Closed call for evidence

Service charge transparency requirements: ongoing costs of the new building safety regime - consultation and call for evidence

Published 2 February 2023

Applies to England

Scope of the consultation

Topic of this consultation:

The Building Safety Act 2022 established new legal duties for landlords and building owners of higher-risk residential buildings to keep their building safe.

There will be an ongoing cost associated with complying with some of these building safety duties, which can be passed to leaseholders through the service charge.

The consultation and call for evidence seek views on:

  • the proposed transparency requirements associated with the ongoing costs of the new building safety regime
  • the administrative and operational changes needed to implement the new transparency requirements
  • the cost of and time taken to adjust existing systems or to implement new systems to meet the transparency requirements
  • the impact of different commencement timings and sequencing

Scope of this consultation:

Building safety service charges.

Geographical scope:

These proposals relate to England only.

Impact assessment:

We are carrying out a call for evidence to gather information on the impact of implementing these proposals. As such, there is no impact assessment for these proposals at this stage.

Basic information

Body or bodies responsible for the consultation:

Department of Levelling Up, Housing, and Communities (DLUHC).

Duration:

This consultation and call for evidence will last for 8 weeks from 2 February to 31 March 2023.

Enquiries:

For any enquiries about the consultation please contact: HigherRiskBuildings.CostTransparency@levellingup.gov.uk.

How to respond:

You may respond by completing the online survey

or

You can email your response to the questions in this consultation and call for evidence to: HigherRiskBuildings.CostTransparency@levellingup.gov.uk

or

You can send written responses to:

Consultation on Higher Risk Buildings – Cost Transparency
c/o Reform, Legislation and Regulators Division
Department for Levelling Up, Housing and Communities
Floor 3 NE, Fry Building
2 Marsham Street
London
SW1P 4DF

If you are responding in writing (via email or post), please make it clear which questions you are responding to.

When you reply, it would be very useful if you confirm whether you are replying as an individual or submitting an official response on behalf of an organisation and include:

  • your name
  • your position (if applicable)
  • the name of organisation (if applicable)
  • an address (including postcode)
  • an email address
  • a contact telephone number

Consultation overview

1. The Building Safety Act 2022 establishes new legal duties for landlords and building owners, or those under a repairing obligation for any of the common parts in the building, of higher-risk residential buildings to keep their building safe.

2. There will be an ongoing cost associated with complying with some of these building safety duties, which can be passed to leaseholders through the service charge. This does not include remediation costs, which are subject to different requirements (for example, the leaseholder protections in the Building Safety Act 2022).

3. The government has committed to ensure that this element of the service charge is transparent to leaseholders, to give leaseholders information about what they are paying for to keep the building safe and assurance that the manager of the building is charging reasonably.

4. This consultation asks for views on policy proposals to ensure this transparency. These proposals apply to landlords, meaning any person who has a right to enforce payment of a service charge.

Introduction

5. The Building Safety Act 2022 includes a package of measures to make buildings safer, make improvements across the entire built environment, and strengthen oversight and protections for residents of higher-risk buildings.

6. One of the changes made by the Building Safety Act 2022 is the creation of new legal duties for Accountable Person to keep their building safe. Accountable persons are landlords and building owners of higher-risk residential buildings of at least 18 metres or 7 storeys, or those under a repairing obligation for any of the common parts in the building. There will be an ongoing cost associated with complying with some of these building safety duties. This does not include remediation costs, which are subject to different requirements (for example, the leaseholder protections).

7. The Building Safety Act 2022 amends the Landlord and Tenant Act 1985 to make sure that the ongoing costs of the new regime can be charged back to leaseholders as part of the ongoing cost of living in a safe building. Leaseholders with leases of 7 years or more in a higher-risk multi-occupied building (of at least 18 metres or 7 storeys in height) covered by the Building Safety Act 2022 will be liable to pay these costs through the service charge. Many leases already allow for similar costs to be charged as part of the service charge – these measures will ensure both consistency and transparency.

8. The principle underpinning this cost mirrors long-standing principles when it comes to service charges; that is, it spreads the cost of looking after any communal or shared areas of a building between those who use and benefit from those areas.

