Information on Consumer Network and roundtable events - November 2021

• AdviceUK
• AgeUK
• Alzheimers' Society
• Christians Against Poverty
• Citizens Advice England
• Citizens Advice Scotland
• Citizens Advice Wales
• Consumer Council Northern Ireland
• Financial Services Consumer Panel
• England Illegal Money Lending Team
• Macmillan Cancer Support
• Money Advice Scotland
• MIND
• Money Advice Trust
• MoneySavingExpert.com
• Money & mental Health Policy Institute
• Scope
• Scottish Illegal Money Lending Unit (SIMLU)
• Shelter
• StepChange
• The Money Charity
• NASMA
• Toynbee Hall
• Wales Illegal Money Lending Unit (WIMLU)
• Which?
• Money & Pensions Service
• Fair By Design
• Money Advice Liaison Group
• DebtCamel
• The Institute of Money Advisers (IMA)
•  The Standard Life Foundation
• Clean Slate (QuidsIn! Magazine)

The Consumer Network (the Network) was established at the creation of the FCA to establish and maintain productive and trusting relationships with consumer organisations and create improved information flows of intelligence between consumer organisations and the FCA.

It has three core objectives:

1. To engage consumer organisations in FCA policy-making, providing a forum for constructive and collaborative working through regular engagement.
2. To gather insights on consumer harm and consumer issues from consumer-facing organisations
3. To provide a means of conveying FCA messages to consumers through these consumer-facing organisations, including hard-to-reach consumers that would otherwise not receive it from the FCA directly.

We do not advertise for applications to join the Network. We have no set membership criteria, but internally we apply a range of general principles in selecting Network members. As explained further below, we look for gaps in the key consumer-related sectors and issues we regulate. In addition, members must be organisations that:

• provide support and materials for consumers of the markets that we regulate, and/or
• provide advice on financial matters (e.g. debt advice), and/or
• have consumer advice helplines on financial matters (not necessarily exclusively), and/or
• have consumer research functions that cover financial matters relevant to the sectors the FCA regulates.

In practice, many members of the Network do all or most of these. The membership, as listed above, consists of the main consumer and debt advice organisations from around the UK, including those with statutory duties, plus a number of more specialised organisations that represent specific categories of consumers in vulnerable circumstances, in particular. Most members have charitable status.

For all organisations, we consider whether they are best placed to become a member of the Network or whether other, equally valuable, channels of engagement are appropriate. For example, where there are organisations that perform some of the above functions but have a wider portfolio of work that includes strong elements of journalism or public and parliamentary lobbying, we take a view in each case on whether membership of the Consumer Network is the most appropriate way for the FCA to engage with them. It might be that other FCA channels, such as the Public Affairs team, the Press Office or senior-level engagement, are more appropriate. We base this judgment on factors such as the balance within the organisation of their consumer-facing and insight-gathering role, and whether they have alternative routes into the FCA, drawing on the criteria above.

Together, the Network membership needs to provide us with cross-UK coverage, including in the Devolved Administrations, and cover the key consumer-related sectors and issues we regulate.

We recently conducted a review of the membership for the network to ensure that it included and reached a sufficiently wide range of consumer cohorts. When adding organisations to the Network we need to balance the input they provide with the resource we have available to dedicate to relationship management with each of the members.

We have withheld the names of current or former FCA staff below the level of Manager or Technical Specialist as well as the names, positions and email addresses of representatives of other organisations. This is because it is the FCA’s policy not to disclose these names as disclosure would breach the requirements of the UK General Data Protection Regulations (GDPR). Therefore, the information is exempt from disclosure under section 40 (personal information) of FOIA.

What we are able disclose to you

General right of access to information held by public authorities

Under section 1(1)(a) of FOIA, any person making a request for information to a public authority is entitled to be informed in writing by the public authority whether it holds information of the description specified in the request. If the public authority holds information of the type specified in the request, the person requesting the information is entitled under section 1(1)(b) to have the information communicated to them. The rights in section 1(1)(a) and (b) are subject to a number of exclusions and exemptions.

Section 40 (Personal Information)

To the extent that the information that we hold contains personal data about individuals, section 40(2)(b) of FOIA provides that '[a]ny information to which a request for information relates is also exempt information if the first, second or third condition listed below is satisfied.'

We have applied this exemption because the first condition (as stated in section 40(3A) of FOIA) is satisfied. Some of the information comprises the personal data of individuals other than yourself which, if disclosed, would contravene any of the data protection principles.

In particular, it would be a breach of the first data protection Principle as set out in Article 5 of the UK GDPR, to disclose such information, as it would not be lawful or fair to do so. As set out above, it is the FCA’s policy not to disclose the names of staff below the level of Manager and Technical Specialist, as well as the names, positions and email addresses of representatives of other organisations.

In addition, the individuals concerned have not given their consent for their personal details to be made public and the release of such information may be detrimental to the individuals themselves.

This is an ‘absolute’ exemption, and so it is not necessary to balance the public interest for and against disclosing the information.