Oral evidence: Government Preparations for Brexit: Border and Security Operations, HC 1674
Oral evidence, 30 October 2018.
Witnesses
Rt Hon Caroline Nokes MP, Shona Dunn, Paul Lincoln and Jon Thompson.
Chair
I welcome everyone to this session of the Home Affairs Committee inquiry into preparations for no deal. Obviously, we and the Government all hope that there will be some kind of deal and that this is about contingency planning. Today, we will focus particularly on those contingency plans and the consequences in the event of no deal. May I ask our panel briefly to introduce themselves and set out their area of responsibility, starting with Immigration Minister Caroline Nokes?
Caroline Nokes
I am the Immigration Minister, so I am significantly involved in our preparations for the border post Brexit. I do not know whether it is easiest to say at the outset that we are working very hard towards securing a deal; we do not want a no-deal situation. That might just get that out of the way, so that I do not have to preface every single answer I give with that.
Chair
Taken. Shona Dunn.
Shona Dunn
I am Shona Dunn, the new second permanent secretary at the Home Office. I have Home Office-wide leadership responsibility with particular responsibility for the borders, immigration and citizenship system.
Paul Lincoln
I am Paul Lincoln and I am the director general of UK Border Force.
Jon Thompson
I am Jon Thompson, and I am the chief executive officer of Her Majesty’s Revenue and Customs. I am also the chair of the cross-Government border delivery group.
Chair
Thank you very much. Do please respond to each of the questions according to who you think is most appropriate, and do not feel the need to respond, all of you, to every question. We wanted to start by focusing on people at the border and on what the arrangements will be.
Stuart C. McDonald
Welcome to our Committee. May I start by asking simply what the border arrangements for EU citizens arriving on or after 29 March 2019 will be if there is no deal, starting, for example, with which passport queue they would be using?
Caroline Nokes
It is important to look at this in the round. There are ongoing discussions about segregation of queues, but you will have heard the announcement from the Chancellor yesterday about wanting to expand the cohorts of passengers that can use the e-passport gates. That is a really important step. We want a Britain that is open for business, that is welcoming to visitors and to people who are coming here to conduct short-term business trips post Brexit. To me, that is really important. We are certainly not going to prevent EU passengers from using e-passport gates. As far as I am concerned, we will continue conversations about how best to segregate queues, and indeed whether that is appropriate. From my perspective, EU passengers will not require visas for visits and will be continuing to use the e-passports gates as they do now.
Stuart C. McDonald
So discussions are ongoing. Do you know when you will reach a decision about how the queues would be organised in the event of no deal?
Caroline Nokes
Deal or no deal, it is important that we have a Britain that is open for business, that we use the e-passports gates as, quite frankly, the most efficient mechanism to get people through the border quickly. We know that e-passport gates are one of the best mechanisms for identifying not necessarily forgeries but imposters—the way they triangulate people’s faces is state of the art. It is certainly not our intention to make transit through the border harder for EU citizens post Brexit, deal or no deal.
Stuart C. McDonald
But I am still no clearer on how the queues are going to be arranged, or when we are going to have a decision on how they will be arranged if there is no deal.
Caroline Nokes
We will continue conversations but I am not going to give you a hard deadline today.
Chair
Presumably, your options are that you have three queues—EU, UK and non-EU or non-EEA—you move the EU citizens into the non-EU, or you keep the EU citizens with the UK. Have you modelled all three options?
Caroline Nokes
I think it is fair to comment that if you were to move the EU citizens into the non-EEA queues, it would have a significant impact on the border—if all of them had to be individually processed by a Border Force officer. Obviously, there is always a Border Force officer monitoring the EU passport gates, but we know that at present it takes in the region of 25 seconds for an e-passport gate to process one passenger, and it takes 85 second for somebody to go through a PCP point. It is self-explanatory that if one of your priorities is flow, the way to ensure flow is not to put all your EEA passengers in the rest of the world queue.
Chair
So you are not planning to do that?
Caroline Nokes
No.
Chair
Does that mean that you will have to change the technology for the e-passport gates, because you will need to check something new or different for EU citizens, or will the checks in April 2019 simply be exactly the same as the ones we have at the moment?
Caroline Nokes
For those who have biometric passports, yes. I will just look at Paul to check that that is right. Of course some EEA passengers still can, will be able to and do use their identity cards. I have to say that that is not my preference. I wish everybody would travel on a biometric passport. Those EU citizens who use them currently will still be entitled to use them post Brexit as part of the citizens’ rights agreement that we reached with the EU up until 2025, which gives them plenty of time to plan to have a biometric passport. Of course, many of them already do have a biometric passport, because they travel around the globe.
Chair
But no deal means no additional checks for EU citizens at the border.
Caroline Nokes
We already use checks for EU citizens according to the—
Chair
I know, but just in terms of any additional ones.
Caroline Nokes
No.
Stuart C. McDonald
Do you anticipate the need for additional staff at the border? You say there will be no additional checks, but we have already seen the Heathrow Border Force struggling to meet KPIs in relation to the time it takes for non-EEA nationals to get through the border. Will there be additional staff to cope with that and will there be additional staff needed to cope with any changes brought about as the result of a no-deal Brexit?
Caroline Nokes
As part of our preparedness for Brexit, we are already in the process of significantly increasing Border Force staff numbers with a roughly 300-person readiness taskforce, which will be on stream in December. We have ambitions to recruit an additional 600 before Brexit. But the reality is that if you continue to allow EEA passengers through the e-passport gates—we are not anticipating a sudden influx of numbers, but we have to have an agile and flexible Border Force that will be able to respond to the live situation as we find it on day one of exit.
Stuart C. McDonald
If no-deal Brexit means losing access to SIS II and passenger name records, would not alternative checks have to be performed? If we do not do that, is it not harder to intercept people who pose a risk to security?
Caroline Nokes
We would use a range of tools including our warnings index. You are right to highlight SIS II, but we have advanced passenger information, which comes to us via the carriers, so is distinct from passenger name records. But I think it is accurate to say that there is a range of security tools, which we very much hope we will continue to access post Brexit and during our continuing negotiations with the EU and on a bilateral level, if it comes to that.
Stuart C. McDonald
But you do not anticipate that that sort of change would increase the amount of time that it would take for an EU national to get through passport control.
Caroline Nokes
Well, it is not going to change the amount of time it takes for them to go through an e-passport gate.
