Insights ¦ Research into Doorstep Interactions in Civil Enforcement

Key Take Aways

1. The enforcement sector demonstrates high compliance with National Standards, with 94% of visits adhering fully to guidelines.

2. Despite overall compliance, breaches occur predominantly around privacy breaches, vulnerability recognition, enforcement hours, and conduct that could cause public embarrassment.

3. Recognising and responding to vulnerability is notably deficient, with only 8 examples of agents acknowledging vulnerabilities during interactions.

4. Enforcement actions outside the permitted hours (6am–9pm) account for 1% of breaches, often without court warrants or clear legal justification.

5. Misrepresentations of enforcement powers and capabilities by agents are observed, risking misuse of authority and potential distress for individuals.

6. The use of body worn video (BWV) footage proves effective in objectively assessing enforcement conduct, with a carefully randomised and representative sample collected from multiple firms.

7. Instances of enforcement that breach privacy include disclosing details to unauthorised parties, leaving private correspondence in accessible locations, and capturing sensitive payment data on BWV.

8. Threats or actions that risk publicly embarrassing individuals — such as revealing debt details to third parties or making disingenuous threats — are identified, though infrequently.

9. Limited breaches related to the removal or threats to remove essential or personal household items are observed, often confined to discussion-based threats rather than actual removals.

10. Behaviour towards enforcement agents from individuals facing enforcement is generally non-aggressive; however, aggressive or threatening conduct occurs in approximately 1 per cent of cases.

11. Good practice is evident in empathetic engagement by EAs — including peaceful property entry, clear communication, providing receipts, and support for vulnerable individuals, which can mitigate distress.

12. Recommendations include expanding research scope to High Court enforcement, improving engagement with smaller firms, and refining standards based on observed behaviours to further professionalise enforcement practices.

Key Statistics

• 94% of viewed enforcement visits complied with all National Standards.

• 6% of visits flagged for breaches of Standards; with most breaches relating to privacy, vulnerability, hours, and public embarrassment.

• 8 instances of breach in recognising vulnerability; none for Breathing Space or IVAs.

• 5 visits (1%) involved enforcement outside of permissible hours without court warrant.

• 7% of videos paused or turned off prematurely; these are not classified as breaches but are relevant within sample analysis.

• 3% of videos breached GDPR legislation, through disclosure of personal information or payment details.

• 100% of property entries were peaceful and via usual means, with no breaches of lawful or peaceful entry standards observed.

• 1% of interaction videos showed individuals being aggressive or verbally threatening towards EAs.

• No instances of enforcement occurring in the presence of children under 16, aligning with standards.

• 91% support vulnerable individuals by signposting or facilitating access to debt advice.

• 100% of EAs provided receipts following payment, demonstrating transparency.

• Less than 2% of videos involved threats to remove goods or actual removal discussions, primarily through discussion and threats rather than actual asset seizures.

Key Discussion Points

• The high overall adherence to standards suggests professionalism within enforcement firms, though specific behavioural gaps merit attention.

• Recognition and management of vulnerable individuals during enforcement are consistently underperforming, raising concerns about fairness and compassion.

• Enforcement outside standard hours often lacks legal authorisation, risking legal challenge and reputational damage.

• Misleading representations of enforcement powers pose ethical and operational risks, underscoring the need for clearer, reinforced standards.

• Privacy breaches, including unauthorised disclosures and inappropriate handling of personal/payment data, need targeted mitigation measures.

• Incidents of actions likely to cause public embarrassment, such as revealing debt details, remain rare but impactful when they occur.

• Behaviour from individuals facing enforcement is predominantly non-aggressive; however, anecdotal evidence of hostility suggests ongoing risk for EA safety.

• Positive practices, such as peaceful property entry, clear communication, and offering support, demonstrate constructive engagement and customer care.

• The effectiveness of BWV as an evidence base underscores its potential utility in ongoing compliance monitoring and oversight frameworks.

• Limitations relating to the scope—excluding High Court enforcement and smaller firms—may restrict the full sector picture; future research should broaden this.

• Training and expert engagement are pivotal in equipping research teams to assess complex interactions accurately.

• The report advocates for refining standards and enforcement processes to reduce distress and enhance professionalism across the sector.

Document Description

This article is an in-depth research report assessing the behaviours and practices of enforcement agents during doorstep interactions with the public within the civil enforcement sector. It utilises Body Worn Video footage from a representative sample of enforcement visits across multiple firms to objectively evaluate compliance with established National Standards. The report covers enforcement conduct, identifying breaches such as privacy violations, hours of operation violations, misrepresentation of powers, and treatment of vulnerable individuals. It highlights examples of good practice and offers strategic recommendations for improving standards, training, and oversight, aiming to foster fairer, more professional enforcement practices in the UK context.