Strategic plan 2009-2012

Last updated 24 October 2008

1. Foreword

The Solicitors Regulation Authority exists for one overriding reason: to protect the public by ensuring that the legal services they receive from solicitors' firms are of a high standard.

In 2006, we set out our strategic objectives, and we began work on reforming our inherited processes to make them fit for the new world of legal services envisaged by the Legal Services Act 2007. We have achieved a good deal, but a huge amount remains to be done.

This strategic plan sets out in more detail how we are planning to achieve our objectives. We are issuing it not simply to explain what we intend to do, but also to invite your views—whether as a client, a solicitor, one of the many organisations involved in legal services, or a member of the public: have we set the right priorities; is what we are doing the best way of meeting our objectives; are we being fair to all those for whom and with whom we work; and are there other matters which we ought to have included?

This plan, which we shall review at least annually, will be the means by which we plan our activities, by which we judge ourselves, and by which we invite others to hold us accountable.

We would welcome your views.

Peter J Williamson
Chair, SRA

Antony Townsend
Chief Executive, SRA

2. About the Solicitors Regulation Authority

The Solicitors Regulation Authority (SRA) was established in January 2007 as the independent regulatory body of the Law Society of England and Wales. We set standards for, and regulate, more than 100,000 solicitors, and 10,000 solicitors' firms, in England and Wales.

The SRA is overseen by a board which includes solicitors and lay members. Its role is to set the strategy, and to ensure that the SRA is an effective organisation, operating in accordance with the principles of good regulation.

The solicitors' profession is diverse and includes single-solicitor practices and huge firms with a global presence and thousands of lawyers. Solicitors also work in the justice system, in government and public bodies, in commercial companies and in not-for-profit organisations. All solicitors follow the same professional principles and code of conduct. We provide advice and guidance to help them do so. From 2009, as the Legal Services Act begins to reform the delivery of legal services, we shall increasingly regulate firms delivering legal and non-legal services.

Our overall aim is for the public to have full and justified confidence in the solicitors' profession. There are a number of activities that we undertake which together set out how we regulate the profession. These include

setting the standards for qualifying as a solicitor and for solicitors' continuing professional development,
monitoring the performance of organisations that provide legal training,
providing rules of professional conduct, particularly to make sure they protect the interests of consumers,
providing authoritative guidance and rules to solicitors on ethical issues, laws and regulations that affect solicitors' work,
administering the roll (register) of solicitors,
providing information to the public about solicitors, their work and the standards the public is entitled to expect,
monitoring solicitors and their firms to make sure they are complying with the rules,
exchanging information with other regulators and law enforcement agencies in order to protect the public,
investigating concerns about solicitors' standards of practice and compliance with the rules, where necessary taking proportionate regulatory action,
when necessary, closing down solicitors' firms so as to protect consumers and the wider public, and returning papers and monies to their owners,
referring solicitors to the independent Solicitors Disciplinary Tribunal (SDT) and dealing with the prosecutions,
running a compensation fund to help people who have lost money as a result of a solicitor's dishonesty or failure to account for money they have received.

The SRA is improving its systems and processes, and developing its people through a managed change programme. A number of projects underpin the delivery of the outcomes across the themes in this plan. The decision-making project aims to ensure that regulatory decisions are made consistently, fairly and transparently at the appropriate level throughout the SRA, in accordance with principles agreed by the Board after public consultation. The organisational development project will support the management of our performance and the development of our competencies. Our equality and diversity strategy and action plan will help us to create an inclusive, transparent SRA that promotes equality and values diversity:

as a fair employer, recruiting, developing and retaining a diverse and talented workforce,
as a fair regulator, open, proportionate, non-discriminatory and transparent in the way it regulates a diverse profession,
as an inclusive consumer-focused organisation.

3. Our statement of purpose

To set, promote and secure in the public interest standards of behaviour and professional performance necessary to ensure that consumers receive a good service and that the rule of law is upheld

4. Our principles

In all our work, we will

be fair and consistent in our contacts with the public and the regulated community,
be inclusive and actively promote equality and diversity in the way we undertake all our activities,
act independently of, but in consultation with, our stakeholders including consumers, the profession and its representative bodies, the judiciary and government,
operate in accordance with Good Regulation principles, adopting a risk-based approach to regulation,
be open and accountable,
demonstrate value for money.