Stuart C. McDonald
Okay. What immigration rules do you envisage applying to EU citizens in the event of a no-deal Brexit? I think you said at the outset that you do not anticipate visit visas being required, for example.
Caroline Nokes
No, we certainly do not. I think it is really important that as part of a future mobility framework, we continue to work closely with the EU and individual member states, to ensure that going forward we can have a reciprocal arrangement where EU citizens can continue to travel here for short-term visits for up to three months, and we would very much hope that we will be able to secure a reciprocal agreement for British citizens who are travelling to EU member states.
Stuart C. McDonald
Would there be any difference in treatment for an EU national who arrives at the border having secured settled status already, and an EU national who arrives at the border and has not managed to get settled status stamped in their passport or provided in an e-document? Is that not going to have any effect on their ability to come in and out of the country?
Caroline Nokes
Obviously, with the settled status scheme there is a significant period—in the region of two years—when we are allowing individuals to get their settled status. In the intervening period of any transition period it will be incredibly difficult to differentiate between an EU citizen who is coming here for the first time, for example, and somebody who has been here for a significant period of time but simply has not yet applied for their settled status but would be perfectly entitled to it if they were to apply. So that poses some challenges, but actually, as we have said, anybody who is coming here on a short-term visit will be entitled to pass through the border using any passport gate, in the normal way, but if they wish to come here and work, different rules will be applied, which will be set out in our future immigration system.
Stuart C. McDonald
Can you give us anything further on the timetable for the publication of the White Paper and any subsequent immigration Bill?
Caroline Nokes
It is coming very soon.
Stuart C. McDonald
There is a need for an immigration Bill. Is the timetable for an immigration Bill altered if no deal looks likely?
Caroline Nokes
The immigration Bill will be in place to turn off free movement. The timetable has not yet been set out, but that, too, is coming very soon indeed.
Chair
Just to follow that up: you cannot differentiate at the border between somebody who is newly arriving and somebody who might have been here for 10 years and has gone to visit their nan, and is coming back again. Does that mean that you will be equally unable to differentiate when it comes to employment? Does it mean that until the settled status scheme is fully in place and fully rolled out, even in the event of no deal there will be no change to employment rules or restrictions for newly arriving EU citizens?
Caroline Nokes
I do think it is important that we are not placing new burdens on employers, traders and so on in a transition period. In any transition period, it will be, as I have said, impossible to differentiate between somebody who has been here and not yet applied for settled status and somebody who has just arrived. That is why we have set out the importance of a transition period, and want to make sure, through our citizens rights deal, that we get those rights conferred on EU cits who are going to apply for settled status and will be entitled to it as effectively and efficiently as possible.
Chair
So are you saying that effectively you will apply a transition period even if there is no deal?
Caroline Nokes
I think we have to have a realistic period in which we allow employers and so on to adjust.
Chair
Is there any way for employers to adjust in advance of the settled status scheme being fully in place?
Caroline Nokes
Adjust as to who they are allowed to employ and who not?
Chair
Yes.
Caroline Nokes
As you may know, we are bringing on stream the employers’ digital right to work check, which obviously will be a useful tool in due course for those who go through the settled status scheme.
Chair
But what will they be checking if somebody has not got their settled status in place yet?
Caroline Nokes
The reality is that we have 3.5 million EU citizens whose rights we are determined to protect, so it is likely that there will be a period during which it is impossible for employers to differentiate between them and somebody who is newly arrived. But it is important that all those here for more than three months will be required to register and go through the mandatory registration scheme, so that once they have been here for three months it will be possible for somebody to differentiate.
Chair
But in practice, those requirements on employers to differentiate between those who have settled status and those who have newly arrived are not likely to happen until the end of an equivalent transitional period to the one that you have got in place, if there is a deal.
Caroline Nokes
Well, the new arrivals, if they are planning on staying for three months, will be required to go through the mandatory registration process, which will be a mechanism which would enable employers to check; but we would hope that employers would make sure that they were employing people who had the right to work, who they could verify via the employers’ digital check. What I am very conscious of is that this presents an enormous challenge for those who have already been here, but have not yet completed the settled status scheme, whose rights we want to protect.
Chair
If so, if there is no deal, this time next year will an employer be expected to do a digital check on a French citizen, for example, who they want to employ, or will they just be able to carry on as they would at the moment?
Caroline Nokes
We expect employers to do right to work checks and, indeed, with British citizens, they will ask to see their birth certificate, passport or some other form of ID to check who they are.
Chair
Okay. Suppose somebody shows their French passport, and they are applying for a job this time next year, and there has been no deal. When they show their French passport will that be sufficient for them to be able to get a job, or will there be some additional check that the employer will be expected to do if there is no deal?
Caroline Nokes
We expect employers to make sure that they are behaving within the law. We would expect an individual to have gone through the mandatory registration scheme if they were planning to be here for more than three months.
Chair
But would the employer have to check that they had been through the mandatory registration scheme?
Caroline Nokes
As part of the right to work check, we expect employers to make sure that they are not employing people who do not have the right to work here.
Chair
I am still confused. Let us suppose that this French citizen has actually been here for 10 years. They will not have gone through the mandatory registration scheme and they may well not have filled in the settled status forms yet because they have so far been told that they have some extra time to do that. How does the employer tell the difference between somebody who is newly arrived and needs a mandatory registration form, and somebody who has lived here for 10 years and has the right to work but has not filled in the settled status form yet?
Caroline Nokes
As part of our planning for the settled status scheme, we have factored in that there may be pressures on employers, on the DWP, and around access to other services. At various points during the scheme, we anticipate that there will be up-ticks in the number of people going through the process. For some there may be a significant time pressure if, for example, they have applied for a new job. We are anticipating that those people will make contact and go through the settled status scheme. For them there will obviously be a time pressure because they will want to be able to evidence to their employer that they have the right to be here. You are absolutely right to point out that it will be almost impossible for an employer to differentiate between a new arrival and somebody who has been here for 10 years and has simply not yet been through the scheme.
Chair
If that is the case, what will the Government’s position be? Will the Government choose a requirement on employers to check mandatory registration, in which case there is a risk that somebody who has been here for 10 years could face discrimination because they cannot prove it? Or will the Government choose to say, “Actually we are not going to make it a requirement to assess mandatory registration”?
