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Part 4: Banding Dwellings in which Valuation Office Agency staff have a Personal Interest

VO letters and forms which are not included as appendices are available as MS Word Templates

4.1 Introduction

It is essential that the VOA is seen to be fair and accurate when banding dwellings in which staff have a personal interest. All staff have responsibilities, as Civil Servants and employees of the Agency when dealing with council tax bands, to ensure that personal interests in properties are declared and that conduct, if challenging a council tax valuation list entry, is appropriate and proportionate.

Members of staff within the Council Tax business stream have the authority to amend banding information on the CDB. Therefore, it is necessary for the Agency to check that any alteration is appropriate and complies with valuation integrity and audit requirements.

4.2 Listing Officer Responsibilities

Staff dwellings: Each Listing Officer (LO) is responsible for the banding and property details of any dwelling within their Unit in which any member of staff has an interest as occupier and/or owner. This responsibility extends to all staff employed in the Agency. A record of these addresses must be maintained by Unit management. This record must hold a Restricted protective marking.

Records to be kept: A record must be kept in each Council Tax (CT) Unit of the staff employed in the Unit and the properties in which they have an interest as owner or occupier, along with other staff in the VOA who own or occupy a property within the Unit’s area. Where any property is outside the Unit in which the member of staff is employed, details should be sent to the relevant LO. Each Director should ensure that details of staff within their Directorates, but not employed in one of the CT Units, is also maintained and sent to the relevant LO each April.

In April of each year: The record must be reviewed and LOs, through their CT Team Leaders, should access the CDB using Council Tax enquiries – Enquire on Banding by Address. All bandings of properties in their area, in which VOA staff have an interest, and the attribute details for these properties, should be checked to ensure that they have not been changed without the LO’s authority.

SCS or Grade 6 occupied properties: LOs are personally responsible for carrying out the banding and checking of the property attribute details of any dwelling located within their Unit in which an Agency Senior Civil Servant, or Grade 6, has an interest as occupier and/or owner.

The Director of Council Tax & Housing Allowances must be asked to confirm that the result of any band review of a dwelling in which a Listing Officer has a personal interest as occupier and/or owner is fair and accurate

Following any review of the banding of a dwelling in which a member of VOA staff has an interest, the LO must be satisfied that the proposed banding, and the property attribute details, are fair and accurate. A record of such checks must also be maintained and made available for scrutiny by audit staff. Click here for the monitoring spreadsheet.

4.3 Individual Staff Responsibilities

The Guide Section 9 - Conduct and Discipline Part 1 outlines the general responsibility for all of us as Civil Servants to be, and be seen to be, honest and impartial in all we do.

Appendix 5 - Conflict of Interest deals specifically with the responsibilities of staff to declare any conflicts of interest and gives guidance on the extent to which they may represent themselves and others in matters to do with the work of the VOA. If you intend to represent yourself or a family member in a CT matter, you must get explicit permission to do so from the relevant CT Unit Head first.

Additionally, paragraph 9.1.10 advises: ‘You must take all possible steps to protect yourself and the Agency from any allegation or perception of impropriety. You must report any real or potential conflict of interest to your manager immediately you become aware of it. This guidance is to help you decide what you must do to reduce your risk of getting involved in a situation where there could be an actual conflict of interest, or it could appear to someone inside or outside the VOA that there is potential for such a conflict of interest. You must not use your official position to further your private interests or those of anyone else and you must report any conflicts of interest to your line managers as soon as they arise.’

Additionally, The Guide also confirms that: ‘You must also avoid apparent conflicts of interest if it could appear to a disinterested third party that you could take advantage of information or connections gained through your work in the Agency to benefit yourself or others. You must take sensible steps to distance yourself from transactions or activities where you may be vulnerable to criticism or accusations.’

With a specific reference to Council Tax: ‘You must NOT under any circumstances attempt to alter the computer data relating to the banding of a property that you have any personal interest in.’

4.4 VT/VTE Hearings

All VOA employees have an individual responsibility to ensure the integrity of the organisation is maintained. You should think very carefully about pursuing a matter to a Valuation Tribunal hearing, or beyond, if doing so could call into question your behaviours in the context of the Civil Service Code or have potential to cause reputational damage to the Agency. You should discuss this with your Unit Head, and make your Director aware of the matter, before proceeding.

4.5 Protocols

You must follow the protocols below if you seek an alteration of a band of a property in which you have a personal interest: (The Guide – Section 9, Appendix 5, Conflict of Interest). LOs should personally approve the assessments adopted in these cases.

Disclosure of Personal Interests: any member of staff who, in a private capacity, makes a ‘proposal’ or other challenge or is involved in any other capacity in connection with an assessment for council tax purposes (either personally or through an agent) must disclose in writing to the LO in whose Unit the property is situated, that they are a member of the Valuation Office Agency.

Unit Head: LOs should seek the approval of their Director to challenge the council tax list entry of a property in which they are interested as owners or occupiers or in which an immediate relative of theirs is similarly interested.

Property owned/occupied by Senior Civil Servants: Property belonging to members of the SCS should be dealt with personally by the LO responsible, and the decision should be confirmed by their Director, or the Chief Operating Officer.

4.6 Information available within the VOA

It is important that staff do not seek to benefit from internal information that is not generally available to the taxpayer. The Civil Service Code specifies that ‘you must not misuse your official position, for example by using information acquired in the course of your official duties to further your private interest or those of others’.

4.7 Cases of doubt

In the event of special difficulties or unusual circumstances the facts should be reported to the Director of Council Tax and Housing Allowances (CT & HA Directorate).

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