Transparency data

6 September 2022: Cerberus Project accounting officer assessment

Updated 2 April 2024

Background and context

It is normal practice for Accounting Officers to scrutinise significant policy proposals or plans to start or vary major programmes, and then assess whether they measure up to the standards set out in Managing Public Money. From April 2017, the government has committed to make a summary of the key points from these assessments available to Parliament when an Accounting Officer has agreed an assessment of projects within the Government’s Major Projects Portfolio.

The Cerberus Project

Border Force works to secure the border, ensure regulatory compliance, manage threats, and maintain high service standards. Home Office Intelligence uses border data to identify and act upon high threat border movements. There is a critical gap in the current approach to the use of data at the border, with siloed systems preventing the effective utilisation of available data.

The Cerberus project will address this gap by delivering the Cerberus system, an advanced, highly capable analytics and targeting system. Enabling analysis of a wider range of datasets within a single system, intelligence officers and operational teams will be able to analyse passenger and freight data across different transport modes, with more targeted interventions based on a richer assessment of threat and risk. This will increase threat detections and seizures while reducing nugatory interventions and increasing the flowrate of legitimate traffic. By connecting intelligence and data across modes Cerberus will enable insights into the activity of organised crime groups (OCGs), preventing intelligence failure and reducing the economic and social harm those OCGs cause. In replacing siloed legacy systems, Cerberus will also deliver considerable cashable savings.

The Cerberus Outline Business Case was approved for FY20/21 with subsequent Full Business Cases approved for FY21/22 and FY22/23. This AO advice is being published following the Finance and Investment Committee approval of the 22/23 business case. It reflects the current position on the project and will be updated if there are significant changes to the project ahead of its closure. The project will continue through into FY24/25. Cerberus is in operational use today, targeting a subset of border movements, delivering both operational benefit and cashable savings. The operational use of the system will be expanded to new transport modes and users throughout the remainder of the project’s delivery, with additional functionality being developed and datasets added to further improve the efficiency and effectiveness of the system.

Assessment against the Accounting Officer Standards

Regularity

The use of data within the system is based on a variety of established legislation and precedents governing the use of border movement data. Cerberus will not use any data that the Home Office does not have authorised access to. Additionally, Cerberus is working to ensure compliance with both the letter and spirit of legislation and guidelines. As a result of these points, there is no new primary legislation required for Cerberus. The system and its use fall within the existing powers and remit of the Home Office.

Cerberus has a dedicated Data Governance Team who oversee the development and delivery of the system and advise the Senior Responsible Owner (SRO) on the compliant development of the system. The project regularly consults with Home Office Legal Advisors and reports to the Home Office Data Ethics Board.

The Data Governance team work with the Home Office Data Protection Officer and Information Commissioner’s Office (ICO) to help the project to ensure data protection compliance within the build and delivery of the Cerberus capability. The Home Office Data Protection Office is conducting a scheduled audit of the project this year to check its compliance with relevant legislation and guidance and make recommendations for improvement where necessary.

The Home Office Intelligence Data Governance Team own the operational requirement for compliance and define the functional requirements for audit and data handling to ensure continued compliance in operational use.

Propriety

Cerberus continues to deliver within the limits of the authority delegated to the SRO. The project’s funding was allocated as part of the Spending Review (SR) process and the project is being delivered within the allocated funding agreed with HM Treasury.

As a Government Major Projects Portfolio (GMPP) project, Cerberus is subject to high standards of internal and external governance and assurance. The project’s business case is submitted annually to the Executive Committee’s Finance and Investment Committee, who act on behalf of the Accounting Officer to maintain Accounting Officer Standards in the delivery of the Home Office project portfolio. Business cases are submitted to and approved by HM Treasury in consultation with the Cabinet Office. The project reports in to the GMPP with quarterly submissions. The project is subject to regular assurance by the Infrastructure and Projects Authority.

The administration of the Cerberus service will include oversight on the appropriate use of data with ongoing monitoring and audit to detect and prevent improper system use. In particular, the use of passenger data will be closely managed, with functional controls to prevent improper access and use of this data, supported by the monitoring and audit regime. The project is working to ensure that the use of the data is appropriately even handed and not prejudice to any protected groups, as is the collection of that data.

The Cerberus system will address unacceptable border security vulnerabilities. There are limited risks associated with the use of the system for border security and these are far outweighed by the reduction in security risk that the system will enable. Actions arising from the analysis of data by the Cerberus system will be appropriately targeted towards unlawful activities and, again, shall otherwise be appropriately even handed. Since the system enables increased targeting towards unlawful activities, burden should be reduced on lawful business as a reduced proportion of searches should be conducted on the lawful passage of goods and people through the border.

