Yorkshire and Humber

Regional Migration Partnership

‘Supporting Local Delivery’

Business Plan 2009-10

1. FOREWORD

By Councillor Olivia Rowley, Chair of the Yorkshire & Humber Strategic Migration Group
and Jeremy Oppenheim, Regional Director, UKBA

Yorkshire and Humber Regional Migration Partnership (YHRMP) has recently restructured,
moved to new premises and appointed, in Rob Warm, a new lead officer. Our ambition is
to build on our successes and good reputation to become a key part of the way that the
region does business, providing expertise and co-ordination on all issues relating to
migration.

We have a very strong foundation in this region. The Regional Migration Partnership is a
partnership of great strength and maturity with a reputation nationally for innovation and
excellence. This is supported by a committed team with great experience and a strong
track record of delivery. This provides an excellent foundation for the future.

But this is a dynamic and fast changing policy area, and our structures and ways of
working need to evolve to reflect that. We need to be more responsive to the needs of our
members, more intelligent in our understanding of migration trends in the region and more
professional in the service we provide. We also need to redefine how the Partnership
relates to UK Border Agency (UKBA) to establish how we can work more closely together
to deliver shared objectives.

This business plan sets out how we intend to achieve this change working closely with one
another.

Olivia Rowley Jeremy Oppenheim

Chair – Strategic Migration Group Regional Director, UKBA

2. AIMS OF THIS BUSINESS PLAN

This business plan is a submission to UKBA to draw down the ‘enabling grant’ which
supports the Partnership’s strategic work (this is a grant paid by government to support
regional coordination on migration issues). However, it is important for Government, and
the region, to understand our work in context. As a Partnership, we believe our
combination of operational delivery and strategic expertise is a key asset. Understanding
our strategic role in the context of the operational work is essential if the region, and
national government, are to fully benefit from our activities.

Following discussions with UKBA and other partners, it was agreed that this year’s
business plan should reflect the full scope of the Partnership’s activities. This provides a
more coherent picture of our activities, and enables the Partnership to maximise the
synergies between our strategic and operational work. It will also enable us to
communicate our work more effectively within the region – improving buy in from partners
and thereby improving delivery on issues relating to migration.

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3. WHAT IS THE REGIONAL MIGRATION PARTNERSHIP?

Yorkshire and Humber Regional Migration Partnership is a regional organisation which

works with national, regional and local government to ensure that the region can deal with,
and benefit from, migration.

We work in partnership with all appropriate agencies across the statutory, voluntary,
community and private sectors to help support the delivery of high quality services to
migrants in a way that benefits everyone living in the wider region. The YHRMP has 4 key
roles:

• Providing strategic leadership and coordination for the region around migration
issues – (‘the enabling role’)

• To work with partners to deliver effective integration of refugees

• To provide central contract management and co-ordination to deliver the

agreement between 10 local authorities in this region and Government for meeting
the accommodation needs of asylum seekers.

• To ensure that the region has the information, data and research to make sure
that the needs of all migrant groups are met in long term local and regional
strategies.

Although the organisation provides an umbrella for delivering the public sector
accommodation contract, and for carrying out a broader strategic role, there is a very clear
separation of these functions in terms of both governance and operations. This is
important in allowing a full and open debate to take place within the region, which is not
clouded by conflicts of interest on the part of those Local Authorities involved in delivering
the contract. The member and staffing structure that we have in place allows us to do this.

4. PARTNERSHIP WORKING

‘Partnership’ is not just part of our name – it is an integral part of how we work. The
Regional Migration Partnership cannot achieve its aims in isolation, and we will work with
the full range of organisations engaged with our client groups in order to deliver our aims
most effectively. This will help ensure that there is a diversity of voices and experience
guiding our work.

Partners come from a range of sectors and include Local Authorities, the voluntary sector,
UK Border Agency, health and police. There is no fixed list, or set number of partners that
we work with – although members of Strategic Migration Group include Police, Health,
TUC, local authorities and the voluntary sector. Whether we are working with a group of
Local Authorities to deliver accommodation, carrying out our strategic enabling role or
working to enable effective integration, we bring a range of agencies to the table and help
co-ordinate their delivery activity.

One of our key corporate functions, identified in the How We Work section is around
developing and maintaining the partnership structures. This will include working more
closely to support the development and operation of multi-agency groups at local and

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regional level, and strengthening our political structures to ensure that Local Authorities
play a key role in shaping regional policy discussions.