5. Our values

i. Ethical

The solicitors' profession is underpinned by a strong ethical framework, and the SRA, in the way it operates, must adopt the same framework. We strive to demonstrate that we are open and honest in all our dealings, whether with the regulated community, consumers of legal services and other members of the public, or with our colleagues. In our decision making, our objective is to be fair, consistent and proportionate and seen to be so. We aim to be inclusive in all that we do and in particular in developing our policies.

ii. Serving our stakeholders

We come into contact with a diverse range of individuals and organisations in a variety of situations. We will aim to ensure that in each situation we understand the needs of those we come into contact with, and will be clear about our expectations in order to manage the expectations of others. We will always be courteous and prompt in our responses and will listen to and learn from those who wish to give feedback.

iii. Accountable

We are accountable primarily to the public, in whose interest we aim to act, as well as to our regulated community and to a wide range of stakeholders, including the Legal Services Board, which oversees the work of legal services regulators. We will demonstrate our accountability through the rigour with which we set and uphold standards and the transparency of our decision making.

iv. Performance focused

Our performance will be focused on the delivery of the strategic plan. Each committee, directorate and individual will have clear objectives which are directly linked to the achievement of the strategic aims and objectives. We will strive for continuous improvement through the management of performance and staff development, and we will tackle poor performance effectively and at the earliest opportunity.

v. Diversity, respect and recognition

We will ensure that we meet our statutory responsibilities towards our staff, the regulated community and other stakeholders. We will work in partnership with our stakeholders so they feel listened to and valued. We are committed to a working environment that is safe and free from harassment and discrimination. We will create a diverse workforce that is reflective of the diversity of the regulated community and the public at large. We will work in partnership with our staff, the regulated community and our stakeholders and demonstrate that we recognise the value of their different perspectives and contributions in achieving our aims and objectives.

6. Our planning process

This is the first strategic plan published by the SRA. It builds on and pulls together a number of initiatives that the SRA Board and its executive team have undertaken since late 2006.

The SRA Board agreed its strategic objectives in late 2006.
The organisational structure of the SRA has undergone a major overhaul to ensure that the new directorates are geared up to deliver the strategy.
Each committee which advises the Board has developed a work plan which aims to deliver the Board's strategic aims and objectives.
Each year the SRA prepares a business plan and annual report, which are available from our website.
The SRA will also publish an equality and diversity strategy in 2008, and will provide annual reports on the implementation of its equality and diversity action plan.

We have taken the opportunity to reflect on these and on developments in the environment in which we operate, and have drafted our strategic plan. We have set out what we want to achieve by 2012 and, in many cases, by earlier dates.

The strategic plan provides an opportunity to ensure that our business plan, our committee work plans and every individual's objectives are geared to the delivery of our strategic aims. We will review these for strategic fit and make adjustments where required. This is a process of continuous improvement.

On a day-to-day basis, our strategic plan helps us to focus on our priority areas and to identify and manage the risks that may undermine our ability to deliver our aims and objectives. Necessarily, these documents as well as the key performance indicators (KPIs) and business plans sit separately, but we will report regularly on progress.

7. Steps to achievement

Our annual business plan is the mechanism for setting out the detail of what aspects of the strategic objectives we will achieve in each year, when we will achieve them and how. Work on our 2009 business plan will commence in September 2008. The objectives of all teams and individual staff within the organisation will be clearly linked to the strategic plan. Complementary to the business plan will be the work plans for each of the SRA's committees.

8. Monitoring progress and measuring success

Progress will continue to be monitored through the use of KPIs and other reports produced on a weekly, monthly or quarterly basis according to need.

We will measure our success through the use of a range of methodologies including KPIs, external evaluations, surveys, and formal and informal feedback from institutions and other stakeholders. Evaluating our success will require an understanding of the impact and benefits of our work and the changes we will have helped to bring about in relation to public confidence in those we regulate and confidence in us as a regulator by both the public and those we regulate. We will publish an annual report reviewing our progress.

9. Strategic risks

We have identified a number of risks which could impede the achievement of our strategic themes and objectives. These are outlined in relation to each strategic theme.

Our strategic risk register, which sets out the risks and strategies for managing them in some detail, is a working document which helps to guide our work and will be monitored and reviewed on a regular basis.

The rapidly changing legal landscape requires us to be adaptable and responsive in managing risk and taking opportunities.

