides additional powers that could have been easily given to Citizens Advice Scotland. When Consumer Futures was dissolved and Citizens Advice was to take on its responsibilities around Great Britain, Energy Action Scotland argued that Citizens Advice should be accountable to Parliament, so that Parliament would have a duty to approve its work plan and receive reports on consumer detriment.

The bill is simply trying to replicate that, and our worry is that that would muddy the consumer landscape. Consumers already have a fairly wide choice of people with whom to discuss problems and, unless the new body also took on the role of consumer education, which we can all agree is lacking, it would not add anything to the landscape.

We take the reverse position. In 2015, when the devolution of the powers was first proposed following the Smith commission, the Scottish Government originally proposed the creation of a single body. However, CAS, Which? and other members of the independent working group said that that was not the way to do it. That might not have been everybody’s position, but it was a starting point, and I am happy to explain why that was. Almost from the start, it was felt that having two distinct bodies with two clear remits was the way forward.

We are huge admirers of what Citizens Advice Scotland does on tackling fuel poverty and on financial wellbeing, welfare, benefits and advice for citizens on immigration and employment rights. If the bill were to be passed, CAS would continue to do those things, and consumer Scotland would focus purely on the consumer landscape.

It is worth remembering that Scottish consumers spend more than £8 billion per month. In order to spend that money, they must have confidence that the markets in which they transact work for them. In too many markets—some are reserved and some are devolved—that is not the case.

We—and almost everybody who made a written submission—think that there are clear gaps in the environment. Rightly, the Scottish Government has not squeezed in a new body to fill the gaps without touching the sides of any other body that is working in the area. Instead, it has done the right thing by looking across the board to see which responsibilities should move from other organisations to consumer Scotland. It has created a system that is bold, brave and logical, so that when organisations such as ours look at the two bodies, it is clear which of them will do what, as well as what organisations such as Trading Standards Scotland and Advice Direct Scotland will do.

I will not pretend to be an expert on the consumer landscape in Scotland. However, looking at the complaints that we deal with, I can see that there is a complaint class that is unique to Scotland—we receive a set of complaints from Scottish consumers that is different from the complaints that we receive from consumers in the rest of the UK. For example, under our communication scheme, there are complaints on the availability of broadband and mobile signals and on broadband speed—those really stand out in the data on Scottish consumers, particularly in relation to consumers in rural areas. We can see the argument for setting up a consumer advocate who focuses on such issues for Scottish consumers.

We are doing some exciting work at the moment, including with one of the working groups that was set up to look at the data strategy for consumer Scotland. The group is looking to bring together data from numerous organisations, including ours, the Financial Ombudsman Service, Advice Direct Scotland and commercial organisations such as Trustpilot and Resolver, to provide a much better picture of the consumer journey and where detriment occurs. We are looking at standardising data sets across those organisations and bringing them together to understand consumers’ experience. That is innovative—we have not seen other organisations doing that kind of work—and could be the model for cross-organisational data sharing in the future. We can see some positives.

Thomas Docherty mentioned that the bill is about not just filling gaps but providing something more strategically coherent. On that basis, do you see any potential problems with the existence of consumer Scotland reducing the public funding that is available to other consumer organisations? If it is going to do part of the job that others currently do, will the others lose money?

12:00  

When you say “other consumer organisations”—

I am talking about organisations such as Citizens Advice Scotland.

Right. Citizens Advice Scotland will not lose any money for its citizens advice bureaux network or for the work that it does on citizens advice issues. That money will not be touched.

It would be an interesting argument if we were to say, “We’re going to have a new body, Consumer Scotland, but we’re also going to fund a second body that will spend taxpayers’ money doing the very things that the first body is doing.” That does not make sense. In its submission to the Finance and Constitution Committee, Citizens Advice Scotland has put the figure at about £1.52 million. That money will move from CAS to consumer Scotland, because that is the money that CAS is given by the Scottish Government to look at consumer issues.

In effect, what you are describing is displacement rather than additionality.

No. This is off the top of my head but, according to the financial memorandum, the total budget for consumer Scotland will be about £1.9 million. I am conscious that the minister is to appear before the committee next month, so I am sure that members will challenge him on this, but we have sought clear assurances, which we have been given, that there will a real-terms increase in funding for consumer Scotland. It will not just be a case of taking the £1.52 million that goes to CAS; it will be a case of taking that £1.52 million and putting in additional funding to deliver a first-class consumer research and advocacy body.