The way in which our structures work are set out in Annex A.

5. ABOUT OUR REGION

Yorkshire and Humber is the 5th largest of the nine English regions in terms of land area,
and the 6th largest by population. It has huge variety, with population density for instance
being 100 times higher in Hull than in Ryedale. It contains more big towns and cities than
most English regions (with Leeds, Sheffield, Bradford, Hull and Huddersfield all in the
biggest 24 nationally) but also has more land in National Parks than anywhere else.

Population is around 5.142 million. This figure has been broadly stable for the past decade
if growing slightly, partly as a result of migration into the region. However, the stability of
the population disguises change within it. The trend is to more older people and fewer
children, and a higher proportion of people from black, Asian and minority ethnic (‘BME’)
communities, especially of Pakistani descent. These communities are most concentrated
in West Yorkshire, itself the most densely populated part of the region and at the
crossroads of key north-south and east-west transport corridors. Household size is
reducing with over half of households now two people or less; whilst rural communities are
increasingly becoming home to a disproportionate number of older and more affluent
people.

In terms of housing in the region, Yorkshire and Humber has a range of different housing
markets. Some provide excellent quality homes and environments, but there continues to
be an imbalance between the housing markets in different parts of the region. Popular
high value areas – especially in North Yorkshire, the western parts of Bradford and South
Yorkshire, North Leeds, Harrogate and York and parts of the East Riding – are
‘overheated markets’, where housing is inaccessible to many local people, key workers
and first time buyers. By contrast, the decline of traditional industries has led to great
changes to many inner urban areas and to uncertainty about the need for and function of
some historic settlements. This coupled with increased household mobility and shifting
aspirations has created a complex picture of demand.

This picture has been further complicated by the recent challenges that we have seen in
delivering housing in the region. Whilst demand for housing remains extremely high, there
are real difficulties faced by many people in accessing that housing, particularly in access
to finance. In turn, this has had an impact on development in the region – from both private
and housing association sectors.

At the same time, the current economic downturn is having a profound impact on the
regional economy. The region is experiencing a deterioration in economic activity with
manufacturing production contracting more quickly than at any point since the early
1980’s. There is a gloomy outlook too for the retail sector in the region, which is suffering
from low consumer confidence and a reduction in the availability of credit.

In terms of employment, Oxford Economics forecasts Yorkshire and Humber will lose
67,100 jobs between 2008-2010 with over 90% of the jobs lost likely to be in the
manufacturing, business services and retail sectors. The region has already seen major
employers such as Corus, HBOS and Bradford and Bingley making significant job cuts.

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Cumulatively, rising unemployment will inevitably have an impact on migration trends in
the region and potentially on wider cohesion issues.

6. IMPLICATIONS AND CHALLENGES FOR OUR WORK

The economic and housing challenges facing the region provide an important context for
all of our work.

• For our strategic enabling role, the strategic challenges that the region faces are
changing, with reductions of A2 and A8 migrants coming into the region, and some
migrants returning to their native countries.
• For our integration role, successful integration will become more of a challenge in
an economic downturn, where individuals from host communities are increasingly
concerned about their own employment and finances.
• In delivering the accommodation contract, wider pressures on social housing will
make it increasingly difficult to identify and secure accommodation.
• On the information, data and research agenda, our key priority for 2009-10 is to
better understand the way in which the economic downturn is impacting on
migration trends.

7. THE SIZE OF OUR BUSINESS

Understanding how migration currently impacts on, and will continue to affect our region, is
key to our long term future. We do have some understanding of where migrants currently
live in the region, and their needs, but the data available to us continues to be imperfect
and imprecise. However, we are, in the forthcoming year, the region in which UKBA is
piloting the sharing of a wider range of information and data about migration. This
development if successful will be rolled out by UKBA nationally. This is an excellent
opportunity to strengthen our thinking around migration trends and ensure that this region
is at the forefront of work nationally in this area.

Our current understanding is stronger in some areas than others. We do know, for
example, the numbers of migrant workers who have registered under the Worker
Registration Scheme, but in contrast, we know little about migrant workers from outside
the EU. Similarly, we know the number of asylum seekers living in the region, but we do
not know what has happened to those who have received refugee status or the majority of
those whose claims have been refused. We are working with UKBA and other partners to
try and plug some of the data gaps to develop a much more rounded understanding of
migrants currently in our region.