The targeted activity enabled by the system supports a number of government polices, and the system is not known to frustrate any government policy.

In summary, the project’s scope and execution as well as the operational service are consistent with the Civil Service and Ministerial Code.

Value for money

In the last spending review, Cerberus increased in cost and duration to bring more advanced and innovative analytics capability into scope. While the benefit of this additional scope is difficult to forecast, Cerberus remains robustly good value for the exchequer and UK public.

The Cerberus businesses cases proposed a recommended option which provided the best Net Present Value of the considered options over the appraisal period. This analysis is assured by the Home Office’s Central Economics Unit overseen by the Chief Economist.

Over the appraisal period, the project has a gross undiscounted cost of £181.2m (including running costs of incumbent systems) which is a net undiscounted cost of £6.4m against the do minimum option. The project will deliver £72.5m of net undiscounted benefits against the do minimum option. Accordingly, with discounting the Net Present Value (NPV) of the option taken forward is £48.7m, with supporting sensitivity analysis showing that the option taken forward is robustly preferrable to the “do minimum” option.

The Whole Life Cost of the option taken forward (inclusive of sunk costs, inflation, optimism bias and irrecoverable VAT) is £198.2m, of which £149.2m is future expenditure. This option will realise gross cashable savings (including inflation) of £106.3m, efficiency benefits (excluding inflation) of £8.6m and monetised, non-cashable security benefits (excluding inflation) of £65.4m. The project is in the process of forecasting additional monetised benefits which will add to this total. There are further substantial non-monetisable security benefits where forecast increased interdictions of illicit commodities do not have a HM Treasury recognised monetary value.

In replacing a number of incumbent, siloed, legacy systems, Cerberus will deliver a significant net saving on technology costs to the Home Office. The project has delivered the first of these savings already.

In addition to delivering technology savings, Cerberus is delivering increased interdictions of illicit goods moving across the border, as well as the identification of the illicit movement of people across the border. Cash seizures and revenue payable goods seizures contribute directly to the Exchequer via HMRC. Other illicit goods, such as class A drugs and firearms, do not have a monetised value but contribute to the reduction in organised criminal activity across the border and a reduction in the associated harms to the UK public. For example, by the end of the appraisal period, the project is forecasting that Cerberus will enable interdiction of an additional 1.6 tonnes of class A drugs per annum at the border. The identification of illicit movement of people, particularly where these movements are identified before they reach the UK border, reduces the cost to the UK of illegal migration and the direct cost to the Home Office and wider Law Enforcement of addressing illegal migration in the UK.

Cerberus is also improving the efficiency of Border Force operations by reducing nugatory interventions at the border and by reducing the resource cost of identifying high threat, high harm border movements.

Feasibility

Cerberus has an established delivery methodology and track record of delivery, with the production system in operational use.

The project’s delivery is overseen by the Home Office’s Project and Portfolio Delivery Directorate. It has robust change control procedures with active risk and issue management and defined escalation routes to the SRO and senior boards.

Both project resourcing and the establishment of formal agreements for authorisation of access to third-party data continue to challenge the project’s schedule. These risks are under active management at a senior level and pose a manageable level of risk to the project’s success.

The project has an improving record of delivery to schedule and has made a number of changes to project management practices over the last year. The project is acting on recent recommendations from the IPA to make further improvements to project management mechanisms.

The Cerberus project continues to forecast delivery within its agreed schedule, cost and quality constraints.

Conclusion

As the Accounting Officer for the Cerberus project, I have prepared this summary to set out the key points that informed my decision in August 2022.

I have considered this assessment against the four accounting officer standards of regularity, propriety, value for money and feasibility.

I am satisfied the programme:

• uses established legal powers and is investing in building a compliant system
• meets the standards of Managing Public Money and accords with the generally understood principles of public life
• represents good value for money for the Exchequer as a whole
• is feasible to deliver

I am therefore satisfied that the programme is a good use of public resources.

If any of these factors change materially during the lifetime of this project, I undertake to prepare a revised summary, setting out my assessment of them. This summary will be published on the government’s website (GOV.UK). Copies will be deposited in the Library of the House of Commons and sent to the Comptroller and Auditor General, Treasury Officer of Accounts and Chair of the Public Accounts Committee.

Patricia Hayes CB

Second Permanent Secretary for the Home Office

6 September 2022