I am glad to hear that no funding will be displaced, but I do not see how that commitment can be made at the moment. I know that colleagues at CAS are deeply concerned that although there might be no change for a short period of time—perhaps the first year—after that, that money could be ripped away from them.

I have a question about brand, after which I will stop, because I am conscious of time. With its network of citizens advice bureaux, Citizens Advice Scotland is a recognised and trusted brand. That is certainly the case in my local community, and I suspect that it is the case in everyone else’s. Consumer Scotland will be a brand-new Government agency. Would it not play better with where consumers are at the moment to give the Citizens Advice Scotland network the relevant powers?

No. Forgive me, but I think that you are talking about two different brands. A much better question to ask would be one about Citizens Advice Scotland and Advice Direct Scotland—

Sorry—I ask the questions and you give the answers; don’t tell me what a better question would be.

Well, bluntly, the comparison that you made is not the right one to make, because consumer Scotland will not deliver advocacy services. Advice Direct Scotland is already delivering advice services through telephony, online and via social media—it has been doing that since 1 April. Consumer Scotland will not be a brand like that; frankly, if it were to try to be such a brand, the committee would have some questions to ask about the spending of public money. Consumer Scotland’s job will be to do research to identify areas of consumer detriment, to investigate what is causing those problems, to propose solutions and to advocate to regulators, businesses and the Scottish and UK Governments how those problems should be fixed. The delivery of advice services is for Advice Direct Scotland and citizens advice bureaux.

Does Mr Lenton or Mr Kerr have anything to add?

I take what Thomas Docherty says about research, but CAS already does research and should already try to influence the UK Parliament through Citizens Advice Great Britain. As I understand it, much of what we are talking about as regards telephony, broadband speeds and energy suppliers will continue to fall within the remit of Westminster’s retained powers, so the new body will have no teeth. All that it will be able to do will be to ask ministers to make recommendations to the UK Parliament. I do not believe that the new body will deliver what is being suggested.

Is the duty to collaborate in the bill sufficient to ensure that consumer Scotland does not duplicate the work of other bodies, such as council trading standards officers and citizens advice bureaux?

Collaboration is needed, and it is always good. However, if collaboration relies solely on the good will of other agencies—for example, South Seeds in Glasgow and Greener Kirkcaldy in Fife, which Energy Action Scotland mentioned in its submission and which very much have boots on the ground in their areas—it is very hit and miss, because such agencies have had funding pulled from them. I am not talking about the £1 million or so that is being taken away from the citizens advice service; I am talking about small, local organisations. If collaboration is based on good will for a Government agency that holds all the funding, we will be asking smaller organisations, which need to fund premises and volunteers, to collaborate without getting any recompense.

Who funds my local citizens advice bureau?

The local authority funds that.

Exactly. The council funds it, not the Government. If any money is getting ripped away, it is local government that is ripping it away, through localism—but that was not my question.

Was that a statement, Richard?

Well it is true. It is the council—you know that, Norrie. The situation is that councils, through localism, allocate money to whoever they wish.

I want to get back to the consumer. If I buy a wonky television, I might go to citizens advice, but it might not be able to help me—we find that some companies do not react. If the company does not react to citizens advice, I might complain to Ombudsman Services about it, if I can. The company might not listen to the ombudsman. Sometimes people do not listen to you; I have come across that. If I then go to consumer Scotland, the company might go, “Oh, wait a minute, that’s consumer Scotland. They’re tied up with the Scottish Government, so we’d better sit up.” Do you agree that going to someone different—even a member of the Scottish Parliament—can get a reaction? Do you agree that, depending on who you go to, you might get a reaction?

As Thomas Docherty said, consumer Scotland will not be doing front-line advocacy. It will be doing in-depth research and looking at consumer detriment; it will not intervene in individual cases. That is my take on it. Therefore—

That might not be my take on it.

Then the bill needs to be explicit on that, and it needs to show the link with the existing consumer landscape.

The organisations that I mentioned—Greener Kirkcaldy and South Seeds—receive funding from the Scottish Government, not local authorities. You talked about people ripping funding away: it is not local authorities who are ripping funding away; local authorities are already under strain. There used to be eight citizens advice bureaux in Glasgow; there are now five, because the local authority has taken the funding away.