Caroline Nokes
We have always said that when it comes to the settled status scheme, we are going to adopt a pragmatic approach and make sure that any enforcement regime is not overly rigorous in any early period, because we are quite clear that it is one of the conundrums that employers will face and that we might expect the health service to face. There will be people who have rights under the agreement and under the settled status scheme, but who have not yet gone through the process to be able to evidence that.
Chair
Sure, but that is about whether the Government are enforcing this or not. What are you expecting from an employer? Is the employer going to have to check the mandatory registration this time next year or not?
Caroline Nokes
The mandatory registration scheme does not confer on somebody the right to work. The Prime Minister has been very clear that free movement ends when we leave the EU, so somebody coming here from the EU for more than a visit will have to go through the normal immigration scheme that we are going to bring forward—the future one—so that they have the right to work for a period in the UK.
Chair
I understand what you just said about free movement ending, but you have already said that if there is no deal, that will not make any difference to who will come through the border or to any additional checks that they will face. I am still struggling to understand. This time next year—as opposed to in five years’ time—will there be any change to who has a right to work here?
Caroline Nokes
Yes, because we will have brought forward the future immigration system, and EU citizens will not have an automatic right to work in the UK unless they have been through the same processes that we are going to apply to the rest of the world.
Chair
But you just said that employers are not going to be able to tell the difference.
Caroline Nokes
I have said that it will be an enormous challenge both for employers and for EU citizens who have the right to work here to make sure that we get them through the settled status scheme as efficiently as we possibly can, which is why we opened it up to private beta testing over the summer and why phase 2 opens in November. We know that it is a huge challenge, but there is absolutely going to be a difficulty in differentiating between those who have been here and not been through the process, and those who have come as visitors and then seek to work.
Chair
So it is unworkable, then?
Caroline Nokes
It is not unworkable because we are going to make sure that by the end of the transition period we have 3.5 million or so EU citizens through the settled status scheme who will be able to evidence digitally their right to be here.
Chair
That is at the end of the transition process this time next year?
Caroline Nokes
Yes, but we are very conscious that this is an enormous challenge. The question is, do you wish us to discriminate against those EU citizens who have absolutely every right to be here and work, or shall we have a pragmatic approach to make sure that we implement a system as part of our future immigration system whereby EU citizens who are coming here for more than a visit have to go through the same processes as everybody else?
Chair
I am still really baffled. I understand that there is a time at the end of a transition period, whether there is a deal or no deal, when you can bring in new rules. I am just trying to work out what happens this time next year—it would have been within the transition period if there were a deal, but if there is no deal, this time next year. You have rightly and understandably said you do not want any discrimination against EU citizens who have lived here for very many years, but who have not yet filled in their settled status. What I am asking you, then, is why and how you think you can then have different rules that will apply to new arrivals—people who have just come after March 2019—when employers cannot differentiate between them.
Caroline Nokes
Because we are going to have to implement a future immigration system that reflects that we have ended free movement—
Chair
By this time next year, if there is no deal?
Caroline Nokes
No, not by this time next year, but we will have ended free movement, so people coming here from the EU will have to go through a mandatory registration scheme. We have to make sure that we have a future immigration scheme that can differentiate between the two, but I think we have been perfectly clear that there are going to be challenges during the transition period.
Chair
So surely you are either going to have a system that in practice is unworkable because employers cannot implement it, or you are going to have to accept that people who are arriving after May 2019 will just be covered by exactly the same rules as people who are already here.
Caroline Nokes
They will have to go through mandatory registration.
Chair
How will anybody check that, if employers cannot tell the difference?
Caroline Nokes
If somebody has been through the settled status scheme, they will be able to evidence that. If somebody has not been here prior to the end of March next year, then employers will have to make sure that they go through adequately rigorous checks to evidence somebody’s right to work. It is a very fair point that we do not wish to discriminate against people who have every right to be here, who we want to stay, and who we have said very clearly are welcome to stay. Indeed, we recognise that they have played an enormous part, both in our economy and our communities. We want to make sure that we do not discriminate against them, which will pose a challenge to Government and, indeed, employers in differentiating between those two groups of people.
Stuart C. McDonald
You say you want to avoid discrimination against EU nationals who have the right to live and work here, but that is exactly what the effect of your policy would be. It is not just employers who will be reluctant because they are unclear whether or not somebody has the right to work; landlords will be even more reluctant. You will have landlords who are not going to touch EU nationals with a bargepole if they have not already gone through the settled status scheme. Surely, the only sensible proposal in the event of no deal is to postpone the end to free movement and postpone the new system until the registration scheme closes in the middle of 2021.
Caroline Nokes
I disagree with that. We have been very clear that we will end free movement when we leave the EU.
Stuart C. McDonald
Are you denying that there is going to be a hell of an impact on EU nationals who have the right to live and work here, and that they will struggle to access accommodation and will find it harder to work, even though they have the right to work?
Caroline Nokes
We want as many people as possible to go through the settled status scheme, as quickly and efficiently as they possibly can.
Stuart C. McDonald
How many do you think you can get through the scheme by March?
Caroline Nokes
We have said that we are going to adopt a pragmatic approach to following that up and to enforcement, and I think it is really important that we do that. We have to give people time.
Stuart C. McDonald
But you are not giving them time.
Caroline Nokes
I am hugely encouraged by the progress we have made with the private beta testing phase 1.
Stuart C. McDonald
It has 600 people in.
Caroline Nokes
It was deliberately a small trial to make sure it worked.
Stuart C. McDonald
Yes, but we have three million people to get through it by March.
Caroline Nokes
And 95% of them found it a quick and simple process, going through within 15 to 20 minutes. It is really important that we make sure that we have a scheme that works, and that is why we are moving to phase 2, where it could be several hundred thousand people who go through the scheme.
Stuart C. McDonald
Do you realistically think that the Home Office can get a new immigration system up and running by March in the event of no deal?
Caroline Nokes
No, I have said we are going to end free movement by March. The new immigration system will obviously—
Stuart C. McDonald
If you end free movement in March, how does somebody employ an EU national after March if they do not have settled status?
Caroline Nokes
We will be ending free movement. EU nationals will be subject to the same requirements as non-EEA nationals, but it is really important that we put in place a future system that recognises that the will of the British people, as expressed in the referendum, was that we end free movement, and we are determined to do that—
Stuart C. McDonald
But you do not need to do it by March. No one voted for a catastrophic cliff edge.
Caroline Nokes
As part of the immigration rules, we will have to turn on a system that allows EU nationals to continue to come here until such time as the future immigration system is implemented.
