Pay or appeal against a late filing penalty beta assessment report
The report for Companies House's Pay or appeal against a late filing penalty beta assessment report beta assessment on the 29/10/2020.
| From: | Central Digital and Data Office |
| Assessment date: | 29/10/2020 |
| Stage: | Beta |
| Result: | Met |
| Service provider: | Companies House |
Previous assessment reports
Service description
These are two linked services, representing alternate actions a user can take when they are in receipt of a Late Filing Penalty for filing their company accounts after the deadline. Although they were developed by different scrum teams, there was close coordination between delivery managers and they share the same technical lead, designer, user researcher and performance analyst.
The Pay a Late Filing Penalty service allows users to pay for their late filing penalty online using a credit or debit card, as an alternative to prior existing payment methods such as BACS transfer, cheque and credit/debit card via phone calls.
The Appeal a Late Filing Penalty service will allow users to log an appeal against the penalty online, including the upload of supporting evidence, as an alternative to the existing processes – downloading and completing a form, then either emailing it as an attachment or sending a physical copy by post, or lodging the appeal via a telephone call, which will often require subsequent contact to provide documentary evidence.
The user will be directed to the services through URL links on their penalty letter.
The Pay a Late Filing Penalty service takes payment through GOV.UK Pay and is also integrated with the Companies House third party finance system.
The Appeal a Late Filing Penalty service is integrated with the Companies House third party finance system for retrieval and checking of penalty details only.
*Note that some users choose to pay the penalty and then appeal - there is no time limit for appealing a late filing penalty. If the appeal is successful, any penalty paid is refunded.
Service users
- Company Directors – who are ultimately responsible for the filing of the company accounts
- Accountants - filing on behalf of their clients
- Company Secretary or other representatives – authorised to act on behalf of the company.
1. Understand user needs
Decision
The service met point 1 of the Standard.
What the team has done well
The panel was impressed that:
- the team had used research to develop personas that reflected the range of service users. The team used those personas to explain the scope of their service and the way in which they’d prioritised users’ needs
- the team had used a variety of research methods and data sources including performance and call centre data
- the team understood the digital skills and confidence of the different user groups and the impact that might have on what they need.
2. Do ongoing user research
Decision
The service met point 2 of the Standard.
What the team has done well
The panel was impressed that:
- the team has tested with representative samples of their users, identified issues and improved the service for users
- the team has a plan for testing the service going forward using a mixture of methods and data sources
- user-research is closely aligned with performance analytics.
What the team needs to explore
Before their next assessment, the team needs to:
- the team has acknowledged they need to do more research with users with access needs.
3. Have a multidisciplinary team
Decision
The service met point 3 of the Standard.
What the team has done well
The panel was impressed that:
- the service team is well resourced with civil servants occupying key roles
- the team clearly work well together and are able to bring in more team members if required
- there is not high reliance on contractors
- the panel were impressed by the way in which the different parts of the teamwork together and the co-location of and close collaboration between the scrum team and the support team. The team had clearly worked hard to ensure that this link was not lost while the teams were working from home and this has clearly had a positive impact.
What the team needs to explore
Before their next assessment, the team needs to:
- ensure the transition to a new service owner is planned and with an appropriate handover period so it does not impact on the service.
4. Use agile methods
Decision
The service met point 4 of the Standard.
What the team has done well
The panel was impressed that:
- the team have a well-established cadence and use ceremonies effectively to allow them to deliver at a good pace
- the team have clearly iterated the service since their last assessment and are able to show how user needs have been at the centre of all the changes made
- the team are using tools well to help them manage their work
- the panel were impressed by how the team could address the impact of working from home on their delivery and how they had changed their ways of working to support their work when 100% remote.
5. Iterate and improve frequently
Decision
The service met point 5 of the Standard.
What the team has done well
The panel was impressed that:
- the team have iterated the service regularly and were able to demonstrate clear examples of how their user research had impacted on the design of the service.
- the team demonstrated their commitment to changing policy in response to user research where possible.
- the panel were impressed by the team’s response to Covid-19 restrictions and their work to change postal addresses to allow for working from home measures.
What the team needs to explore
Before their next assessment, the team needs to:
- ensure that this work to iterate and improve the service continues through the Public Beta and that they return for a Live Assessment
6. Evaluate tools and systems
Decision
The service met point 6 of the Standard.
What the team has done well
The panel was impressed that:
- the team has selected Open Source technologies across the board
- the team has developed a very efficient CI/CD pipeline and appropriate tools to manage and test this
- the team is deploying microservices to ease deployment and supportability/upgradeability
- the tools selected are widely available and have a very large pool of people from which they can call for help as required.
7. Understand security and privacy issues
Decision
The service met point 7 of the Standard.
What the team has done well
The panel was impressed that:
- the team has started to consider the security requirements of the system as a whole and the data within it
- the team has taken into account the GDPR requirements that may be applicable to the system
- the team realises and has accounted for PCI-DSS obligation for card payments.