Recent policy changes and other influences have changed the composition of migrants
across the region during the past year and will continue to do so:

• Asylum seekers (and failed asylum seekers receiving support) continue to be

mainly located in the urban areas, with Leeds, Sheffield, Kirklees, Bradford and
Rotherham taking the largest numbers. The past year has seen a significant
decrease in the overall number of asylum seekers being accommodated in the
region, falling from around 10000 to 8000, mainly due to the UKBA Case Resolution
Programme. Asylum seekers will continue to be dispersed by the Home Office to
Yorkshire and Humber, although the overall numbers in our region will be affected
by factors such as instability around the world, increasing border controls in the UK,

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 and the continued progress of the Case Resolution Programme. The UASC reform
programme may also have an impact in the region.
• Resettled refugees - In line with the increased annual quota of 750 refugees to be
resettled under the Gateway Protection Programme across the UK, the number of
refugees arriving in our region under this programme continues to rise slowly. Hull
and Sheffield, the original participating authorities, have received just over 500
refugees in total since the programme began in 2004; Bradford is a new participant
accepting a first group in December 2008. In the coming year, we anticipate that
around two-thirds of the national quota will be composed of Iraqi refugees – who
may have different needs to previous groups. This is likely to be reflected in future
Gateway arrivals in our region.
• Migrant workers from the A8 Accession States (those who joined the EU in 2004)
continue to arrive and register to work in our region but there has been a significant
decrease in new registrations – partly due to the impacts of the recession. 12300
workers registered via this route in 2008. Most of our migrant workers are
registering their place of work in the urban areas, with Leeds, Wakefield, Kirklees
and Bradford receiving over 1000 registrations each this past year. However, all
Local Authorities will have felt the effects of new migrants in their area, as workers
have registered in every Local Authority across the region (the smallest number
being 70 in Craven), reflecting the nature of the work available to these groups.
While the ‘typical’ migrant worker in our region is Polish, aged 18-34 and male,
there are other regional trends. For instance, the region hosts significant numbers
of workers from Latvia, Lithuania and the Czech Republic (which has an effect on
the demand for translation services) whilst in some local authority areas there are
now more female than male registrations. It is also important to understand better
the wider pressures that migrant workers may place on local services. 2008
registrants brought nearly 1400 dependants to the region which will have put
pressure on local services, particularly local schools.

What all of this demonstrates is that, although we have a strong and growing
understanding of migration in our region, migration patterns are not static, nor are they
easily predictable. While it is useful to know the current picture of migration in the region,
our partners need to be able to plan for possible future changes in coming years. The
Partnership is committed to developing and improving our regional understanding of
migration in order to enable them to do this.

8. 2009-10 – HOW WE WILL WORK

Key to the Partnership’s future success will be our ability to provide a high quality service
to members, Partners and the wider region. Therefore, in addition to the specific work
strands identified below there are also 4 organisational objectives which will underpin
everything we do:
• Develop and Maintain the Partnership Structures
• Develop a One Team Approach and Ethos
• Communicate Effectively
• Provide a Professional Service to our Members, Partners and Clients

More detail on these organisational objectives is provided on the following page:

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 Develop and maintain the partnership structures –

• Develop and maintain the Strategic Migration

Group, associated subgroups, RIES Board
(Refugee Integration and Employment Service),
and the Public Sector Contract Group
• Work with Local Partnership Structures to
support better delivery
• Work with Yorkshire Forward and Local
Government Yorkshire and Humber to establish a
clear space in the new regional structures

Provide a professional service to our members, Develop a one team approach and ethos
partners and clients
• Establish an organisation wide secretariat • Support the team to better understand and
function to provide a more professional service to communicate the range of work that the YHRMP
members. RMP delivers
• Agree and implementing corporate templates and Partnership • Establish ourselves in our new accommodation
quality standards for all meeting papers and Team • Provide all staff with the management support
materials circulated to members. they need to do their jobs effectively.
• Establish a schedule for the production and
circulation of meeting papers to provide members
with timely information to inform decision
making.