Stuart C. McDonald
Yes, but why not wait until the settled status system is essentially complete? Why do it in March when it will have a catastrophic impact on whether people can access work and accommodation? You will have industries completely unable to recruit from the EU in lots of posts.
Caroline Nokes
We are very conscious that in harmony with other Government Departments we have the modern industrial strategy. We are working very hard with the DFE to make sure that British employers have an attitude of seeing their first port of call for recruitment within the UK. As part of the immigration rules, we will have to turn on a system that allows EU citizens to continue to come here post-March until such time as the new immigration system is implemented.
Stuart C. McDonald
To take just one example, in the construction sector some 80% of its migrant workforce would not qualify under tier II. Essentially what you are saying to the construction industry is, “Come March, 80% of your international recruitment will just come to an end. You will have to train up all these people within the next four or five months to fill that gap.”
Caroline Nokes
We are not saying that. As part of—
Stuart C. McDonald
That is the implication of ending free movement in March.
Caroline Nokes
As I said, as part of the immigration rules, we will have to find a mechanism that will still allow our industries and businesses to find the staff they need. We are very clear that as part of the future immigration system, we will move to a position where we are applying the same rules to the EU as we are to the rest of the world so that we will have a skills-based immigration system that enables us to continue to attract the talent we need from around the globe, while putting us in control of immigration for the first time since free movement came in.
Kate Green
You said a moment ago that you did not intend for there to be new burdens on employers, but what is the situation for someone who is here currently, who would be entitled to settled status, but who has not completed the process before the aftermath of 29 March next year? The employer can look at the registration process, but that person has not come through that electronic registration process. They may have been here for many years. Are you saying that the employer will have to make other checks—absent the person having applied for settled status, but none the less probably being eligible for it had they applied—to ensure that they would have the right to work or carry on working?
Caroline Nokes
It is really important that we do not make life any more difficult for employers. We expect employers now to make reasonable checks on someone’s right to be employed, whether they are British citizens, here from the EU or here under a tier II visa. As part of the immigration rules, we occasionally update those requirements. For example, one that is coming down the tracks is that we will no longer be asking employers to require the long birth certificate—we are changing it to the short birth certificate. I am absolutely conscious that there will be a challenge around how EU citizens evidence their right to work if they have not been through the settled status scheme and how employers check that, but it is important that we continue with the process. I do not particularly like this term, but the current term is a statutory excuse. If an employer can demonstrate that they have made checks on whether someone is entitled to work, that can be viewed by the Home Office as them having gone through the necessary process.
Kate Green
I am sorry, but if an EU or EEA national wants to work now, the employer has virtually nothing to do except confirm the individual’s identity.
Caroline Nokes
If it is a British citizen, they might to ask to see their ID, their passport and their birth certificate.
Kate Green
Exactly. But if they have the right to settled status and have not applied for it yet, what checks do you expect the employer to make on those individuals?
Caroline Nokes
As part of the changes to immigration rules, when we turn off free movement we will have to give an enablement to EU citizens to continue to come here and be here. On the specifics of what additional checks we might expect employers to make if people have not been through the settled status scheme—there is a challenge around how someone who has not yet been through the scheme but has every right to be here evidences that—I might have to write to the Committee with further information.
Kate Green
It will be very important for employers to know very soon what you are expecting them to check that they do not have to check currently. What discussions have you had with employer bodies about this?
Caroline Nokes
On this specific point?
Kate Green
On the specific point of people who could apply for and receive settled status but have not yet done so post 29 March.
Caroline Nokes
Having met a significant number of employer bodies including the CBI and chambers of commerce, having done three roundtables in Scotland, Northern Ireland and Wales over the course of the summer recess, and having met organisations such as the National Farmers’ Union, during the process of those engagement sessions not a single employer raised that with me.
Kate Green
How many EEA citizens do you expect to have received settled status, completed the application process and successfully been granted settled status by 29 March next year?
Caroline Nokes
I think I have written to the Committee already with the update of—
Kate Green
Sorry—if you could remind me.
Caroline Nokes
In the beta phase 1, in the region of 4,000 people were eligible to go through the process and 1,000 actually did. That was making an appointment with Home Office staff and going through the process in almost a hand-holding way. So 25% of those who were eligible had gone through the process. We are now opening—
Kate Green
Of those who were eligible to participate in the pilot?
Caroline Nokes
Of those who were eligible to participate in phase 1 of the pilot.
Kate Green
So a very small number, in truth, out of the totality of EEA citizens currently here.
Caroline Nokes
If you will let me continue, I will bore you with some numbers. In the second phase of the beta testing we have opened it up to all NHS trusts and the equivalents in Scotland, Wales and Northern Ireland, and indeed to those employed by universities, although not students. We think that is a cohort in the region of a quarter of a million people. We might expect, on the current stats, that maybe a quarter of them will go through the process, although it is much less—I am struggling to find the right term—hands on. People will be provided with a link to go through the scheme, and they will effectively be doing it on their own on whatever device that they so choose. If a quarter of those go through I would be very happy indeed, because of course when you have a voluntary link, who knows who will or will not go through it? We expect phase 2 to come to an end at the end of December, and then there will be a fire break between phases 2 and 3, as indeed there was between phases 1 and 2. Then we will open it more widely at the start of next year. I am not sure that I can put a solid number on how many people I expect to go through by the end of March, but it is absolutely imperative that we have tested it, first in a smaller, controlled way and then at scale, before we open it up much more widely. My ambition is to make sure that we have as many people go through the process as swiftly as possible.
Kate Green
Has the Department modelled different scenarios for different numbers having completed the process by March 2019?
Caroline Nokes
Yes, we have, and we have considered the impact of flow through the system. Obviously our anticipation, as with all such large-scale digital-based operations, is that people might very enthusiastically seek to go through the process to begin with. There will then be a lull in the process no doubt, and then ramping up towards the end, but of course the end does not come until the end of 2019. If everything were to go through in a steady flow—I apologise that I cannot remember the precise number, but I think it was in the region of 8,000 per day—obviously you have to have systems that are sufficiently robust to cope with many, many times that number, in case everybody tries to sign up on day 1.
Stephen Doughty
Just a couple of follow-up questions on those issues. Is it true that the application process for settled status can still be done only on an Android phone, and not on an iPhone?
Caroline Nokes
The application can be done on any device, but the chip-checker currently works only on Android.