9. Originally, the government planned to require that these costs be recovered through a separate charging mechanism modelled on the service charge that leaseholders pay, known as the ‘building safety charge’. In response to feedback that this could have created additional and unnecessary bureaucracy for landlords and leaseholders, the government amended the legislation in Parliament to simplify how the costs are managed as part of the service charge. Streamlining this system will lessen the administrative burden, reducing operating costs and ultimately reducing the financial burden on leaseholders.

Building safety measures

10. The Building Safety Act 2022 amends the Landlord and Tenant Act 1985. This change ensures that landlords can pass on the costs they incur for any of the following building safety measures required by the Building Safety Act 2022:

  • applying for registration of a higher-risk building
  • applying for a building assessment certificate
  • displaying a building assessment certificate
  • assessing building safety risks
  • taking reasonable steps to manage building safety risks
  • preparing and revising a safety case report
  • notifying the regulator of a safety case report, and giving a copy of a safety case report to the regulator
  • establishing and operating a mandatory occurrence reporting system, and giving information to the regulator
  • creating and updating the golden thread of information and documents
  • giving particular information and documents (as per sections 89, 90 and 92 of the Building Safety Act 2022)
  • preparing, reviewing, and sharing the residents’ engagement strategy
  • establishing and operating a system for the investigation of complaints
  • giving a contravention notice to a resident, and making an application to the county court
  • making a request to enter premises, or making an application to the county court for an order requiring that the accountable person be allowed access to premises

11. The costs of these measures are the ongoing costs of the new building safety regime. This does not include remediation costs, which are subject to different requirements (for example, the leaseholder protections).

12. Where legal and other professional fees, fees payable to the regulator, or management costs are incurred as part of taking one of the above building safety measures, they are counted as being part of the cost of that building safety measure. This means that, unlike legal fees associated with liability for remediation costs, legal fees can be passed on through this part of the service charge where they are incurred as part of meeting the new requirements set out above.

13. The government has committed to ensuring that this element of the service charge is transparent to leaseholders. This is so that leaseholders will have better information about what they are paying to keep the building safe and assurance that the manager of the building is charging reasonably – and the ability to challenge costs at the First-tier Tribunal if not.

14. We are proposing to create a legal requirement that landlords must identify the element of the service charge spent on the ongoing costs of the new building safety regime in:

  • service charge demands
  • annual service charge statements

15. We are also proposing that leaseholders should be able to obtain an itemised breakdown of the total money per building of the annual service charge that is going towards paying for the building safety measures.

16. These proposals apply to landlords, meaning any person who has a right to enforce payment of a service charge. Where Resident Management Companies or Right to Manage Companies are the landlord within this meaning, they will be responsible for complying with any transparency requirements.

17. These costs would be apportioned, and demands made, in accordance with the terms of individual leases.

18. We intend to allow landlords to pass on the ongoing costs of the new building safety regime to leaseholders once the regime is up and running. This is to allow accountable persons to gather funds to comply with the duties listed in paragraph 10 (above) once compliance becomes a statutory requirement.

19. We recognise that the changes proposed might incur an initial and ongoing costs as the Accountable Person and other landlords adjust existing systems or put new arrangements in place. We would like to understand the scale of these costs to help our decision-making.

Part 1: Transparency proposals

Service charge demands

20. We are proposing to create a legal requirement that landlords must identify the element of the service charge spent on the ongoing costs of the new building safety regime in service charge demands. These demands will be issued in accordance with existing lease mechanisms.

21. This means that there would be a separate line in the service charge demand stating how much money of the service charge is going toward paying for the building safety measures.

Question 1: Do you agree or disagree with the proposal that landlords must identify the element of the service charge spent on the ongoing costs of the new building safety regime in service charge demands?

Please select one of the options below.

  • Agree
  • Disagree
  • Neither agree nor disagree
  • Not sure

Question 1a: Please provide an explanation for your answer question 1.

If you answered ‘Disagree’ or ‘Neither agree nor disagree’, please explain what changes should be made. 

Annual service charge statements

22. Many leases require that landlords provide a summary of service charge accounts within a specific time-period of the end of the relevant accounting period. This typically happens annually.

23. We are proposing to create a legal requirement that landlords must identify the cumulative element of the service charge spent on the ongoing costs of the new building safety regime in these accounts or statements, when they are presented to leaseholders. This will help them better understand the total cost of the new regime.

24. This means that there would be a separate line in the annual service charge statement, stating how much money of the annual service charge is going toward paying for the building safety measures.