Communicate effectively
• Launch the new website, and establish it as a key
regional resource
• Develop a communications strategy
• Produce accessible information sheets which
form the basis of a briefing pack for elected
members and partners.
• Visit each member of SMG and PSG and other
LAs, to discuss the work and future direction of
the Partnership.
9. 2009-10 – OUR AIMS AND ANTICIPATED OUTCOMES

For 2009-10, we will focus our work on 4 key strands:

• Providing strategic leadership and co-ordination (the enabling role)
• Supporting effective integration of refugees
• Central Contract Management for Local Authority Asylum Seeker Accommodation
• Improving our research and intelligence

Detailed activity and milestones for these key strands are set out in the activity tables
included as Annex B.

10. OUR FINANCES

Yorkshire & Humber Regional Migration Partnership is funded from three main sources:
• We receive a grant from the UK Border Agency to support our strategic leadership role
and most of our research activities.
• We receive a central management fee to cover our work in delivering the
accommodation contract (this is a commercial contract)
• Our refugee integration work is supported by a contract with Yorkshire Forward, and
our work on Refugee Integration and Employment Service is funded by a contract with
the Home Office.

A more detailed financial breakdown of how we use our resource to deliver our enabling role
has been submitted to UKBA with this Business Plan.

11. CONCLUSION

This Business Plan represents a new way of working for the region. At its heart is a much
more integrated approach to migration issues reflecting the range of work that our regional
partnership is responsible for. As a strategic partnership, it makes sense for us to understand
our activities as a coherent whole, and to represent them to the wider region as a package.
This makes is clear where we are adding value to local delivery activity.

The business plan is also underpinned by an awareness that future ways of working are
currently evolving. The RMP in Yorkshire and Humber has always been regarded as a strong
and effective partnership with its roots in effective delivery of the accommodation contract.
Our track record, and our strong relationships with local government and other partners,
makes us well placed to develop future ways of working that build upon past successes. Key
to this will be a redefined and stronger relationship with UKBA – working in partnership with
the Agency to deliver our shared priorities for the region.

Finally, the business plan sets out for the first time, not just what we are going to do, but also
how we are going to work. This is important, not just for the staff team, but also for the
partnership activities themselves. If we are to be recognised as an important and influential
part of the wider regional arrangements then it is vital that officers can understand and
represent the work of the partnership in a professional and consistent way.
Annex A: The Shape of Our Structures

Regional Local
Delivery Authority Leaders UKBA Strategy
Local Authority Group

Public Sector RIES Contract Strategic Migration

Contract Group Board Group

Partners
SMG Subgroups
UKBA
• Refugee Integration
Group
10 Local 7 RIES Sub-
• Asylum Impacts Group
Authority contractors
• Migration Impacts
accommodation Group
providers • Migrant Health Interest
Group
• Employment and Skills
Group
• Children and Young
People Group

LOCAL AUTHORITIES

OTHER DELIVERY PARTNERS

MULTI-AGENCY GROUPS

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Annex B: Detailed Activities and Outcomes

I. Providing strategic leadership and co-ordination (the enabling role)

Process/Activity Outputs and PIs Outcome/Change on the Delivery by

Provide strategic leadership via
SMG and associated
structures
Establish robust political
structure for LA engagement in
migration issues
ground Whom
SMG to meet quarterly National and regional RMP Manager
Attendance to be over 75% decision making that reflects
the broader views of the
LA group to identify member region
representation from all LAs
in the region.
LA group to meet quarterly
with a 50% improvement in
elected member attendance

Provide a regional focus for
cross departmental
engagement in regional
migration issues.
Develop better
communication and
dissemination routes for
information through
Government Office
Broader ownership of RMP Manager
migration issues across a
range of policy areas.

Participate in the review of
enabling role and move to
implement outcomes of the
review
Business plan agreed by
UKBA
Participation in LGA
network relating to review
An effective structure for RMP Manager
future working that is widely
understood and reflects the
needs of the region
A Partnership recognised
nationally as strong and
effective

Represent the views of the Ensure consistent and National and regional RMP Manager
region to Government informed representation on decision making that reflects
the LGA Asylum and the broader views of the
Refugee Task Group region

Use SMG and associated

structures to provide a
regional structure for UKBA
to engage with in broader
discussions around delivery
of future contract delivery

Respond as appropriate to
Government consultation on
migration issues

Continued regional
participation in national
groups and networks – e.g.
National Migration Group,
Migration Impacts Forum
etc