Yes. The local authority took the funding away.

I know that colleagues will disagree.

I accept that the Scottish Government—and the minister, when he comes to the committee next month—will have to do some explaining to people. However, let me say again that consumer Scotland will not take money away from front-line organisations, because it will not be doing their job—that is specifically not what it will be doing.

I think that the organisation’s total head count will be somewhere between 16 and 20, according to the financial memorandum. Any suggestion that it could deliver a face-to-face advocacy service is as ludicrous as Citizens Advice Scotland trying to set up a telephony advice scheme to rival Advice Direct Scotland. That is just not the purpose.

Let me be very clear: people who go to citizens advice bureaux are not going there for advice on standalone consumer issues. A brief example would be what happened with Thomas Cook last week: Which? and Advice Direct Scotland had a huge number of hits on our websites and social media from people with queries about their consumer rights—they would have been going to Ombudsman Services as well. Those customers will not be walking into citizens advice bureaux in large numbers to have those conversations, because that is not what people do. However, the staff who have lost their jobs might well go to citizens advice bureaux to get advice about where they stand financially. That is the brilliant role that Citizens Advice Scotland plays and will continue to play in the future. There is a very clear divide.

The main things that Citizens Advice deal with are rents, council tax—

Benefits.

In my experience, you name it and they will deal with it.

Perhaps Jonathan Lenton might want to comment before we move on to questions from Colin Beattie.

I would just add that in Ombudsman Services we talk about strategic redress—as well as helping the individual, we think about how we can work with other organisations to improve the consumer experience. There are four pillars of consumer protection: advice, advocacy, enforcement and redress. How the organisations work together can determine how the consumer experience can be improved. Has that worked brilliantly well in the past? I would say that it probably has not. We are improving as a group of organisations. For example, in energy, we have a tripartite arrangement with Citizens Advice UK and the Office of Gas and Electricity Markets. We get together every month and look at our data and we identify issues that are causing detriment to consumers. Then we put a plan together on what Ombudsman Services, as the alternative dispute resolution provider, Citizens Advice, as the advice provider, and Ofgem, as the regulator, are going to do. We think that the intention behind consumer Scotland suggests that such an organisation could really add to that co-ordinated approach and conversation.

I have a very simple question. Does the bill give consumer Scotland the necessary powers to carry out its role?

Yes.

Why?

Because of what it is intended to do. Consumer Scotland is intended to be a research body and an investigatory body—it is important to say that I do not mean that it will investigate an individual transaction or company, but rather that it will look at investigating markets. It will be a body that develops policy and advocates on behalf of consumers. You could add extra powers, Mr Beattie, if you wished it to do additional things. There is a question about super-complaints, for example. However, in relation to the four tasks that it has been set—and the things that it will not try to do—it has the right balance of powers.

I point to the good work that Citizens Advice did a few years ago highlighting the loyalty penalty. Citizens Advice found that customers who stay with companies for a period tend to pay more than new customers and that vulnerable customers are more likely to stay with their service provider, which means that that group is significantly impacted. That is the kind of work that we expect consumer Scotland to do for Scottish consumers. The work that Citizens Advice did has had big ramifications in some of the sectors that we are involved in—we can see the impacts on the energy and communications sectors, with policy makers looking at the research and doing something about it.

I will repeat the question. Does the bill give consumer Scotland the necessary powers to carry out its role?

Again, I note that this is probably not my area of expertise. One thing that we like in the bill is the fact that it places an expectation on public bodies that they will take into account the impact on consumers of any future changes to the law. We think that that is pretty good. I do not know what my fellow panel members think, however.

12:15  

Scotland will be the first part of the UK to do that. We have been huge champions of it. On occasion, we had some difficult conversations on the subject with the minister, but he has been really supportive, and we think that it is a really important step forward.

I suppose that, when we look at consumer Scotland’s powers, the biggest thing that we see is lacking is that it does not have any enforcement powers. Is that a problem?

It is not, because consumer Scotland is not trying to be an enforcement body. I will put that the other way round. Because it is not trying to be an enforcement body, it does not need enforcement powers. Which? is not an enforcement body and neither is Citizens Advice Scotland. We do research and advocacy. We are not trying to step on the toes of others.

I saw Norrie Kerr nod his head in response to my question.