25. We are also proposing that leaseholders should be able to obtain an itemised breakdown of the total money per building of the annual service charge that is going toward paying for the building safety measures. For example, the annual service charge statement received by each leaseholder would outline the total amount of their annual service charge that was used to fund building safety measures. The total spend per building would then be broken down into the specific measures and activities that were paid for. However, this would not be broken down further to set out each leaseholder’s individual contribution to each measure.

Question 2: Do you agree or disagree with the proposal that, as part of the annual service charge statement, landlords must do both of the following:

  • identify the element of the service charge spent on the ongoing costs of the new building safety regime
  • provide a per-building itemised breakdown of the specific measures that were paid for

Please select one of the options below.

  • Agree
  • Disagree
  • Neither agree nor disagree
  • Not sure

Question 2a: Please provide an explanation for your answer to question 2.

If you answered ‘Disagree’ or ‘Neither agree nor disagree’, please explain whether you consider there is a better alternative, and what this would look like.


Question 3: Do you have any other comments on the proposed requirements to make the ongoing costs of the new building safety regime transparent?

Please provide your views.

Part 2: Implementation requirements

26. We recognise that administrative and operational changes (for example, changes to IT systems) might be required to implement these proposals, and that these changes may incur initial and ongoing costs. We would like to understand more about these impacts.

Service charge demands

27. Questions 4-5a are related to the administrative and operational changes that might be required to issue service charge demands with the ongoing costs of the new building safety regime made separately identifiable.

Question 4: If you will be responsible for charging these new costs, what administrative and operational changes are required to ensure that you can issue service charge demands with the ongoing costs of the new building safety regime made separately identifiable?

Please select one of the options below.

  • I am not responsible for charging these new costs
  • Administrative or operational changes will not be required
  • Administrative or operational changes will be required
  • Other

Question 4a: If you answered ‘Administrative or operational changes will be required’ or ‘Other’ please explain your answer or specify what administrative or operational changes will be required.


Question 4b: If you will be responsible for charging these new costs, and you think that administrative or operational changes will be required, please provide an estimate of the costs of making the administrative or operational changes.

Please provide your views.


Question 5: Do you agree or disagree that any administrative and operational changes would be easy to implement with regards to service charge demands?

Please select one of the options below.

  • Agree
  • Disagree
  • Neither agree nor disagree
  • Not sure

Question 5a: Please provide an explanation for your answer to question 5.

If you answered ‘Disagree’ or ‘Neither agree nor disagree’, please explain why.

Annual service charge statements

28. Questions 6-8a are related to the administrative and operational changes that might be required to issue annual service charge statements with the ongoing costs of the new building safety regime made separately identifiable, and to provide a per-building itemised breakdown of the specific measures that were paid for.

29. We are proposing to create a legal requirement that landlords must identify the cumulative element of the service charge spent on the ongoing costs of the new building safety regime in these accounts or statements, when they are presented to leaseholders. This will help them better understand the total cost of the new regime.  This means that there would be a separate line in the annual service charge statement, stating how much money of the annual service charge is going toward paying for the building safety measures.

30. We are also proposing that leaseholders should be able to obtain an itemised breakdown of the total money per building of the annual service charge that is going toward paying for the building safety measures. For example, the annual service charge statement received by each leaseholder would outline the total amount of their annual service charge that was used to fund building safety measures. The total spend per building would then be broken down into the specific measures and activities that were paid for. However, this would not be broken down further to set out each leaseholder’s individual contribution to each measure.

Question 6: If you will be responsible for charging these new costs, what administrative and operational changes are required to ensure that you can issue annual service charge statements with the ongoing costs of the new building safety regime made separately identifiable?

Please select one of the options below.

  • I am not responsible for charging these new costs
  • Administrative or operational changes will not be required
  • Administrative or operational changes will be required
  • Other

Question 6a: If you answered ‘Administrative or operational changes will be required’ or ‘Other’ please explain your answer or specify what administrative or operational changes will be required.


Question 6b: If you will be responsible for charging these new costs, please provide an estimate of the costs of making the administrative or operational changes.

Please provide your views.


Question 7: If you will be responsible for charging these new costs, what administrative and operational changes are required to provide leaseholders with an itemised breakdown of the total money per building of the annual service charge that is going toward paying for building safety measures?

Please select one of the options below.

