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DCRS Form Changes
Introduction
The Director Conduct Reporting Service was introduced in April 2016. At that time, we intended to develop the form with iterative changes. Unfortunately, the original development team left the Service soon after DCRS went live and we were unable to secure IT resource until earlier this year and we have now been able to complete work on developing the form.
On Wednesday 18th November at 7.00am, we plan to take down the DCRS system in order to conduct some essential maintenance work. This maintenance work will include the implementation of a version control system so that Insolvency Practitioners can see all submitted cases in the version of the form at the time of the submission. At the same time, a new version of the form will be uploaded and we will also be making changes to our rules engine that performs the sift function to take account of the new questions and to refine the sift process. It is planned that the system will be available again from 7.00 am on Thursday 19th November. From 6.00pm on 2 November, a message will be placed on the IP dashboard regarding this maintenance work.
Prior to the Service taking down the DCRS system, Insolvency Practitioners will need to submit any cases that they currently have in progress. Unfortunately, all information completed on any case in progress but not submitted will not be saved and the whole form will need to be completed when the system is available again.
The revisions to the form have been designed on feedback received from Insolvency Practitioners and their staff from the online feedback form and verbally and also from our colleagues who are using the output from the form to make their decisions.
The form does have more questions to obtain additional information at the outset if it is available, but this should result in our colleagues having better details, and fewer but more appropriate cases will be sifted in so that we should not have to make as many requests for information to supplement the content of your conduct report.
Summary of main changes
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Contact details – request for details to access the online report to creditors
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Company Information – new questions on company’s trading details, connected failures, bank accounts and electronic company records.
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Director details – question asking if director is deceased and if this is a sole director. Questions about the director’s date of birth and contact details have been changed from optional to if known. These questions must be completed where this information is known.
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Company Insolvency – New questions for compensation order considerations and for live company names in S216 breach cases.
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Books and Records – Changes to questions to establish the extent to which records have been delivered, how the absence of records has hampered Insolvency Practitioners and what detriment caused. The logic on the parent question has also changed so a “No” answer opens the subsequent questions.
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Director Conduct (Page 1 of 6) – renamed Insolvent Trading and minor question changes
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Director Conduct (Page 2 of 6) – renamed Detrimental Transactions, change to parent question to link it more to transactions. Additional questions added regarding sums involved and when transactions occurred.
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Director Conduct (Page 3 of 6) – renamed Tax affairs, amendment to the main question and the addition of an option to show where the Crown is owed less than 40%.
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Director Conduct (Page 4 of 6) – renamed Asset Disposals
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Director Conduct (Page 5 of 6) – renamed Successor Trading, addition of question to establish if company ever made a profit and addition of an “uncertain” option to certain questions where Insolvency Practitioners had reported not knowing enough to say yes or no.
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Director Conduct (Page 6 of 6) – renamed Customer Treatment
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New section – Other Investigations. The “other investigations” question has been moved from Company Insolvency to a new section and asks for details of the investigating body and what they are investigating. Additional question for an Insolvency Practitioner to flag if they have identified potential criminality not investigated elsewhere.
Feedback
Your views are important to us and have helped drive the changes that have been made. Therefore, when new form is live, we would appreciate your continued feedback to help us understand the extent to which the form meets the need of its users. This can be done by clicking on the feedback option near the top of every page within DCRS.
Future Planned Changes
Work is also ongoing to provide an overview page for each case that shows each section of the form and a progress tracker. This overview page will allow direct navigation to each section and users can also link back to the overview page from each section. The overview page will also contain the submit button and a link to a single page overview of the completed form. These functions should hopefully save time for users, especially where they do not complete the form in one visit.
Further information will be issued about these changes closer to this system update.
FAQs
- Why are questions about the director’s date of birth and contact details no longer optional?
The form contains questions that ask for the director’s date of birth, email address and telephone numbers. This is important information that assists us in properly identifying and contacting the director at an early stage in order to progress our enquiries and if appropriate seek a disqualification undertaking. In most cases, it is expected that the director’s date of birth and contact details should be held by the office-holder and should be entered onto the form.
Some IP’s may have concerns about providing this information under GDPR. However, as part of the Insolvency Service’s range of functions, personal data is collected and processed under a number of different lawful bases under GDPR/DPA. This includes the ‘public task’ basis in GDPR Article 6(1)(e) which specifies that lawful processing requires that
“The processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller”.
Therefore, contact details and a date of birth should be provided where this is held by the IP. In instances where this is not provided, the Insolvency Service will contact the IP to find out what details they have been using to contact directors.
- Where should I address queries relating to RP14/14S and DCRS?
Queries relating to Redundancy Payment matters should be sent to IPHelpdesk@insolvency.gov.uk .
Queries relating to conduct report matters and access issues should be sent to DCAS@insolvency.gov.uk or by using the contact-us option at the bottom of every page in DCRS.
- IP staff frequently contact us to say that they cannot see cases on their dashboard.
This is often because the IP or Service Manager has not added them as a staff member to that particular case. Before submitting an error report to the Insolvency Service, please check with your Insolvency Practitioner or Service Manager that they have added you to the case.
Instructions on how to add staff can be found at https://assets.publishing.service.gov.uk/government/uploads/system/uploads/attachment_data/file/522981/Guidance_notes_for_Service_Manager_and_Staff_access_to_DCRS_.pdf
All IPs appointed to cases should see them on their dashboard. Any IP that cannot see a case they are appointed to on their dashboard should let us know using by emailing DCAS@insolvency.gov.uk or by using the contact-us option at the bottom of every page in DCRS.
- In some firms, for a variety of reasons, an individual may wish to be an Insolvency Practitioner and a Service Manager or may change from one to another. When trying to set up their new status, the user will often receive a password error message. This is because each email address is only allowed one type of access to DCRS.
If a user changes status from Insolvency Practitioner to Service manager, they can either use a different email address for the Service Manager access or request their email address is removed from the IP Directory. To request this, users will need to contact our Estate Accounts team on CustomerServices.EAS@insolvency.gov.uk adding IP Directory in the subject field.
For a Service Manager to change to an Insolvency Practitioner, they would need to be removed from DCRS as a Service Manager by the individuals who added them and ensure their IP details are recorded correctly on the IP Directory, the link to this can be found here: https://www.gov.uk/find-an-insolvency-practitioner, if their details are not recorded they will need to contact Estate Accounts on the above email address.
If someone needs to retain both sets of access, they will need to use a different email for each.
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