What the team needs to explore
Before their next assessment, the team needs to:
- ensure that an ongoing brief is maintained for PCI-DSS obligations especially as they are self-certifying under SAQ.
8. Make all new source code open
Decision
The service met point 8 of the Standard.
What the team has done well
The panel was impressed that:
- the team has selected Open Source technologies for all aspects of the environment.
- the team is well versed in the nature of Open Source and use of appropriate public repositories i.e. GitHub.
- the team is continually improving their code to allow further publication and sharing on GitHub by removing “sensitive” from the codebase.
9. Use open standards and common platforms
Decision
The service met point 9 of the Standard.
What the team has done well
The panel was impressed that:
- the team is making use of common GDS technologies i.e. GovPay
- the team is developing microservices that can allow sharing of common components within Companies House.
10. Test the end-to-end service
Decision
The service met point 10 of the Standard.
What the team has done well
The panel was impressed that:
- the team is well versed in CI/CD techniques and has wrapped testing into this
- the team believes testing is a fundamental requirement and is a core requirement for everything they do.
11. Make a plan for being offline
Decision
The service met point 11 of the Standard.
What the team has done well
The panel was impressed that:
- the team is making use of highly resilient cloud technologies e.g. availability zones.
What the team needs to explore
Before their next assessment, the team needs to:
- the team should investigate and document how they will handle services on which they are reliant i.e. GovPay is offline.
12: Make sure users succeed the first time
Decision
The service met point 12 of the Standard.
What the team has done well
The panel was impressed that:
- the team has designed a very short, simple journey for paying a penalty – and has data from the private beta that means they’re confident that the majority of users can succeed the first time
- the appeals service similarly has good data to back up this point – 91% of users with valid penalty references have been able to complete the service
- the team has iterated the paper letter so that there is a smoother transition to the online journey
- the team has trained and created guides for their colleagues supporting the service, to ensure that it works well for users who can’t use the online service.
What the team needs to explore
Before their next assessment, the team needs to:
- demonstrate a clear plan for improving the journey of the 15% of users who don’t have a company authentication code
- further explore the ‘account-less’ option to pay fines, using only an email address to proceed
- do more user research with users with access needs in the future – particularly screen reader users as this has been hard to conduct remotely in recent months.
13. Make the user experience consistent with GOV.UK
Decision
The service met point 13 of the Standard.
What the team has done well
The panel was impressed that:
- the service uses the GOV.UK Design System and is consistent with its styles and patterns
- the service uses GOV.UK Pay to take payments
- the team discovered some accessibility issues on the payment pages that they have fed back to the GOV.UK Pay team.
14. Encourage everyone to use the digital service
Decision
The service met point 14 of the Standard.
What the team has done well
The panel was impressed that:
- the team demonstrated their commitment to encouraging users to use the online service for Pay a Late Filing Penalty. However, the panel were also impressed by their efforts to maintain existing payment methods to ensure those who couldn’t use the service online were still able to make payment
- the team were also able to show how they plan to increase usage of the Appeal a Late Filing Penalty service through amendments to the penalty notice.
15. Collect performance data
Decision
The service met point 15 of the Standard.
What the team has done well
The panel was impressed that:
- appropriate tools are used to collect analytics data with plans in place to upgrade their PIWIK instance to Matomo. The data is held in secure locations controlled by the organisation. Their SIRO has signed off on the use of PIWIK as the chosen analytics package
- the users IP address is anonymised
- the team Integrates the data from many different sources to provide richer, more valuable actionable insights. Insights gained from user feedback or user research are validated using analytics and fed back to the team
- annotations are being made to analytics tools to capture key stages.
16. Identify performance indicators
Decision
The service met point 16 of the Standard.
What the team has done well
The panel was impressed that:
- the team thought about the measures then need in place by running a Performance Framework workshop
- the team meets every two weeks to discuss the analytics findings for the previous two weeks. Any findings and actions are fed into the team backlog
- the team demonstrated where analytics findings fed into positive changes to service leading to a 36.5% reduction in completion time. The team showed where analytics could show where issues occurred and therefore allows the team to reproduce the issues and resolve them
- the team shares the findings widely by the show and tell
- regular analytics findings meetings
- a live dashboard
-
a very thorough monthly dashboard - they are looking to iterate on the dashboard
- the KPI’s are reviewed regularly at the analytics meetings
- the team reviewed their customer feedback to map the questions more closely to their set of personas.
17. Report performance data on the Performance Platform
Decision
The service met point 17 of the Standard.
What the team has done well
The panel was impressed that:
- not applicable due to the current status of the Performance Platform
- the team are collecting the mandatory KPI and displaying them on the dashboard.
18. Test with the minister
Decision
The service met point 18 of the Standard.
What the team has done well
- Companies House is an Executive Agency of BEIS. The service team confirmed that the Chief Executive and Board of Companies House have been involved in the development of this service and that the service has been tested with senior stakeholders including their sponsor, the Director of Finance.