  • I am not responsible for charging these new costs
  • Administrative or operational changes will not be required
  • Administrative or operational changes will be required
  • Other

Question 7a: If you answered ‘Administrative or operational changes will be required’ or ‘Other’ for question 7, please explain your answer or specify what administrative or operational changes will be required.

Please provide your views.


Question 7b: If you will be responsible for charging these new costs, please provide an estimate of the costs of making the administrative or operational changes needed to provide leaseholders with an itemised breakdown of the total money per building of the annual service charge that is going toward paying for building safety measures?

Please provide your views.


Question 8: Do you agree or disagree that any administrative and operational changes would be easy to implement with regards to annual service charge statements?

Please select one of the options below.

  • Agree
  • Disagree
  • Neither agree nor disagree
  • Not sure

Question 8a: Please provide an explanation for your answer to question 8.

If you answered ‘Disagree’ or ‘Neither agree nor disagree’, please explain why.

Timings

31. As noted in paragraph 6, we intend to allow landlords to pass on the ongoing costs of the new building safety regime to leaseholders once the regime is up and running. This is to allow the accountable persons to gather funds to comply with the duties listed at paragraph 10 of this document once compliance becomes a statutory requirement.

32. The charging mechanism and transparency requirements can be commenced separately, meaning that the costs of the new regime could be charged back to leaseholders without requirements for landlords to proactively provide information about the total expense. Our intention is to ensure that these costs are made transparent as quickly as possible after the charging mechanism is commenced.

33. Respondents should note that existing rights under the Landlord and Tenant Act 1985 give leaseholders rights to ask for a summary of service charge costs and request further information about those costs. Once the ongoing costs of the new regime are being charged back to leaseholders, the summary of costs and supporting documents will need to include details of those costs (though they may not be separately identified).

Question 9: What would the impact on you be if there were a delay between commencing the charging mechanism provisions and the transparency requirements?

Please select one of the options below.

  • Strongly positive impact
  • Somewhat positive impact
  • No impact
  • Somewhat negative impact
  • Strongly negative impact
  • Not sure

Question 9a: Please provide an explanation for your answer to question 9.

Please provide your views.

34. Alongside these changes, the government is also exploring broader proposals to better protect and empower leaseholders by giving them more information on what their service charge costs include, in light of recommendations from the Housing, Communities and Local Government Committee (as it then was) and Lord Best’s Working Group report on the Regulation of Property Agents.

35. We recognise that the proposed changes to create transparency requirements for the ongoing costs of the new building safety regime and to provide details about service charge costs more generally would create further additional costs if these changes were implemented separately. This is on the grounds that the accountable persons and other landlords will likely have to adjust their systems twice, the cost of which may ultimately be passed on to leaseholders. We recognise that a single wholesale changeover to a slower timeline could be more cost effective, but there is a trade-off between transparency and cost.

36. We would like to understand your views on how best to implement any changes. We have 2 proposed approaches:

  • Option 1: The transparency requirements for the ongoing costs of the new building safety regime come into effect as quickly as possible after the regime is up and running, meaning that a staggered implementation may be required if the government pursues the wider service charge reforms.
  • Option 2: The transparency requirements for the ongoing costs of the new building safety regime are delivered to a slower timeline as part of any wholesale reform to drive up transparency of service charge costs, offering potential efficiencies in implementation.

Question 10: Would you prefer option 1 or option 2? (Outlined in paragraph 36, above).

Please select one of the options below.

  • Option 1
  • Option 2
  • Neither
  • No preference

Question 10a: Please provide an explanation for your answer to question 10.

Please provide your views.

Part 3: Equalities

37. We are also seeking views on the potential impacts our proposals may have on groups of people with protected characteristics. Protected characteristics are age, disability, gender reassignment, marriage and civil partnership, pregnancy and maternity, race, religion or belief, sex, and sexual orientation.

Question 11: What do you consider to be the equalities impact on individuals with protected characteristics of any of the proposed requirements?

Please give reasons and any evidence that you consider relevant.  Please see Annex B: Personal data (below) for more information on the use of sensitive types of data, and please take this into account when formulating your response. Please do not share special category personal data or criminal offence data if we have not asked for this unless absolutely necessary for the purposes of your consultation response.

Part 4: Other comments

Question 12: Do you have any other comments on what would be required to successfully implement these proposals?

Please provide your views.