I return to my original point. What is consumer Scotland for? It will have no enforcement powers, and we already have organisations such as the Competition and Markets Authority and trading standards, which have such powers. If it will just be another research body that seeks to influence people, then I am sorry, but in my view we already have that across the consumer landscape.

Can I interject? I have a question for Thomas Docherty. In the Which? submission to the committee, you say:

“The proposed Bill provides Consumer Scotland with the necessary powers to adequately represent consumer interest and achieve its stated aim of improving support for Scottish people.”

To be clear, you consider that it does not need any enforcement powers or actual powers to make anything happen in order for it to achieve those aims.

Yes, because—

What are its powers, then?

I am sorry to repeat myself, but consumer Scotland will not try to act like a trading standards body or a regulator. Those are the two particular areas where it would need enforcement powers. It will try to look at areas such as banking services and access to cash, legal services, telecoms and rail, to give you four examples. None of those issues has had any attention from a consumer body in Scotland in recent years, although members of the committee have lodged many questions and raised issues to do with the quality of services in their areas. We have identified that consumer Scotland could look at the problems with those things and come up with solutions.

As I said, there is also an argument on the question of super-complaints, which could be considered if that was subsequently felt to be useful. Fundamentally, however, we think that the bill strikes the right balance.

We will go back to Colin Beattie.

I will remain on the subject of what consumer Scotland should and should not do. Would you like it to do anything in particular in the area of consumer redress?

There are a number of areas of consumer markets where access to ADR schemes and ombudsman schemes is not compulsory and we believe that the detriment is severe. There are many areas that consumer Scotland could choose to focus on. I hope that, in the first couple of years, it will carry out an investigation into how Scottish consumers are affected by not having a right to automatic ADR in some of those areas.

We have some experience of offering ADR in unregulated sectors. We opened the consumer ombudsman service in 2015 following the introduction of new regulations that required all traders to make customers aware of ADR, but traders were never compelled to use the ADR scheme that they had to inform their consumers about. Actually, without—

Can I interrupt? The question was whether you would like consumer Scotland to do anything in particular in the area of consumer redress.

I do not anticipate that consumer Scotland would act as a redress body but, like Thomas Docherty, I think that there are areas in business sectors where the lack of redress causes problems for consumers. I reiterate that that would be an interesting area for consumer Scotland to explore.

I agree.

A couple of points have been raised about banking. Which? has done a report on Scottish banking, the Scottish Affairs Committee at Westminster has done an inquiry into banking and bank closures, and this committee has done an inquiry into bank closures. There has been research into the problem, and solutions—or, rather, suggestions; using the word “solutions” may be going too far—have come out of that.

You mentioned the loyalty penalty work done by Citizens Advice Scotland. I am in no way trying to be negative about that, but we have known for years that there is an issue about losing out by staying with one supplier. I am struggling to see how the proposed organisation would provide additional opportunities to look at that issue. To some extent, there are already organisations that cover the issues that you have highlighted.

About 18 months ago, I had a wonderful morning giving evidence to this committee on the issue of banking, which is why I raised it. If you recall, I said that we had produced some statistics. We had what I call “What?” statistics—about what the loss of branches had been. We have since put up new information saying that, in the past five years alone, 30 branches have gone from Scotland. However, no work has been done on the reasons why. As I said to the committee at the time, no work has been done on the longer-term impact. It is all very well having statistics—frankly, there is no shortage of statistics, as long as agencies such as ours can produce lots and lots of numbers—but what has been missing so far is an investigation into those statistics.

Do you not think that this committee and the Scottish Affairs Committee should be doing that, and coming up with recommendations? That is what committees do. We take evidence from organisations such as yours, the banks and various consumer groups and individuals, and come up with suggestions or solutions.

I will use banking as an example, but this would apply equally to telecoms, rail or whatever else. Our advice to the Scottish Government would be based on the work that we have done. We fund ourselves—we are not a publicly funded body and we take no money from the taxpayer. The cost of doing a substantive piece of work to get into the problem in Scotland would be six figures. This committee does not have six figures to spend on that type of in-depth research to understand the everyday finances that people are trying to use. That is work that is not currently being done. Such research would include market research and polling, and doing focus groups in, say, the Highlands and Islands, Edinburgh and Kilmarnock. It would involve proposing solutions and then campaigning. That is where the advocacy comes in. The committee made some brilliant, thoughtful recommendations to UK and Scottish ministers, many of which, disappointingly, neither Government has so far chosen to take up. That on-going advocacy work is the bit that consumer Scotland should be doing.