10. Strategic themes 2009–2012

Theme 1: Setting the standards

To set standards for entry to the profession, professional behaviours and continuing professional development so as to maintain and enhance the competence, performance and ethical conduct of solicitors and uphold the rule of law
To set standards for organisations offering legal services

Theme 2: Support and monitoring

To provide information, advice and support to those we regulate to help them comply with the standards set
To operate processes to monitor compliance with standards, so as to identify cases requiring remedial, investigative or other regulatory action

Theme 3: Consumer protection, enforcement and discipline

To protect consumers by ensuring effective professional indemnity and compensation fund arrangements
To tackle unacceptable professional or organisational performance, misconduct and dishonesty by firm, fair, timely and proportionate regulatory and disciplinary action

Theme 4: Access to justice, transparency and consumer information

To promote choice, innovation and accessibility in the provision of legal services through various types of business structure
To provide information to help consumers to make decisions about legal services and to understand the standards they are entitled to expect

Theme 5: Organisational improvement

To demonstrate value for money in all our dealings
To attract and retain diverse, high calibre staff who are committed to service excellence through continuous business improvement

Theme 1: Setting the standards

To set standards for entry to the profession, professional behaviours and continuing professional development so as to maintain and enhance the competence, performance and ethical conduct of solicitors and uphold the rule of law
To set standards for organisations offering legal services

Current delivery

The Solicitors' Code of Conduct 2007 aims to provide a concise and coherent set of rules which provide effective client protection whilst reflecting modern business practice. The Code adopts a simple structure of core principles and mandatory rules accompanied by non-mandatory explanatory guidance. This represents a move away from the previous, sometimes confusing, mix of material.
The SRA's Professional Ethics Helpline provides regulatory guidance to solicitors on matters of professional conduct, including issues arising from the introduction of the Code. When solicitors were last surveyed, in 2006, it was rated as by far the most valuable service the Law Society (of which it was then part) provided to solicitors (see also 2.3 below).
The SRA's legal education, training and professional development activity supports the setting of ethical values and standards for those entering the profession and for their maintenance on the roll. This involves considering applications from those seeking to become students and solicitors, and overseeing the quality of all training provision ranging from academic institutions and continuing professional development (CPD) providers to training establishments.

1.1 Ethical standards and rule-making

Where are we now?

The new principles-based Code of Conduct was launched in July 2007 and continues to "bed down".
We provide guidance on the rules and interpretation where necessary, identify issues which have an impact on policy in relation to regulation of solicitors and draft new or amended rules as required.
New rules under the Legal Services Act 2007 were made in July 2008 and come into force in March 2009.
Written guidance to accompany each new rule is currently under development.
A training programme for all staff on the new rules is also under development.

Objectives

To set and communicate effective and proportionate standards of professional behaviour and performance
To make effective rules to secure acceptable standards of safe, competent and honest practice
To ensure that our rules are assessed for their impact so as to avoid unfairness or discrimination
To make our rules, supporting guidance and information accessible by all
To monitor the working of the rules in practice and identify where amendments or new rules may be necessary, or where rules become unnecessary

Outcomes

Our rules reflect principles designed to protect consumers and the public interest.
Our rules are clear, proportionate, targeted at identifiable risk and promote competition in the legal services market.
Our standards and rules do not have unjustifiable adverse impact upon individuals and groups.

Risks 
The rules will not be made or be approved in time. 
The public will not be adequately protected. 
Some of the rules will be unenforceable, ignored or not understood. 
Identified risk will not be dealt with effectively. 
Failure to identify and manage external change and lose opportunities 
Additional, unanticipated demands on staff time or inadequate resourcing 
Our impact assessments do not adequately identify all significant impacts, including those on particular groups within the profession. 
Legal challenges 

Measurement and reporting

Approaches used to measure success will include

using information from surveys of solicitors, regular meetings with solicitors to evaluate "workability" of the rules and effectiveness of the guidance and impact assessments,
analysing data routinely collected by our guidance team on type and frequency of queries and analysis of patterns of non-compliance,
using feedback from consultations and other feedback on impact assessments from diverse groups and individuals.

1.2 Standards of entry and service delivery for individuals

Where are we now?

A comprehensive reform programme is underway to ensure that all parts of the qualification process together deliver the "day one" outcomes (attributes required of solicitors at the point of qualification). These include changes to the structure of the legal practice course, piloting work-based learning and a fundamental review of qualified lawyer transfer processes.
We are developing a strategy for assuring the quality of services by solicitors once in practice. This includes reviewing accreditation and CPD.