Part 5: Demographics

38. See Annex B: Personal data (below) for more information on how your data will be used.

Question 13: What is your name?

Please write your first name and last name. If you would prefer not to say, please specify this.


Question 14: What is your email address?

Please write your email address. If you do not have an email address, please write ‘N/A’. If you would prefer not to say, please specify this.


Question 15: Are the views that you have expressed on this consultation your own personal views or an official response from an organisation you represent?

Please select the option which applies to you.

  • Personal
  • Organisation
  • Prefer not to say

39. If the views that you have expressed in this consultation are your personal views, please answer questions 16-18a. If the views that you have expressed in this consultation are an official response from an organisation you represent, please answer questions 19-20.

Demographic questions for individuals

40. Please complete this section if the views that you have expressed on this consultation are your personal views.

41. See Annex B: Personal data (below) for more information on how your data will be used.

Question 16: Which of the below statements apply to you?

Please select all the below statements which apply.

  • I am a leaseholder
  • I am a freeholder
  • I live in a leaseholder-owned block
  • I live in a leaseholder-managed block
  • I am a commonhold unit holder
  • Not sure
  • Other (please specify)
  • Prefer not to say

Question 17: Is your building over 7 storeys or 18 metres in height?

Please select one of the answers below.

  • Yes
  • No
  • Not sure

Question 18: Do you know who manages your building?

Please select one of the answers below.

  • Yes
  • No

Question 18a: If you answered ‘Yes’ to question 18, who manages your building?

Please select one of the answers below.

  • Commonhold Association with no Managing Agent
  • Commonhold Association with an appointed Managing Agent
  • Freeholder or Landlord with no Managing Agent
  • Freeholder or Landlord with an appointed Managing Agent
  • Residents’ Management Company with an appointed Managing Agent
  • Resident owned freehold with no Managing Agent
  • Resident own freehold with an appointed Managing Agent
  • Right to Manage Company with no Managing Agent
  • Right to Manage Company with an appointed Managing Agent
  • Not sure or unknown
  • Other (please specify)

Demographic questions for organisations

42. Please complete this section if the views that you have expressed in this consultation are an official response from an organisation you represent.

43. See Annex B: Personal data (below) for more information on how your data will be used.

Question 19: What is the name of your organisation?

Please write the name of your organisation. If you would prefer not to say, please specify this.


Question 20: Which category best describes the activities of your organisation?

Please select one of the answers below.

  • Charity
  • Commonhold association
  • Developer
  • Government body
  • Housing association
  • Insurance services
  • Investor
  • Legal services
  • Local authority
  • Managing agent
  • Professional body
  • Representation group
  • Residents’ Management Company
  • Residents’ association or tenants’ association
  • Retirement sector developer
  • Right to Manage Company
  • Software developer
  • Survey or valuation Services
  • Trade association
  • Prefer not to say
  • Other (please specify)

Next steps

44. Thank you to all participants for taking the time to respond to our consultation.

45. The consultation will close on 31 March 2023. We will be considering these comments when determining how best to take forward the proposed policy.

Annex A: About this consultation

This consultation document and consultation process have been planned to adhere to the Consultation Principles issued by the Cabinet Office.

Representative groups are asked to give a summary of the people and organisations they represent, and where relevant who else they have consulted in reaching their conclusions when they respond.

Information provided in response to this consultation may be published or disclosed in accordance with the access to information regimes (these are primarily the Freedom of Information Act 2000 (FOIA), the Environmental Information Regulations 2004 and UK data protection legislation). In certain circumstances this may therefore include personal data when required by law.

If you want the information that you provide to be treated as confidential, please be aware that, as a public authority, the Department is bound by the information access regimes and may therefore be obliged to disclose all or some of the information you provide. In view of this it would be helpful if you could explain to us why you regard the information you have provided as confidential. If we receive a request for disclosure of the information we will take full account of your explanation, but we cannot give an assurance that confidentiality can be maintained in all circumstances. An automatic confidentiality disclaimer generated by your IT system will not, of itself, be regarded as binding on the Department.

The Department for Levelling Up, Housing and Communities will at all times process your personal data in accordance with UK data protection legislation and in the majority of circumstances this will mean that your personal data will not be disclosed to third parties. A full privacy notice is included below.

Individual responses will not be acknowledged unless specifically requested.

Your opinions are valuable to us. Thank you for taking the time to read this document and respond.