Stephen Doughty
So half the population will be disadvantaged in making that application easily.
Caroline Nokes
Well, that is Apple’s choice. That is the reality. The Home Office has been working really closely with Apple, certainly since I have been in the job, so for the last 10 months, to encourage them to move to a position where they will allow the chip-checker to be used on their devices, but you can go through the settled status scheme on an Apple device, and it saves it every step of the way, much like doing your tax return online—you do not have to start from scratch every single time. You can then complete it by using an Android device at the very end.
Stephen Doughty
Do you think this can be resolved, or are you just going to blame Apple?
Caroline Nokes
Well, it is Apple that will not release the upgrade that we need in order for it to function.
Stephen Doughty
Well, it is you who are requesting that the system changes and that people have to register. One would think that you would design a system that was accessible to as many people in the population as possible in the easiest way possible.
Caroline Nokes
It is accessible—
Stephen Doughty
To half the population.
Caroline Nokes
It is accessible via any device, but the chip-checker has not been released by Apple. To try to blame that on the Home Office is very unfair of you.
Stephen Doughty
Okay. Can I ask what individuals receive as proof once they have applied for settled status?
Caroline Nokes
They get a digital status that they can forward, via a secure link, to employers, landlords and a wide range—
Stephen Doughty
Do they get a physical document—a biometric permit or anything like that?
Caroline Nokes
No.
Stephen Doughty
So if an employer or another person who had to check their status was unable to access an online system at that time, how could they check?
Caroline Nokes
The Government’s mission is to move to services that are digital by default. We think that providing this—there are several examples of where this is working successfully, such as the digital right to work check. We are rolling out the digital right to rent check, which landlords will be able to access. It might be of interest to the Committee—I know that we have previously demoed how the settled status scheme would work; I am not sure if this Committee took up that offer, but it might be of interest to you to do so, and at the same time have a walk-through of the digital right to work check. It is a fantastic example of how Government services can be delivered digitally.
Stephen Doughty
Given the Windrush scandal, the serious delays in issuing biometric permits to individuals who have the right to live or work here and need to be able to demonstrate that to an employer or otherwise, and the mistakes that are regularly made in those processes, why should we have confidence that the system will work effectively in any way for a whole series of individuals?
Caroline Nokes
You highlighted, in your words, the delay in issuing biometric residence permits, but of course we are not issuing a physical permit—
Stephen Doughty
No, but we are talking about the proof of the right, Minister, and the mistakes that are often made at the Home Office end in those systems.
Caroline Nokes
We are sending a digital proof that does not require any manual construction or the printing of a card, so that is one enormous step forward. You are right to highlight the lessons learned from Windrush. I am very conscious that in the last couple of months a child of EU parents was probably born in the UK who may well live to 120 or 130. It is absolutely imperative that we have a durable system and do not fall back into the trap of Acts of Parliament that give deemed leave, for example, which nobody has any institutional memory of 40 years later. It is really important to us that we have a scheme that is durable and that will be able to be evidenced forever, not only by the Home Office but by the individuals concerned.
Douglas Ross
How important is it to have adequate numbers of Border Force staff before we leave the European Union?
Caroline Nokes
It is very important to have not only adequate numbers but sufficiently flexible and agile staff so that we can deploy them where they are needed at the correct time to fulfil roles that may indeed occur.
Douglas Ross
How would you rate the progress to recruit and employ the additional staff required?
Caroline Nokes
We are doing very well on recruiting the readiness taskforce, and we expect to have about 280 of the projected 300 in post by December. We are taking steps around centralised recruitment and around the fast-track vetting of individuals. Border Force has increased its capacity for training so that we can meet the requirements, but you are absolutely right to highlight that it is important that we remain on track in that respect. I am not sure if Mr Lincoln wants to add anything.
Paul Lincoln
The Committee will probably be aware that two different sets of numbers are normally talked of in this space: about 300 in the readiness taskforce, which we committed to recruit, and then, as part of our preparations, about another 600 additional officers. If you take our baseline against which that was originally done, in March, we were at about 7,700, and at the end of last month—we do not routinely publish this, but we recognise that we are in slightly unusual times—we were at 8,190. We are making significant progress towards that target. Beyond that, we also have other areas that we can fall back on if we need to do so. For example, we work very successfully with immigration enforcement staff who we utilised as part of our summer surge this year, and beyond that, we routinely use HMRC surge during the summer as part of the support for us, if we require it.
Douglas Ross
What is the average time taken for someone to apply for a job with Border Force, to be offered and then to accept the job?
Paul Lincoln
We have said that routinely it would take somewhere between about six and 12 months, depending on the process that has been put in place. We stepped up our recruitment campaign in March, recognising that there was going to be the potential for it to take some time for things to come into place. That is why we started at that date.
Douglas Ross
Do you think six to 12 months is acceptable?
Paul Lincoln
It is a very long time to get people into government, which is why Government are currently trying to shorten the number of steps that it takes to bring people in. There are a significant number of steps that we have to go through. As the Minister said, we have now put in place the ability to fast-track every one of Border Force’s new recruits through security clearances.
Douglas Ross
At what point in the process do you ask about a notice period?
Paul Lincoln
We ask about a notice period as we give the offer, so someone can say whether or not they need to work to that—
Douglas Ross
But surely before you give someone an offer you could ask what their notice period is?
Paul Lincoln
Yes, you could ask that as part of the process, but routinely it would be when you offer. The average that we have experienced is—
Douglas Ross
My question was why don’t you?
Paul Lincoln
We do occasionally—
Douglas Ross
So why don’t you routinely? The routine practice—this is not necessarily conducted by us in all cases but is done by Capita and Government recruitment resourcing. We follow the standard processes that they have put in place.
Douglas Ross
I have an example. Someone applied to join Border Force in April. They went through various application forms, questions, online tests and interview in early June. They were then given a provisional offer in early October, three months after the interview and six months after applying. They are now going through final checks. Assuming that is okay, they are told they will get a formal offer at the end of November. In the eight months it has taken, they have not been asked if they have a notice period, which for them is three months. It will take this person over a year from originally saying that they want to join Border Force. The Minister has accepted that we need to have sufficient numbers in place. Eight months after going through all these hoops, with significant investment of Border Force’s time, Capita’s time and the individual’s time, there will be another three-month period for notice. It seems there is no urgency to recruit these staff. We saw in the NAO report that since the start of October there have been 452 offers but only 149 acceptances. Do you think part of the reason is that it is taking you too long to offer these jobs?