Objectives

That our activity is designed to ensure that those joining the profession

come from a wide range of backgrounds and experience and have an understanding of equality and diversity issues and of their legal and professional obligations towards their clients and employees in this area,
meet appropriate standards of character, knowledge and skills and ethical behaviour,
are able to sustain client confidence,
understand and are able to sustain commitment to the rule of law,
demonstrably uphold the principles governing those providing legal services: independence, integrity, the duty to act in the best interests of clients and client confidentiality.

Outcomes

Our standards for admission to the profession and for non-lawyer partners in legal disciplinary practices (LDPs) will

be appropriate to protect consumers and the wider public interest,
be proportionate and based on evidence of risk,
enable entry from applicants from a wide range of backgrounds,
be capable of ensuring competence.

Our arrangements for permitting individuals to remain in practice will

be appropriate to protect consumers and the wider public interest,
be proportionate,
sustain a diverse profession,
ensure continued professional competence.

Risks 
Quality of profession deteriorates 
Adverse impact on individual consumers 
Legal challenge against individual entry decisions 
Loss of confidence in the SRA 

Measurement and reporting

Approaches used to measure success will include

benchmarking changes against existing levels of diversity within the profession,
assessing fitness for practice through surveys of practitioners and their employers plus routine monitoring visits,
obtaining feedback from consumers of legal services.

1.3 Standards of entry and service delivery for firms

Where are we now?

Rule 1, rule 2 and rule 5 of the Code of Conduct lay down requirements relating to competence, standards of service, client care and business management.
Extensive training and promotion of the requirements of these rules has now taken place.
The framework for the character and suitability tests for non-lawyers has been approved by the Board.

Objectives

That our activity is designed to ensure that firms regulated by the SRA

are managed by those with appropriate standards of character, knowledge, ethical behaviours and business management skills,
exercise appropriate control over their employees and operations,
are able to sustain client and public confidence,
uphold the principles governing those providing legal services: independence, integrity, the duty to act in the best interests of clients and the rule of law and the proper administration of justice.

Outcomes

Our standards for non-lawyer partners in legal disciplinary practices (LDPs) will

be appropriate to protect consumers and the wider public interest,
be proportionate and based on evidence of risk,
enable entry from applicants from a wide range of backgrounds,
be capable of ensuring professional competence.

Risks
Rules 1, 2 and/or 5 will be ignored, misunderstood, prove difficult to enforce or discriminatory, 
have failed to set the client and public protection at the correct level. 

The character and suitability tests will prove inadequate. 

Measurement and reporting

Approaches used to measure success will include

using information from surveys, and regular meetings with, solicitors and consumer groups to evaluate "workability" and effectiveness of the rules and guidance and impact assessments,
analysing data routinely collected by our guidance team on type and frequency of queries and by our standards advisers and caseworkers on non-compliance.

Theme 2: Support and monitoring

To provide information, advice and support to those we regulate to help comply with the standards set
To operate processes to monitor compliance with standards, so as to identify cases requiring remedial, investigative or other regulatory action

Current delivery

Our Ethics Helpline received over 67,000 calls from the profession, whilst the guidance service dealt with more 4,000 letters and emails. In 2007–2008, a number of improvements to working methods have been introduced to improve capacity and quality of service. We also provide information to solicitors through our contact centre and our website (see Theme 5 below).
We operate processes to monitor compliance with standards, in order to identify cases requiring remedial, investigative or other regulatory action. We use office and field-based investigators proportionately across the risk range and have central risk assessment and information-gathering units. The latter is developing the capacity to analyse information and monitor trends in the profession. In 2007, our practice standards advisers visited 9 per cent of all firms.
We have also promoted the use of our staff in presenting topics to local groups from the public and the profession with the aim of raising the practice standards of the profession. In 2007, we gave 10 client care seminars. We have also held a well-attended series of regional regulation roadshows, highlighting important regulatory issues and developments for solicitors.

2.1 Information collection and analysis

Where are we now?

We have identified the IT and web requirements to enable us to integrate, collect, maintain and analyse information more effectively than at present.
We have completed an external consultation on future information requirements and will complete an audit on the information currently held by the SRA by the end of 2008.
An Information Unit and cross-directorate operational sub-group have been set up to drive forward these improvements.
A strengthened management information team has started to develop a comprehensive range of KPIs and trend analyses.
The Risk Assessment and Designation Centre is in full operation dealing with reactive assessment and is now integrating proactive profiling into its processes to support other areas of the business.