I will continue on the research aspect. When a consumer has a problem, they might go to citizens advice or trading standards, or they might phone up Which? for advice. In my constituency, there is also the Community One Stop Shop, which is not aligned with any of the other organisations. There is a wealth of case history out there. Is any organisation pulling all that together to identify trends, problems or areas that should be investigated?

From the lack of response, I take it that the answer is no. There is therefore a need for a body that will do that type of work. In order to do so, it will have to have the agreement of all the organisations to share that data. Are there any issues that would prevent an organisation from sharing that data?

I do not believe that sharing the data would be an issue. The question would be how anonymised the data would need to be. Organisations already collect data and they now have general data protection regulation responsibilities. If they are not already collecting data that can be anonymised, the question is what they do with all the old stuff. The preparation of that data to give to a new body might require quite a bit of work.

I have a meeting on Thursday afternoon—I do not know whether Jonathan Lenton will be there—regarding the Scottish Government’s data working group that is digging into the issue that Mr MacDonald raised about what we would need to do. We already share data, exactly as Norman Kerr said, and we take out individuals’ details in order to do so. It is the trends that are crucial, though. The issue is not that one person has had a bad experience of buying a used car, for example. The data that ADS collects shows that large numbers of people have problems with used cars or with buying furniture, which is another common problem. Pulling together that kind of data is very important.

Could there be a specific role for the new organisation? For instance, I am aware that there is not a recall database in the UK, whether the recall is about cars or other products—Which? had a campaign recently about tumble dryers, I think. Is there a need for an organisation to highlight to consumers all the recall issues, or the concerns arising from research? We talked earlier about consumer education. Which? has been very good over the years at promoting best-buy products and so on, but there does not seem to be general information out there from organisations, unless you are a Which? subscriber. Is there a need for that type of information to be out there?

Yes, definitely.

The size and shape of the proposed organisation means that it would have 20 staff and a budget of £2.5 million. However, we are already seeing so many issues mount up that they would be too much for an organisation of that size as it tried to create the database that Mr MacDonald wants as well as get the co-operation of myriad other organisations. If we want the organisation to do that, we need to be explicit in the bill about its role and be more realistic about a budget. Thomas Docherty talked about a six-figure budget for research, but if the kind of money that we are talking about is £2.5 million, we will not get much research each year from an organisation of that size.

The organisation could have a signposting role in the early days, until the point at which it built up some form of database.

It could.

That is absolutely crucial. The Scottish Government has been very clear, and we have all said, that there is a confusing landscape for consumers. It is not always about inventing something new; it is about ensuring that consumers know where to go, whether that is to the ombudsman service for redress, or to trading standards, or to Advice Direct Scotland if what they need is information on their flight rights, for example. I am thinking of the dreadful news over the past two weeks about Thomas Cook.

Thank you.

Thomas Docherty gave examples earlier about some issues that have come up, such as the availability of cash and the disparity in digital connectivity. Is it the case that such issues have never had a home to which people could go to raise complaints or issues? Might consumer Scotland begin to hoover up some of those issues that have not had an obvious home? Is that what the bill and the proposed body will provide?

12:30  

That is an excellent question, Mr Coffey, and I think that there are two parts to the answer. First, part of the issue is that there has not been a body that has had responsibility for looking at such issues, to gain an understanding of what causes them and what the redress might be, and to advocate for that.

Secondly, some of the issues—perhaps not ScotRail, but digital connectivity—are emerging. We are all of a certain age; the idea that we would sit with our phones all the time is new. There is an expectation that broadband is the fourth utility. People expect more than just the 10 megabits per second universal service obligation minimum, and they expect to be able to use their phones all the time.

In the past 30 years we have gone from having 24,000 bank branches in the UK to about 7,500. There has been a reduction in ATMs, too.

Those are emerging issues. Again, it is about working with others, such as Ombudsman Services, Which? and CABx, to identify emerging threats and come up with an action plan. I will be so bold as to say that I would be amazed if this committee did not have suggestions for what consumer Scotland might focus on in its first couple of years. It cannot focus on all the issues in its first year. It could probably do two a year, and it might do a third, as it grows.