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 Work with LAs and UKBA to Provide LAs with the
move forward the UASC information and support
reform programme. they need to make informed
decisions on participation in
the UASC reform
programme
Provide, if appropriate,
regional
response to UASC reform to
underpin the work of
individual local authorities
Monitor and manage the way Monitor the cluster numbers
that asylum seekers are against the agreed 1:300 Y
dispersed in the region. and H policy guideline,
identifying areas of
overpopulation and
adjusting numbers and
proportions
Support local partnership Work with localities to
arrangements which tangibly encourage and maintain the
support local delivery development of multi-
agency groups.
Attend at least one meeting
of each multi-agency group
in year
Provide accurate and
accessible tailored briefing
notes to each locality on
relevant issues – at least 4
annually
Key Risks for Strategic Enabling and Co-ordination role
Risk Risk Level
i. Weak member engagement in structures Medium
ii. Loss of confidence in structures during Low
transition to new working arrangements
iii. UKBA review of enabling role leads to Low/Medium
significant loss of budget
iv. Housing pressures mean that it is difficult Medium
to maintain the 1:300 cluster ratio
A coherent regional response RMP Manager
to the UASC agenda which
reflects and responds to the
needs of LAs
A clear and fair system to RMP Manager
minimize the impact on LAs
of dispersal and to ensure
numbers reflect the local
circumstances
Effective local delivery RMP Manager
underpinned by good quality
information
Mitigating Action
We will be working proactively with LAs
to clarify the benefits that participation
brings
We will aim to move to new
arrangements as quickly as practical
once the outcomes of the review of the
enabling grant are known
We will work to influence the current
review to ensure continuity. We will
also continue to try and diversify our
funding base.
We will work through the
accommodation contract to expand the
numbers of LAs involved in dispersal to
help build in flexibility.
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v. Lack of local support to develop multi- Medium We will make sure localities understand
agency structures the benefits to developing strong multi-
agency structures and help share
practice between different areas.

vi. Lack of central capacity within the RMP Medium/High Work with partners to try and secure
team to deliver local expectations of additional resource to provide more
support for multi-agency arrangements tailored support

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II. Supporting Effective Integration of Refugees
Process/Activity
Publish the final Refugee
Integration strategy
Implement the Refugee
Integration strategy
Develop RIES to deliver
effective services to refugees
across the region
Work with partners to help
ensure the region delivers an
effective resettlement
programme
Outputs and PIs
Strategy completed and
published
Conference to launch strategy
Strategy distributed to key
regional, local and national
partners and organisations
Action Plan agreed and
implemented
Role of RIG changed to oversee
implementation of strategy.
Quarterly reports on
implementation to RIG and
SMG
KPIs as defined by the contract
Service established and
partners engaged.
Information produced regularly
for partners
Ensure that all LAs are made
aware of the potential positive
benefits of participation in the
Gateway Protection Programme
Outcome/Change on the Delivery by
ground Whom
Improved strategic co- Refugee
ordination of refugee Integration
integration in the region. Manager
Greater awareness of
refugee integration
Improved information and
strategic direction
Clear refugee integration Refugee
responsibilities for Integration
organisations and strategic Manager
bodies.
Improved integration of
refugees and asylum
seekers in the region.
Improved integration of RIES
eligible refugees in the Manager
region.
Improved processes and
information for integrating
refugees.
More positive public
perceptions of refugees
Wider understanding of, RMP
and participation in, the Manager
regional resettlement
programme
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 Key Risks for Refugee Integration role
Risk
vii. Disengagement of key partners in integration
strategy
viii. Difficulties with implementation of Integration
Strategy Action Plan – leading to lack of real
change for refugees.
ix. RIES does not meet targets and KPIs
x. Resettlement programme fails to identify and
support new delivery partnerships in the
region.
Risk Level Mitigating Action
Low We will work closely with partners
through regular progress reporting,
access to strategic documents and
linking to wider regional objectives
Medium/high We will support partners in delivering
their actions and identifying potential
problems. We will review the strategy
taking into account organisational and
external factors which could affect
progress
Medium We will work with delivery partners to
identify potential difficulties and plan
solutions
Medium Individual decisions do rest with LA’s
but we will work with them and others
to ensure that decisions are informed
by best quality information.
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III – Central Management of the Local Authority Accommodation Contract

Process/Activity Outputs and PIs Outcome/Change on the Delivery by

Ensure the contract is delivered
and that we have the
necessary structures for
ongoing dialogue about the
contract to take place
Target Contract Compliance
meetings to take place
monthly
Contract Board meetings to
take place quarterly
Performance reports
produced monthly and
circulated to all LA deliverers
ground Whom
An effective and viable Contract
contract, delivering Manager
suitable accommodation to
asylum seekers in a way
that reflects the local
context and minimizes
local tensions.