Objectives

To hold our information centrally so that it can be readily accessed by all staff (subject to permissions)
To have a consistent approach to risk management, information and decision making across the organisation
To ensure the information gathered is relevant, accurate and complete to enable investigations, decisions, policy and strategy to be based on evidence of risk
To have a single forum for collection, analysis and feedback on how we are using our information to inform our priorities as we move forward
To audit the accuracy of our information in relation to compliance and support activity and the information firms and individuals provide us with
To achieve excellent levels of accuracy of information provided by regulated individuals and organisations

Risks
Information is inaccurate, misleading or incomplete. 
Information is not produced in a timely or readable manner. 

Measurement and reporting

Approaches used to measure success will include

validation of recorded information against benchmark standards,
regular reviews of collected information to test its value as an indicator of risk,
gap analysis,
regular audits of recorded information to test for accuracy and completeness.

2.2 Mechanisms for support and monitoring

Where are we now?

We have established our proactive risk assessment processes during 2008 and continue to refine and improve them.
We will also make improvements in the scope and accessibility of information about the profession. This will enable us to monitor more effectively and better target our supportive practice standards visits to firms.
One measure of our success will be an increased proportion of consumers who have no grounds for complaint, together with a rising proportion of complaints dealt with in-house.

Objectives

To help the profession, particularly those organisations targeted for support by the SRA
To increase customer satisfaction with all regulated individuals and organisations
To reduce the number of consumer complaints against regulated organisations which have received support from the SRA
To ensure that the monitoring processes we operate are fair and non-discriminatory so as to prevent any disparity in the treatment of individuals
To reduce the number of consumer complaints against all regulated individuals and organisations
To develop and implement plans for supporting low-risk and medium-risk firms
To better understand the needs, expectations and concerns of the diverse groups within the legal profession
To ensure information is provided in a clear and consistent manner, written in easy-to-understand language

Outcomes

Effective machinery is in operation for advising and guiding solicitors and organisations.
Those we regulate value the SRA's information, guidance and support.
Our leaflets for the public are received positively.
There is an increase in standards and a decrease in poor practice.

Risks
The profession feels unsupported.
The public is unaware of the SRA or perceive it as ineffective.
Resources are wasted through missed opportunities to inform or prevent future trouble.

Measurement and reporting

Approaches used to measure success will include

written and oral surveys of users' experiences,
monthly reports of information and guidance provided,
analysing and publicising common areas of concern,
complaints records,
competence data.

2.3 Quality and timeliness of advice

Where are we now?

We have extended the opening hours of the guidance service and recruited additional staff.
We are improving response times for telephone, electronic and letter-based enquiries.
We are proposing a new organisation visit and assistance programme which combines office and field-based assistance during the first year of operation for a new provider of legal services that is regulated by the SRA.

Objectives

To ensure that the majority of solicitors are satisfied that they are getting the advice and guidance that they need from the SRA
To make sure that all information we produce relating to professional responsibility is clearly written and tested for clarity among the regulated community
To achieve excellent service standards for requests for advice and guidance via the following channels: web, telephone and written correspondence.

Outcomes

Accurate advice (and/or guidance) is readily available for practitioners through booklets, information leaflets and on the website
Routine enquiries by telephone or email will be dealt with in a timely manner
The Ethics Helpline is providing advice/guidance on complex professional issues in a timely manner and when practitioners require it.

Risks
Delays in receiving a satisfactory response 
Inconsistency of advice or guidance 
Advice or guidance too detailed or too superficial 

Measurement and reporting

Approaches used to measure success will include

telephone and written surveys,
monitoring and assessing the quality of written and oral advice or guidance,
collating of response data from monitoring systems and comparing with relevant KPIs.