Paul Lincoln
We have said that we need to improve the time it takes to do that. We are working very closely with the chief people officer.
Douglas Ross
You have not told the Committee how you are going to do that.
Paul Lincoln
We have fast-tracked the number of people who can go through. We have up to 320 places available every month to put through our security clearances. As part of our process, we were already moving towards a centralised recruitment process within Border Force, to make sure that we were speedier. Beyond that, we are trying to improve the process, including helping people to fill in their forms to speed things up, having learned the lessons from the last campaign.
Douglas Ross
What is the reason that you have such a low acceptance to the offers given?
Paul Lincoln
The current information that we have from Capita is that we are running at about a 70% acceptance rate.
Douglas Ross
But 452 offers to 149 acceptances is not 70%.
Paul Lincoln
We are told there is a reporting lag in that, so the acceptance rate is running at about 70%.
Douglas Ross
You have issued no further offers, but the number of people who have accepted has gone up significantly in about three weeks?
Paul Lincoln
At the end of 26 October we had 405 acceptances.
Douglas Ross
Out of 452 offers?
Paul Lincoln
Out of a reported 700 offers.
Douglas Ross
So 405 out of 700.
Paul Lincoln
It is still just over 50%, in terms of the reported acceptance rate, but as I said we are told there is a reporting lag.
Douglas Ross
Is that a reporting lag with the NAO?
Paul Lincoln
No, with our recruitment campaigns. Capita give us the information as they get it, and there is a lag in terms of the information about when someone accepts. If there is a gap, it is not necessarily because they have refused the job but because they have not necessarily accepted it yet.
Douglas Ross
Mr Thompson, how do HMRC do in terms of recruitment?
Jon Thompson
How long end to end?
Douglas Ross
Well, how do you rate your department’s progress with that?
Jon Thompson
End to end—between advert and someone starting with us—it takes four months on average. It was nine months when I started. We stripped the process down significantly, identified where the barriers were and removed them.
Douglas Ross
HMRC require 5,454 full-time equivalents for EU exit work and in September you had 2,374 in place.
Jon Thompson
Correct.
Douglas Ross
Do you think that is good enough?
Jon Thompson
I think we are well on track to where we need to be.
Douglas Ross
So you think that is—
Jon Thompson
The key area that I guess—
Douglas Ross
Sorry—do you think that is good enough?
Jon Thompson
Yes, at this point.
Douglas Ross
So you are satisfied that you will meet the 5,454 target?
Jon Thompson
Yes.
Douglas Ross
Without any caveat?
Jon Thompson
I think we’ll be very close to it.
Douglas Ross
“Yes” or “very close”?
Jon Thompson
We are never quite at 100% staffing, because there is always some fluidity to our workforce, but it would certainly be around 95%.
Douglas Ross
Do you have similar problems to Border Force in terms of timeframes?
Jon Thompson
No, because—as I said, when I took over as CEO it was taking us nine months from advert to somebody starting. We did a full process stripdown of that and have got it down to, on average, four months.
Douglas Ross
Can you share some of your good practice with Border Force?
Jon Thompson
We certainly can.
Douglas Ross
Have they asked you?
Jon Thompson
I do not recall us having a conversation about it; we certainly can. We have been at the forefront—
Douglas Ross
Mr Lincoln, Border Force take six to 12 months, which is quite a large range. HMRC have it down to four months. Why have you not asked them for their good practice?
Paul Lincoln
We are using the good practice of the chief people officer, who takes—
Douglas Ross
But not of HMRC, who have got it down to four months?
Paul Lincoln
—who takes best practice from across Government.
Douglas Ross
But you have not thought of going to HMRC, who are working in a similar field to you?
Paul Lincoln
The chief people officer is taking best practice from across Government, to reduce our overall recruiting timeframes.
Jon Thompson
There is one significant difference between us, which is the length of time it takes to get through a security check. I guess you need an SC.
Paul Lincoln
We do.
Jon Thompson
Whereas working at HMRC you don’t; there is a lower security check, and that is a factor that drives some of the time issue.
Alex Norris
Jon Thompson, how many staff have HMRC lost over the last eight years?
Jon Thompson
How many have been lost over the last eight years?
Alex Norris
Yes, what is the reduction in establishment over the last eight years?
Jon Thompson
I couldn’t honestly answer that question off the top of my head, but it would be tens of thousands.
Alex Norris
And as a percentage?
Jon Thompson
I couldn’t honestly tell you: I have been the chief exec for two and a half years, so I couldn’t give you the eight-year number off the top of my head.
Alex Norris
And the two and a half year number for reduction in staff?
Jon Thompson
We are roughly where we started when I took over, because there have been fiscal events that have added customer compliance staff for evasion and avoidance work while we have reduced the customer service estate.
Alex Norris
In relation to your Building our Future programme, for the rest of that programme do you anticipate future staff loss?
Jon Thompson
No.
Alex Norris
No staff loss?
Jon Thompson
No. The original anticipation was that—when we saw our settled spending review 2015, it was anticipated that by 2020 we would be down at 48,000 full-time equivalents. We now anticipate that will be 58,000. There are the 5,300 for Brexit. There has been a series of fiscal events that have given us more than 2,000 additional staff to focus on avoidance and evasion. And the programme that is universal credit impacts on us because tax credits is reducing significantly slower because universal credit is taking longer to build up, and therefore I anticipate we will have 3,000 additional staff compared with what we would have had by the original plan for universal credit. So that’s 10,000 more.
Alex Norris
In the event of no deal, what would that 58,000 staffing number need to be?
Jon Thompson
I gave you the no-deal numbers.
Alex Norris
Oh, those are the no-deal numbers.
Jon Thompson
Those are the no-deal numbers—5,300.
Alex Norris
I know we are talking about no deal today, but let me just ask this for comparison purposes. In the event of Brexit with the Brexit deal that the Government are currently pursuing, what would the staffing numbers be?
Jon Thompson
The deal that I have struck with the Chancellor of the Exchequer is that those people who are no longer required for no deal we would apply to other productive work.
Alex Norris
Within HMRC or—
Jon Thompson
Within HMRC as long as, essentially, we get more tax revenues; then they pay for themselves.
Alex Norris
So it is 58,000, deal or no deal, for HMRC.
Jon Thompson
Were it today, yes.