All contract KPIs met.

Closer partnership working to Performance management Improved service delivery Contract

share good practice and reports produced monthly – to asylum seekers in our Manager
innovative approaches. used to identify effective ways region.
of working

Deliver against the standards

set out by the Home Office

Support effective local

delivery by hosting 2 away
days for local asylum
managers to identify and
share innovative approaches.

Participation in national
networks and structures to
identify best practice from
other regions and share with
deliverers in Yorkshire and
Humber

Explore capacity for additional
bed-spaces as and when
required by UKBA
Formal discussions with
cross-sector housing
providers (LAs and others)
who are not currently involved
in the contract.
Greater flexibility to deliver Contract
the contract and reduced Manager
pressure on those LAs that
are currently involved in
the accommodation
contract.

Preparation for future
renegotiation of contract with
UKBA post 2011.
Develop a project plan for Continuity of service for Contract
working towards contract UKBA and providers – Manager
renewal setting out the leading to better provision
processes that we will go for service users.
through and how and where
we will consult with and
engage providers.

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Key Risks for Contract Management Role
Risk
xi. Changes to contract bedspace numbers
might impact upon the financial viability of
the contract up to 2011onwards
xii. Home Office internal decisions fail to
recognize the wider impact on the YHPSG
capacity to fully deliver its obligations under
the Target Contract
xiii. Sustaining an acceptable level of contract
bedspaces for the Target Contract up to
2011 onwards
xiv. Potential conflict of interests with enabling
role
Risk Level Mitigating Action
Medium/High We will continue to use the review
mechanisms within the contract to
carry out active dialogue with UKBA to
ensure the contract remains viable
Medium/High We will actively encourage earlier
consultation through the Asylum Impact
Group that allows for better planning on
issues such Section 4/CRD reviews
Medium We will review various options available
to support any shortfall in bedspaces
required for the current contract
through active consultation with various
housing providers
Low We will have a clear separation of roles
– in terms of both governance and
operational delivery.
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IV Information, data and Research

Process/Activity Outputs and PIs Outcome/Change on the Delivery by

Share information on impact
and implications of asylum
dispersal in the region
ground Whom
Monthly updates on numbers and Better decision making Policy Officer
implications reflecting the needs of the
locality and region
Quarterly accessible policy
briefings produced for SMG,
placed on website and circulated
widely
Performance
Management information Management
produced monthly to support Officer
delivery of the target contract.

Ensure the region has the
information, data and research
to make sure the needs of all
migrant groups are met in long
term strategies.
Develop, and keep updated, Better decision making Policy Officer
regional web-based database of reflecting the needs of the
research about migration to locality and region
provide a comprehensive and
accessible resource for relevant
agencies and researchers.

Provide policy, statistical and
practice information to LAs
and other partners to enable
them to deliver more effective
services at local level.
Develop mechanisms to produce Better decision making Policy Officer
regular district level information on reflecting the needs of the
migration trends to LAs and other locality and region
partners.
Quarterly accessible policy
briefings produced for SMG,
placed on website and circulated
widely

Develop a LA policy officer Better practice – with

Launch the new website, and
establish it as a key regional
resource
network to share approaches and pooling and sharing of
information on monitoring impacts expertise.
of migration
Website launched and used to Information accessible to Information
share all information on all partners Manager
information, data and research

Key Risks for Information, data and research Role

Risk Risk Level Mitigating Action

xv. Lack of resource to carry out this role Medium/High Working with partners to secure additional
resource to carry out this work

xvi. Gaps or timelags in data undermine usefulness
of data
xvii. Policy changes or revision of UKBA published
statistics could reduce information available to
us and causes a gap in understanding
Medium Working with UKBA to develop ways to
strengthen existing data sets to improve
relevance
Low/medium Consider alternative means of collecting
data –e.g. new research or monitoring