Theme 3: Consumer protection, enforcement and discipline

To protect consumers by ensuring effective professional indemnity and compensation fund arrangements
To tackle unacceptable professional or organisational performance, misconduct and dishonesty by firm, fair, timely and proportionate regulatory and disciplinary action

Current delivery

Our rules require solicitors to have insurance for client losses of at least £2 million per claim and to contribute each year to the compensation fund which can make grants of up to £1 million in circumstances where insurance might not cover the loss.
We investigate possible misconduct by solicitors in a number of ways depending on the level of risk and the most effective way of gathering evidence. Many cases are dealt with by correspondence. More serious cases involve a visit to the firm and the use of strong powers to require the solicitor to provide documents and other evidence.
We prosecute the most serious cases at the Solicitors Disciplinary Tribunal, which has the power to fine, suspend or strike off a solicitor. Less-serious cases can be dealt with in our own adjudication system in accordance with our published decision-making criteria.
Very serious risk to the public can lead to our intervening into a solicitor's practice. There are a small number of occasions each year when we intervene into a practice, which has the effect of closing it down. We also have power to control the risk posed by particular solicitors by allowing them to practise only subject to certain conditions, such as that they should not handle client money or deal with certain types of case where there is evidence that they are incompetent or worse.

3.1 Consumer protection

Where are we now?

We set standards to protect consumers and ensure that they understand the service that will be provided to them and its likely cost.
We assess the risk disclosed by the information we receive suggesting that solicitors are not competent or have acted improperly.
We keep the scope of financial protection provided to clients under review and update our Compensation Fund Rules and Indemnity Insurance Rules when required.
We pay out between £10 million and £15 million in grants from the compensation fund in most years.

Objectives

To set standards that will protect and help consumers in their dealings with solicitors
To deal effectively with information from consumers or other sources suggesting that a solicitor may not be competent
To provide effective and coordinated arrangements to help consumers recover loss caused by solicitors

Outcomes

The standards set are transparent and helpful to both consumers and solicitors
All information we receive is dealt with in the public interest, fairly and in a non-discriminatory way
A high proportion of those who have used a solicitor within the last three years are satisfied with the service they receive
There are effective mechanisms in place to provide financial protection for consumers

Risks 
Resources focused inappropriately on particular areas of regulatory activity 
Growing demands on the compensation fund 
There is a lack of overall coordination and control at all interfaces between stages in the SRA's regulatory processes. 

Measurement and reporting

Approaches used to measure success will include

reviewing performance against KPIs for processes leading to intervention and SDT cases,
benchmarking changes against the existing level of complaints referred to the Legal Complaints Service (LCS).

3.2 Enforcement and discipline

Where are we now?

We receive and actively seek out information and intelligence to enable us to assess risk and decide on the right level of investigation to protect the public and the administration of justice.
We have published the criteria we use to assess risk, part of our drive to maximise fairness and transparency in all of our work.
We use a range of methods to investigate possible misconduct including forensic investigation visits and desk-based investigation.
We prosecute up to 300 solicitors each year before the Solicitors Disciplinary Tribunal.
We require solicitors to practise under carefully controlled conditions when they may pose a risk.
We are preparing rules to implement our new powers to fine and publicly rebuke solicitors without the cost and delay involved in a prosecution at the Solicitors Disciplinary Tribunal.
We are preparing a re-tendering exercise for intervention agents for January 2009.

Objectives

To use risk assessment criteria that are fair and based on quality and objective intelligence and information
To secure sufficient evidence to enable prompt action to address risks to the public, to prove allegations before the Solicitors Disciplinary Tribunal, and to share with law enforcement agencies and other regulators where it may be appropriate for them to take action
To demonstrate fairness and transparency in our enforcement and disciplinary work

Outcomes

All investigations and visits are based upon transparent and fair risk criteria.
Our response to information is appropriately prompt and proportionate to the risk it discloses.
All relevant information is taken into account in risk assessment decisions, including past history.
We intervene into a solicitor's practice when it is necessary and proportionate to do so.
The most serious disciplinary allegations are prosecuted before the Solicitors Disciplinary Tribunal, and we are able to deal effectively with less-serious matters by using our own disciplinary powers.
We can show that our work is undertaken in a non-discriminatory manner.

Risks 
Disproportionate regulatory impact on minority groups 
Failure to deal promptly with solicitors' conduct that poses a high risk to consumers 

Measurement 
Risk evaluation and review 
Feedback from the regulated community on what causes regulatory breach, and how it can be avoided 
Research to understand the reasons for any continuing disproportionality in relation to particular groups 

Theme 4: Access to justice, transparency and consumer information

To promote choice, innovation and accessibility in the provision of legal services through various types of business structure
To provide information to help consumers to make decisions about legal services and to understand the standards they are entitled to expect