Constituents come to me about the plethora of ridiculous fees that are attached to buying concert and theatre tickets. For example, there are multiple booking fees, so if someone buys four tickets they pay four booking fees. Such issues have been a problem for years. Can we expect consumer Scotland to deal with that issue? How would it do that and make recommendations for—in this case—the UK Government?

In the context of the UEFA nations league next summer, I understand that the Scottish Government will introduce a bill on secondary ticketing—I think that that is correct. That is exactly the type of issue on which consumer Scotland might say, “Look, in Scotland we have a problem. At big festival events and big sporting events, we see consumers being ripped off. Here are our proposals”—although I am not suggesting that it would do that next year. It is not just about going to the UK Government all the time; it is about going to the Scottish Government or the regulator and saying, “We have identified a pattern of bad behaviour, and these measures could be taken to address it.”

The new body could look at that issue, then. Has a previous body ever looked at it and had any success?

We did some work on secondary ticketing at UK level, to highlight practices. The CMA, to its credit, has done some work to crack down on people such as Viagogo. However, not enough work has been done on, for example, the extent of the problem in Scotland and the powers of the Scottish Parliament and Scottish Government to address it.

There is some potential for us there. Thank you.

As drafted, the bill protects only individual consumers and does not extend to small businesses or sole traders. Has it got the balance right in that regard?

As I said, I do not think that the bill is needed, but if it goes ahead, my answer to your question is no. It would need to take cognisance of all consumers, and small traders are consumers.

We are running an event today at the Tory party conference on exactly that issue, that is, the detriment that is experienced by small businesses. As we see it, a lot of microbusinesses face exactly the same issues as consumers face, in the context of knowledge of the market, bargaining power and ability to enforce their rights when things go wrong.

The Financial Ombudsman Service has just expanded its remit to cover businesses with up to 50 employees. We are limited to 10 employees at the moment. We are arguing that the protection of alternative dispute resolution should be extended, and we certainly agree that microbusinesses in Scotland should be entitled to the same protections.

What would the cut-off point be, based on what is in other legislation? Would it be 10 employees? What is best practice?

The current figure that is used is fewer than 10 employees, for a microbusiness.

Yes. In the world of ADR, we are used to the definition of a microbusiness as being one that has 10 employees or fewer. Our argument now is that we think that businesses that are slightly larger than that need protection.

I have a brief final question. What are your views on the consumer duty aspect of the bill? What do you think of what is proposed in that regard?

We worked very hard, along with other organisations, to persuade the Scottish Government that such a duty would be a welcome step forward. Rail is a very good example of why it is needed. At the moment, there is not a duty on the body that runs the railway to consider consumers in doing so. Anyone who lives in Fife or Dumbarton will probably have suffered at the hands of Scotfail in the past couple of years. That is the kind of area in which people will benefit from the consumer duty.

To be fair, we agree with Citizens Advice Scotland that the specific wording that is used in the bill about having due regard to consumer interests needs to be looked at but, fundamentally, what is proposed is a pioneering step. Scotland will be the first part of the UK to have a consumer duty. The other Administrations are looking at having such a duty. If we get consumer Scotland right and we get the consumer duty right, Scotland will be at the front end—as is so often the case—of improving the environment for consumers.

I see that others are nodding their heads. Do you agree, Norman?

I do.

I thank all three of you. [Interruption.] I am sorry—I beg Jackie Baillie’s forgiveness. She wants to ask a final brief question.

Absolutely. Thomas Docherty mentioned Dumbarton. Does he not appreciate that members of the Scottish Parliament have consistently raised concerns about ScotRail with the Government? We will have a debate on the issue this week. What will a Government agency be able to do that will be different from what MSPs currently do? How will it be any harder than we are?

The key thing to remember is that consumer Scotland will not be a Government agency any more than CAS is a Government agency.

Consumer Scotland will be a consumer agency.

It will be a consumer agency that will be accountable to the Parliament, not the Government. I am always in bewildered awe of Jackie Baillie’s tenacity on behalf of the people of Dumbarton, and I would never be brave or foolish enough to say that anybody could work as hard as Jackie Baillie does.

There you go. I think we’ll stop there, convener.

I think we will. I thank all three witnesses for coming in.

12:37 Meeting continued in private until 12:54.