Alex Norris
Okay, that is really helpful; thank you. Minister Nokes and Shona Dunn, how many staff in the Home Office will need to be diverted into no-deal preparation if we get to that point?
Caroline Nokes
Staffing in the Home Office is always responsive to particular priorities. I don’t think I can give you a specific number for how many are specifically working on no deal. As you have heard, there will be in Border Force an uptick in the region of 900 in the number of staff in place by March 2019 compared with March 2018, but of course we have significant numbers of additional staff working on the EU settled status scheme—in the region of 1,500, I think. But deal or no deal, they will be required.
Alex Norris
But will there come a point, if no deal becomes the most probable of the highly probable outcomes, where you have to divert staff from other programmes within the Home Office to deal with that?
Caroline Nokes
I think that if you consider Border Force very much as the delivery arm of HMRC when it comes to customs, in a no-deal scenario that is where the most significant pressure is going to be for the Home Office.
Alex Norris
I am talking about within the Home Office itself—civil servants and planners who might be working on other projects that are not related to this at all. Will any of them have to do a different job for a time period to support you in a no-deal situation?
Caroline Nokes
It is inevitable that people will have to be reallocated to no deal, but I cannot give you a precise number.
Alex Norris
What projects will you choose to deprioritise first?
Caroline Nokes
The Home Office is a very large organisation.
Alex Norris
Yes. It does lots of very important things as well.
Caroline Nokes
From my perspective—you will be conscious of this because your Committee has been very interested in it—the performance of UKVI is paramount. I would be very reluctant to see any staff from that area moved over to Border—
John Woodcock
So not from that.
Caroline Nokes
Ah—Mr Woodcock is going to take me through a “not from this” and “not from that” process, which could be extremely painful for me indeed. The reality is that obviously that would be a matter to decide across the whole of the Home Office. I am not going to sit here and, on the hoof, make it up as we go along.
Alex Norris
In terms of how Government will plan to make that prioritisation if it has not happened yet, will there be an inter-ministerial arm wrestle to decide? Not a literal one, a metaphorical one.
Caroline Nokes
No, not an inter-ministerial arm wrestle. The reality is that from the start of the summer onwards we have significantly increased our no-deal contingency planning, which is absolutely the right thing to do. I am going to bore you all with the comment that of course we are working for a deal, and that is what we want to get out of it, but it is absolutely right that we are now working very closely alongside other Departments on our no-deal planning. I would highlight the work of bodies such as the border delivery group, and the work that is currently going on across Government with Departments such as the Department for Transport and the Department of Health and Social Care, making sure that we have contingency planning in place. Of course that goes alongside things such as the Civil Contingencies Secretariat at the Cabinet Office. It is very wide ranging, but we have certainly increased the attention on the prospect of no deal since the beginning of the summer, and rightly so. I do not know whether Shona wants to add anything.
Shona Dunn
Briefly—you have covered most of it, Minister—in terms of Border Force, the numbers that we have been recruiting are very much designed to be able to cope with any scenario that we deal with. As you say, numbers have significantly increased on the UKVI side in order to undertake European casework and to support the EU settled status scheme. The thing I would add is that the Department has in recent months been looking in a consolidated and integrated way at its no-deal planning across the piece. We are absolutely not in a position to say that these things will stop, but we are looking at everything that is going on and making sure that we are in a position to make those judgments as and when we need to do so.
Alex Norris
Do you have the ability to bring in people who are working in Government but not in the Home Office as supernumerary support for a short period of time?
Shona Dunn
If we found ourselves in that position—coming back to the point that Paul made about the chief people officer and cross-civil service HR—I think there would be questions to be asked about the degree to which that was possible. I don’t think we anticipate at the moment that that would be necessary, but that depends on the circumstances that we face at the time.
Chair
I am going to stick on the border staffing issues at the moment. Can I quickly clarify, Mr Lincoln, the point you made, I think to Douglas Ross? You said you had a target. At the moment you have 7,700 staff.
Paul Lincoln
The baseline which the NAO report, for example, speaks about was 7,700-ish.
Chair
You are now on to 8,190, and your target is—
Paul Lincoln
About 8,600, so it is on track for that. I should also point out that the requirements to be placed on us in a day one no-deal scenario are actually less than that which we are recruiting for. The NAO report also says that.
Chair
Say that again: the requirements on you in a no-deal scenario are actually less?
Paul Lincoln
We are recruiting higher than the specific requirements that other Government Departments are placing on us in a no-deal scenario.
Chair
Does this just take you back to your 2014 staffing levels?
Paul Lincoln
The NAO report says that we have, over a period of time, reduced by about 7%. We are looking to move up by 8%. The difference here, of course, is that it is not just a linear question of numbers. Between those times we have had significant changes in technology. We talked earlier about e-gates and automation. That makes a big difference to the way in which you deploy your staff.
Chair
And a 25% increase in passengers.
Paul Lincoln
The key difference there is mostly around the non-EEA. There are about 20 million non-EEA passengers, and the announcement yesterday by the Chancellor will affect a cohort of 9.5 million. We expect somewhere over 6 million to make use of the e-gates as a result.
Stephen Doughty
With the greatest respect to many of your staff, Mr Lincoln, who do an incredible job in keeping us safe and making the appropriate checks, we have had some pretty damning evidence from Heathrow, other airport operators and others about performance levels. This obviously refers to non-EEA, but there have been 6,024 non-EEA breaches of your targets in just the last four months across all four terminals at Heathrow. You can regularly see the levels of queues and the challenges faced at any port of entry to the UK, so why should we have confidence in the organisation being able to deliver what will potentially be a very, very challenging environment—a very uncertain environment—at your current staffing levels?
Paul Lincoln
We recognise that the performance during the summer in some of the larger airports such as Heathrow was not what we had hoped. We provided about 220 additional staff, which made a difference; Heathrow and others will say that it made a difference to performance during the summer. In fact, I was with the Airport Operators Association yesterday—I met with them a number of different times during the summer. They are all very pleased, of course, by the announcement that was made yesterday, and they all think it will have a significant effect on performance next year.
Stephen Doughty
May I ask you about e-passport gates? From personal experience of travelling through them, I have not been through them at a time when there hasn’t been a failure of one of them, when numerous of them have not been out of service and when there has not been an intervention by a physical Border Force individual, when an individual has not been recognised and so on. Do you believe that you have the physical human staff to cope with failure and, indeed, with when individuals do not get recognised by the system?