Current delivery

The Legal Services Act 2007 provides us with a framework for the delivery of legal disciplinary practices, and for the subsequent introduction of alternative business structures.
Our contact centre is the first point of contact with the SRA for many consumers, solicitors and others, receiving over 600,000 calls a year. It handles a wide range of enquiries and plays an important role in providing the public with up-to-date information about solicitors.
The SRA's website is an increasingly important part of our operation. It is being continuously expanded, and content of particular interest to consumers is now easily accessible. We now publish on the website information about the outcomes of regulatory action which has been taken in relation to individual solicitors. This is an important step in increasing transparency and facilitating consumer choice.
The SRA has begun to develop a consumer engagement programme. During the course of the year, we commissioned qualitative and quantitative research designed to explore consumer attitudes, and in particular to explore consumer awareness in relation to referral arrangements. Further consumer research is currently being planned. The research was subsequently presented to a forum of regulators and consumer bodies, held by the SRA in conjunction with the National Consumer Council. Plans are currently being developed for a permanent forum to look at consumer engagement issues.

4.1 Provision of choice, innovation and accessibility

Where are we now?

We are developing rules which will bring about the introduction of legal disciplinary practices (legal services bodies) where solicitors can work together with other legal service providers.
We are developing options for establishing alternative business structures where solicitors can work together with other professionals and legal practices can be owned by a wide range of individuals and organisations.

Objectives

To promote access to justice for all consumers by removing any unneccessary constraints in the ways legal services are provided, working where appropriate with the Legal Services Board and other regulators
To monitor the operation of the legal services market to identify continuing limitations to access and choice
To ensure that practitioners are aware of and understand the options available for delivery of legal services
To ensure that consumers from a diverse range of backgrounds have equal access to information about legal services so that they can make informed choices
To ensure that our rules are fair to all

Outcomes

The removal of unnecessary restrictions on the ways in which legal services are provided to consumers

Risks
Fail to identify and manage external change and lose opportunities 
Fail to achieve the right balance of regulation 
Fail to foresee potential consumer detriment 

Measurement and reporting 
Use feedback from groups within the regulated community to assess constraints to freedom of action on service delivery 
Analysis of issues and trends from data and information collected and held within SRA 
Analysis of data on the take-up of new models of legal service delivery 
Analysis of information on queries from the profession

4.2 Consumer information

Where are we now?

We have improved the structure and the layout of our website to make it easier for users to find what they are looking for, to provide new content, and to focus on the differing needs of our main user groups—consumers, solicitors, and students and trainees.
We are working on a web survey to find out more about visitors to our site and gain feedback.
We are in discussion with the Law Society about establishing the online register of solicitors.
We have undertaken some initial consumer research and are developing a consumer engagement programme.
Our contact centre is a significant and developing source of information for consumers.

Objectives

To ensure that up-to-date, accurate and relevant information is accessible to all consumers, so they can make an informed choice of legal service provider
To inform consumers about what to expect from providers
To make use of appropriate information available from the LCS (or the Office for Legal Complaints) and elsewhere to understand better the concerns of clients about legal service delivery
To develop relationships with consumers and consumer groups to gain improved understanding of consumers' needs and concerns, and the expectations which they have of the legal profession and the SRA

Outcomes

Clear, accessible and relevant information is provided for all consumers of legal services.
Information is available in a variety of formats to ensure that the diverse needs of consumers are met.
An accurate register of regulated individuals and organisations is available to the public.
There is a body of consumer-sourced information available evaluating the effectiveness of the SRA and regulated firms.

Risks
The SRA is unable to meet consumer needs and to act as a useful source of information for consumers of legal services. 
Failure to obtain and make information accessible to all groups of consumers 
Lack of technical infrastructure in place to support provision of register and regulatory information 

Measurement and reporting 
Using feedback from diverse consumer groups to assess ease of access to and clarity of available information 
Analysis of web visitor statistics and surveys 
Analysis of contact centre calls 
Analysis of information from the consumer complaints handlers 
Analysis of issues and trends from data and information collected and held within SRA 

Theme 5: Organisational improvement

To demonstrate value for money in all our dealings
To attract and retain diverse, high calibre staff who are committed to service excellence through continuous business improvement

Current delivery

We have established a change programme to support organisational improvement during this period of significant statutory and operational change. Business analysts and project managers from the change programme have been working with business champions and staff from within our operational units to prepare us for the changes ahead. We are working in partnership with information technology and human resources professionals to develop both our IT infrastructure and our operational effectiveness.
Each directorate is looking at the direction and effectiveness of its operations and making improvements in the ways in which
- we measure performance,
- our structure and processes fit the services which we will be delivering in the future,
- we use information to support our decision making,
- we make our processes and policies as fair and transparent as possible.
Our management information team is helping the business to develop a comprehensive range of KPIs for efficiency, speed and quality.
Our new information unit is improving the range and use of information collected to support short-term and long-term assessment of risk and trend analysis across the SRA.