Are you satisfied that this consultation has followed the Consultation Principles? If not or you have any other observations about how we can improve the process please contact us via the complaints procedure.

Annex B: Personal data

The following is to explain your rights and give you the information you are entitled to under UK data protection legislation.

Note that this section only refers to personal data (your name, contact details and any other information that relates to you or another identified or identifiable individual personally) not the content otherwise of your response to the consultation.

1. The identity of the data controller and contact details of our Data Protection Officer

The Department for Levelling Up, Housing and Communities (DLUHC) is the data controller. The Data Protection Officer can be contacted at dataprotection@levellingup.gov.uk or by writing to the following address:

Data Protection Officer
Department for Levelling Up, Housing and Communities
Fry Building
2 Marsham Street
London
SW1P 4DF

2. Why we are collecting your personal data

Your personal data is being collected as an essential part of the consultation process, so that we can contact you regarding your response and for statistical purposes. We may also use it to contact you about related matters.

We will collect your IP address if you complete a consultation online. We may use this to ensure that each person only completes a survey once. We will not use this data for any other purpose.

Sensitive types of personal data

Please do not share special category personal data or criminal offence data if we have not asked for this unless absolutely necessary for the purposes of your consultation response. By ‘special category personal data’, we mean information about a living individual’s:

  • race
  • ethnic origin
  • political opinions
  • religious or philosophical beliefs
  • trade union membership
  • genetics
  • biometrics
  • health (including disability-related information)
  • sex life
  • sexual orientation

By ‘criminal offence data’, we mean information relating to a living individual’s criminal convictions or offences or related security measures.

Please consider this when drafting your responses, in particular where there is a free text box or an opportunity to write out your response.

The collection of your personal data is lawful under article 6(1)(e) of the UK General Data Protection Regulation as it is necessary for the performance by DLUHC of a task in the public interest or in the exercise of official authority vested in the data controller. Section 8(d) of the Data Protection Act 2018 states that this will include processing of personal data that is necessary for the exercise of a function of the Crown, a Minister of the Crown or a government department (in this case a consultation).

Where necessary for the purposes of this consultation, our lawful basis for the processing of any special category personal data or ‘criminal offence’ data (terms explained under ‘Sensitive Types of Data’) which you submit in response to this consultation is as follows. The relevant lawful basis for the processing of special category personal data is Article 9(2)(g) UK GDPR (‘substantial public interest’), and Schedule 1 paragraph 6 of the Data Protection Act 2018 (‘statutory etc and government purposes’). The relevant lawful basis in relation to personal data relating to criminal convictions and offences data is likewise provided by Schedule 1 paragraph 6 of the Data Protection Act 2018.

4. With whom we will be sharing your personal data

DLUHC may appoint a ‘data processor’, acting on behalf of the Department and under our instruction, to help analyse the responses to this consultation. Where we do, we will ensure that the processing of your personal data remains in strict accordance with the requirements of the data protection legislation.

5. For how long we will keep your personal data, or criteria used to determine the retention period

Your personal data will be held for 2 years from the closure of the consultation, unless we identify that its continued retention is unnecessary before that point.

6. Your rights (for example, access, rectification, restriction, objection)

The data we are collecting is your personal data, and you have considerable say over what happens to it. You have the right:

  1. to see what data we have about you
  2. to ask us to stop using your data, but keep it on record
  3. to ask to have your data corrected if it is incorrect or incomplete
  4. to object to our use of your personal data in certain circumstances
  5. to lodge a complaint with the independent Information Commissioner (ICO) if you think we are not handling your data fairly or in accordance with the law. You can contact the ICO at https://ico.org.uk/, or telephone 0303 123 1113.

Please contact us at the following address if you wish to exercise the rights listed above, except the right to lodge a complaint with the ICO: dataprotection@levellingup.gov.uk, or:

Knowledge and Information Access Team
Department for Levelling Up, Housing and Communities
Fry Building
2 Marsham Street
London
SW1P 4DF

7. Your personal data will not be sent overseas

8. Your personal data will not be used for any automated decision making

9. Your personal data will be stored in a secure government IT system

We use a third-party system, Citizen Space, to collect consultation responses. In the first instance your personal data will be stored on their secure UK-based server. Your personal data will be transferred to our secure government IT system as soon as possible, and it will be stored there for 2 years before it is deleted.