Paul Lincoln
The availability of the gates that we have running at any given time runs at more than 99%. There are times when we choose not to have certain banks of gates open, which is the issue you are probably referring to, and that is around what is the best use of our staff at any given time. We run to service level agreements with the airports, which means that we do not need to have all those gates open and our staff are better deployed in the non-EEA queues as a result.
Stephen Doughty
What percentage of the individuals going through require an intervention by a physical human?
Paul Lincoln
The reason why people might require an intervention is not simply that the gates are wrong. We do assessments of what is going on there. We actually expect referrals out of that. We specifically want there to be referrals.
Stephen Doughty
But what percentage?
Paul Lincoln
I am not prepared to say publicly the percentage on that, but we want to have referrals out of that because we want to check if we think there are people who may be imposters or are using forged documents.
Stephen Doughty
But it requires a significant investment. If you are going to increase the use of e-passport gates, you will have to increase the number of physical human staff there, to be able to do those additional checks.
Paul Lincoln
We do not expect there to be a significant increase as a result of that.
Stephen Doughty
But what are the actual metrics? Have you modelled this?
Paul Lincoln
We have done modelling of this, but, as I say, I am not prepared to say in open committee what the answers to those questions are.
Stephen Doughty
Okay. One last question: Minister, in terms of the money that has been provided to the Home Office, you have had £500 million extra in the last two years for Brexit preparations. How much of that has been spent on the preparations we have been talking about today, and what additional money were you granted yesterday in the Budget for additional preparations and what will it be used on?
Caroline Nokes
A significant proportion of the money has been spent on the EU settled status scheme, which I hope the Committee will agree is an important and good use of the funds. I am conscious that the Home Office is currently bidding to the Chancellor for the next round of Brexit funding. I do not think I am at liberty to divulge the number, but it is obvious that our focus has been on the EU settled status scheme and EEA caseworkers. It has been about Border Force preparedness and ensuring that we have enough officers in place there.
Stephen Doughty
So you were not specifically granted extra money yesterday. You are in the process of bidding for it now.
Caroline Nokes
I believe so.
Stephen Doughty
But you cannot tell us the amount you are asking for?
Caroline Nokes
No.
Stephen Doughty
Is it more or less than £500 million?
Caroline Nokes
I am not going to tell you. I don’t think I can tell you. I don’t think I am at liberty to divulge that number.
Chair
Will the Border Force be expected to do additional security checks if there is no deal?
Paul Lincoln
We will continue to do all the checks we already do—100% of all scheduled arrivals; we will continue to do that. If you think about the juxtaposed controls in France, we already screen all the lorries coming through—100% have sniffer dogs go around, for example. That is one of our most significant finders for organised immigration criminality. We will continue to do forgery protections, we will continue to do safeguarding and modern slavery examinations, and we will continue to do CT referrals and schedule 7 examinations with CT policing.
Chair
If there is no deal, though, you will lose SIS II and you will lose the passenger name record data, so you will lose routine data on individuals subject to European arrest warrants, missing people, witnesses, absconders, people or vehicles needing checks or surveillance and significant objects that should be seized, including firearms or passports. How much of a loss of intelligence is that to you at the border?
Paul Lincoln
On the passenger name records, Barnier is on record as saying that he would like to continue that even in a no deal—
Chair
I know; we are assuming that in an ideal world all this is sorted. What I am just figuring out is, in a no-deal situation, what will be lost?
Paul Lincoln
The reason I made that point was because he was saying that in a no-deal situation he hoped it would continue. If we did lose some of those things, of course, we do not just work purely off EU tools, but we work with a range of other partners on this. We work, for example, with the counter-terrorism group, which is done through counter-terrorism national security networks rather than through EU Commission tools, and we also work with our Five Eyes partners. We will continue to get a range of other information and a lot of the information put on our systems is not done through SIS II. It is also done through local police forces and other institutions we work with.
Chair
I am sure all of that is true.
Paul Lincoln
That said, I am not saying it will not be more difficult. The witnesses who are due to follow will probably say that for them it will be more difficult as a result. We work with a lot of people and we are working with all those partners to try to ensure that we minimise any disruption.
Chair
But the evidence we took from Rob Wainwright used the example of a sex offender arriving at the border and the Border Force not being able to check that, or not receiving that information, because they do not have access to SIS II. We also received information saying that, on average, police, Border Force and immigration officials access SIS II more than 1.4 million times a day. How many of that 1.4 million times are Border Force and immigration?
Paul Lincoln
I do not have the statistics in front of me on the number of times we have accessed it and for what purpose.
Chair
Does that not feel like a pretty important thing to know if you are planning for no deal? If that is the loss of intelligence that you will have to make good through other routes, surely that is an important thing to know?
Paul Lincoln
We routinely check a huge system and huge number of records—I am not prepared to say how many of those records there are—in order to check for people against a range of different outcomes, some of which will be immigration, some of which will be counter-terrorism and some of which will be national offenders, as part of that.
Chair
However, I think Parliament needs to know what the loss is in terms of the scale of the intelligence and information that we will have at our borders if there is no deal, so I am going to press you again: what is the loss of intelligence as a result of not having access to SIS II at our borders for our Border Force? What information will they routinely not get that they are getting at the moment?
Paul Lincoln
We have contingency plans to work with Interpol, which will provide us with other sources of information as part of that.
Chair
Will it provide the same extent of information?
Paul Lincoln
It will provide similar sources of information. Of course, all EU member states are part of Interpol. There are 193 members of Interpol from whom we would be looking to try to get information.
Chair
So that will provide all the information, for example, on significant objects that might need to be seized—firearms or passports? Will it provide all of the same information?
Paul Lincoln
I am not saying it will provide all of the same information. It will provide similar information and we are working with people to ensure that, as close as possible, Border Force officers will have the right information to be able to make interventions where they need to.
Chair
Will it provide all the same information on people or vehicles that need checks and surveillance?
Paul Lincoln
I don’t think it will provide all of the same information; it will provide similar information, and we are working—
Chair
I don’t understand what “similar information” means. If it is not all of the same information, does that mean you will have some additional information that will be better, or you will have less information?
Paul Lincoln
We will have different information in some cases, because different sources will give us different things. It is worth saying that in a no-deal situation we will also be able, in some cases, to get additional data that we are not currently able to get, particularly in the goods space.
Chair
Why?
Paul Lincoln
Because we do not routinely take customs data, for example, on goods that we could use for targeting in the future.