5.1 Value for money

Where are we now?

A risk-based approach to allocating work has been implemented, made available to stakeholders and the public for comment, and is being further developed.
"Polluter pays" processes have been reviewed, and updated standard costs implemented across all conduct and regulatory matters decided at adjudication as from January 2006. Work is planned to improve collection and to extend the application of these charges where appropriate.
Redesign of business processes is identifying and removing duplication and inconsistency.
The decision-making and organisational development projects are making progess.

Objectives

To continue to implement risk-based regulatory processes, with proportionate allocation of costs
To put in place effective fee structures, including differential practising certificate and "licence" fees, and ensuring that the proportion of fees attributable to the SRA can be identified more accurately
To publish the full cost of regulation on an annual basis
To implement a modern IT system designed to meet the requirements of efficient, risk-based, information-led regulation
To automate and streamline our business processes wherever possible within the limits of current IT infrastructure
To develop effective, credible and consistent measures of overall effectiveness across the SRA's processes
To review and test all regulatory processes against the principles of good regulation
To put in place effective and efficient systems for the storage, retrieval and destruction of records
To develop and implement policies and procedures to ensure that we recover the costs of regulation wherever appropriate
To be able to demonstrate continuous improvement of business performance against challenging targets
To put in place challenging customer service standards and service level agreements
To ensure that, by the end of 2009, all regulatory decisions are made at the lowest safest level
To ensure that we produce high quality management information to drive internal efficiency and external accountability

Outcomes

The full costs of regulation are transparent.
Our business processes are efficient and effective, utilising technology wherever possible.
We can demonstrate that our business processes deliver value for money.
Our external service providers demonstrate value for money through adherence to customer service standards and/or service level agreements.

Risks
SRA is less efficient/effective than comparable regulators. 
Loss of credibility with stakeholders 
Unplanned reductions in service required to reduce costs 
Resources are inadequate to enable delivery of the strategic plan. 
Inadequate IT systems and services to enable delivery of the strategic plan 

Measurement and reporting

Approaches used to measure success will include

comparative activity costing and trends,
gap analyses,
monthly and quarterly financial reports to the senior management team and relevant committees,
consumer and professional surveys,
benchmarking against other regulators,
reduced challenges to SRA decisions.

5.2 High calibre staff committed to service excellence

Where are we now?

An organisational development project is running which will improve the consistency and effectiveness of performance reviews and provide an overall skills audit.
KPIs are being developed to support the improved performance management approach.
A review of salary and reward structures is in progress.
We have revised our organisational values.

Objectives

To recruit, retain and develop high quality and highly motivated staff through a culture of cooperative working
To support strong and consistent leadership
To ensure that SRA's shared values are maintained and demonstrated consistently by all staff
To recognise and reward appropriately the performance and contribution of staff to achievement of objectives
To maintain human resources policies and procedures that are fair, open and transparent
To put recruitment, training, personal development, mentoring, talent management and succession-planning schemes and targets in place to achieve better equality and diversity inclusion in the SRA's workforce
To achieve better equality and diversity inclusion in the recruitment of board, committee and adjudication panel members

Outcomes

Our recruitment and retention policies enable us to recruit and retain high calibre staff from diverse backgrounds.
We can demonstrate that our staff contribute efficiently and effectively towards achievement of the SRA's objectives.
Our values are shared by our staff and those with whom we work.
Our staff share a commitment to service excellence through continuous business improvement.
Our staff and managers at every level have the skills, knowledge and confidence to deal and work with the diverse range of individuals with whom they interact.

Risks
Lack of clarity about and consistency in SRA internal culture 
Loss of high calibre staff 
Staff feel undervalued and underdeveloped. 
Poor performance is not tackled. 
The organisation underperforms. 
Failure to recruit staff, board, committee and panel members from diverse backgrounds 

Measurement and reporting

A range of measures will be used including

staff surveys,
analysis of performance appraisals,
progress against objectives for teams and individuals,
analysis of recruitment and selection data,
KPIs.

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