Assessment panel observations

This service assessment followed a slightly different model to previous. Rather than a service assessment dedicated presentation of the Discovery findings, the assessment team attended the final Discovery Show and Tell for all stakeholders. An additional hour was then added on for the assessment panel to talk with the Discovery Team and ask additional questions.

This appears to have worked relatively well and is a potential model for future assessments, especially Discovery assessments.

The Discovery Team and the Product Owner were clear that this Discovery has effectively identified a number of new questions than could be answered in the time available. There appears to have been an assumption that the “Phase 1” Discovery work, completed some time ago, could be picked up and run with or built upon. It is not clear what of this Phase 1 work was used in this Phase 2 or what, if any, of the Phase 1 work remains valid at this point.

Given that Phase 1 Discovery didn’t lead to anything at the time, it may well have been more appropriate to review the Phase 1 to determine usable assets, rather than assume it remained valid work to build directly upon. There has been much previous work around the complexity and differences within Local Authority operations. There were missed opportunities to use previous findings and lessons from other Discoveries.

Recommendation - review previous Discovery findings and recommendations to identify concerns, gaps or assets before deciding on scope of further Discovery. Undertake this considering the broader scope of the FHRS scheme. There was a particularly strong recognition that moving Digital Badges online brings many other factors into focus e.g. data quality, timeliness, validation. By opening up how to deliver a service, the underlying pillars are also exposed.

In the Discovery there was a particularly strong focus on the “mandatory” element of displaying the badge. This appeared to override taking into consideration how other bodies enable businesses to display other rating or certification schemes digitally. It is not clear that mandating at this stage is necessary or the first step.

The assessment team felt this had also led to a focus on the more technical or complex solution options. Ultimately, a Food Business would commit fraud by presenting a misleading or incorrect FHRS rating. Therefore, at the simplest level, the Food Business could be given access to a range of Digital Badge resources to reflect their respective rating.

There was a strong push for a tracking element. The idea being that use of the badges could be monitored by the FSA. This carries strong notions of oversight and potential trust issues for implementation. Whilst an option, the issues raised with some possible options also needed exposing. The service design was a good and interesting piece of work, recognising the complexity, but given the actual range and depth of user interviews, there appeared to be limited evidence on which to base this. There was also a lack of clarity on the actual users for the Digital badges.

Recommendation - to inform policy recommendations and implementation decisions provide a range of possible Digital Badge implementation options with associated impact assessment. This would include likely costs and benefits to FSA, Food Business, Local Authorities and Consumers. There was a particular mention of using the existing FHRS rating design. However, the feedback suggested that Consumers do not find this easy to understand. Therefore wedding to a particular style for digital to mirror what is seen on the doors of premises may not be appropriate.

Recommendation - Review and test FHRS Digital badge designs. Do they need to match the style guide for the existing physical badges? The FSA does not currently have a strong baseline for food business web/digital presence. This may potentially hamper policy formation. For example, what proportion of Food Businesses are already represented via the aggregators who are already displaying FHRS online? In conjunction with this, consideration should also be given to food business complexity. For example, is the online presence of a Food Business singular, but they have multiple premises e.g. A supermarket will only have one website, but many stores.

Recommendation - FSA to explore developing useful definitions for premise v business v establishment A common challenge observed by the panel is the complexities around the understanding of the differences between for example premises, establishments and food businesses. In some cases, the differences matter. Several studies on the LA data Landscape highlight three problems:

1. There is a huge variety of data across the LA landscape
2. LAs mostly do not hold business information, but rather Premises information.
3. FHRS is built around establishments. All of this makes management of the data needed to present to end users complex.

The FSA should explore drafting a useful set of definitions to help reduce confusion and reduce problems through future work for both FSA and Local Authorities.

Recommendation - FSA to consider research into Food business web/digital presence to help inform policy and option selection Need a broader food business web/digital presence research activity - as basis for multiple FSA activities - “the FSA does not have a good empirical understanding of the digital landscape of the food industry”.

Recommendation - If Digital badges are made mandatory, FSA also needs to consider how this may wrap or join up with other services. This includes those currently in service and those in development e.g. Report a food problem? Report an allergic reaction? FHRS is only one element, but if FSA pushes its brand through the Digital Badges, it may also need to consider greater use of other associated services and access to them. The assessment panel observed a general recognition from the team and the wider FSA that there are interactions between the narrowest potential scope of a digital badges service and a set of wider needs. In addition, the larger impact of the whole of FHRS as, any changes and direction of travel will all impact on how this aspect could be taken forward.

User Needs

Further clarity on who is the actual user. There are needs across consumers, Food Businesses and Local Authorities with respect to implementing Digital badges. Who is the lead user and who does it need to work for first. There was no specific evidence of research with consumers (may have been in Phase 1). There were also a relatively limited set of Food Businesses interviewed with no specific acknowledgement of the differences in how aggregators work e.g. Just eat v Trip Advisor. In particular, there needs to be a real focus on small businesses and their needs, how would they react to mandatory display?

Data

There are specific challenges around business vs establishment - currently FSA or LAs dont have a conceptual model that contains actual business lists. Data quality - known issues, and assumedly out of scope of this work - but what routes for an end user or a food business to report these, and what are the desired timescales for fixes to flow through.

The Team and Ways of Working

Good recognition of the Agile process and ways of working. Really good to hear such enthusiasm for what the team has done from Jayne, Product Owner. Potentially more FSA Digital Team engagement during the Discovery could have helped highlight opportunities or existence of information from previous Discoveries