Part 5: Customer service
5.1
In this Part, we discuss:
- the information available to applicants, licensees, and the public about the licensing process and the requirements of the Act;
- communication with licensees and alcohol industry representatives; and
- the time taken to process applications.
5.2
The Act specifies requirements to be met in applying for a liquor licence or manager’s certificate. We expected information about these statutory requirements to be readily accessible and easy to understand, licensing documentation to be easy to follow, and forms easy to fill out. At each DLA we looked at guidance brochures, checklists for applicants, information published on the website, and other material about the licensing process. We also looked at how DLA staff helped applicants to fill out licensing documentation.
5.3
We expected the applications to be processed within a reasonable period of time; delays in processing could cost businesses money, and job seekers might need a manager’s certificate to begin work. The application process brings a period of uncertainty until processing is complete. Timely processing is therefore an important dimension of good customer service.
5.4
We assessed whether each DLA’s licensing system was able to measure processing times, whether there were performance targets for processing licence applications, and if performance against those targets was reported to management. Where the necessary information was available, we assessed processing times ourselves.
5.5
A third important aspect of the customer service relationship is ongoing communication. This can encourage co-operation by licensees, and promote responsible practices consistent with the intent of the Act.
5.6
We also asked a sample of licensees for their views on the services provided by the territorial authorities we visited.
Main findings
5.7
Applicants, licensees, and the public had access to a range of information about the Act and the licensing system. However, the type and form of this information varied. Some DLAs’ promotional or guidance material was particularly useful. Standardising the content and format of information about the Act and the licensing system would give applicants and the public access to a consistent set of guidance.
5.8
DLAs offered a number of services to applicants, and were responsive to their needs. The positive findings from our assessment of customer service practices were confirmed by the responses from our survey of licensees. In our view, all DLAs should consider carrying out regular surveys of their licensees to assess satisfaction with their services.
5.9
Many DLAs communicate periodically with licensees, getting involved in training, convening licensee groups, or distributing newsletters. DLAs can use these activities to remind licensees of their obligations, obtain their commitment to responsible practices, and promote voluntary compliance. This training and education role is an important part of the work of inspectors.
5.10
Timely processing of applications is an important aspect of customer service. All DLAs had licensing information systems capable of measuring processing timeliness, but not all had targets or were reporting on the time taken to process applications.
Informing applicants, licensees, and the public
Guidance material
5.11
Well-informed applicants are more likely to meet statutory requirements and to have their applications dealt with promptly. This results in a more effective and efficient regulatory process for both the licensee and the DLA.
5.12
The legislation prescribes the information to be provided with an application and, for some types of licence application, requires the applicant to supply supporting documentation.1 DLA staff told us that applicants often made an error at some stage of the application process, causing delays and extra work for the applicant and staff.
5.13
In some territorial authorities, administrative staff or inspectors checked that applications were complete before they were accepted and processing began, and some used a checklist for counter staff . In some cases, staff met applicants in person to help them fill out their applications. This was helpful for applicants.
5.14
In one authority where applications were accepted without checks for completeness and accuracy, additional staff time was spent following up with applicants to correct errors or seek additional supporting documentation. Counter staff and customer service officers dealt with a wide range of inquiries from the public, and providing a checklist and some basic training about the requirements of the Act could make processing more efficient.
5.15
Providing detailed guidance is a simple and efficient way to help ensure that applications are complete and accurate. One way of doing this is to include with licensing documentation (while adhering to the format prescribed by the Regulations) explanations for the more complex requirements most likely to result in errors. The application forms used by one DLA were a good example of this approach, providing useful guidance for the applicant by explaining, in simple terms, the statutory requirements for public notices, compliance with fire evacuation schemes, and host responsibility practice.
5.16
There may also be potential for DLAs to make the application process more efficient by identifying the most common errors and amending their forms and guidance material to provide explanation where necessary.
5.17
Unless an application for a renewal is lodged before the expiry date, a liquor licence becomes invalid. Although licensees are responsible for applying to renew their licences in a timely way, most DLAs remind licensees when their licences are about to expire. This is an extra dimension of customer service.
5.18
Sending reminder letters in the format of renewal applications is a timely and convenient way to trigger the renewal process for licensees. The covering letter sent to the licensee or manager with the issued licence or certificate is another useful way to remind the licensee or manager of their obligations.
5.19
The Act requires applications to be publicly notified in local newspapers. Some DLAs prepare these public notices for the applicant. Errors in the wording or format of public notices may constitute breaches of the Act, and this extra customer service is seen as cost-effective by saving time for applicants in having to re-advertise.
5.20
Each DLA made a variety of information available to applicants and the public, consisting of brochures, checklists, or information published on the territorial authority’s website. Some DLAs had published their territorial authority’s alcohol policy, which was posted on the authority’s website, providing applicants and the public with guidance on hours of trading, host responsibility requirements, consideration of applications for special licences, district plan provisions, the DLA’s enforcement approach, and how to object to an application as a member of the public.
5.21
From some websites, applicants were able to download application forms, although none of the DLAs offered the opportunity for online applications. This option could be efficient and convenient, particularly for renewals.
5.22
For various reasons, each DLA can define its own set of requirements for applicants to meet when seeking a licence or certificate in its district. However, for the most part, applicants must meet a common set of statutory requirements. We therefore expected, as we carried out our visits, to find a standard set of information about the Act published in brochures or on each website, with consistent content and in a similar format.
5.23
Information about the Act differed in detail, coverage, emphasis, and format from one DLA to another. This meant that interested parties did not have access to consistent information about the Act, the regulatory process, and how it would be administered. We see benefits in all DLAs publishing a common set of information about the Act, in the interests of consistency.
5.24
Some DLAs had developed particularly useful material for applicants and the public, such as:
- descriptions of enforcement procedures;
- a detailed booklet for special licence applicants;
- guidance for the public on how to make an objection;
- answers to common questions about the licensing system; and
- a self-audit checklist for licensees that explained what the regulatory agencies were looking for when they carried out monitoring visits.
5.25
Guidance on how special applications will be considered is important information for licensees and the public. We are aware that approaches differ, but this type of material could usefully be included with the information disseminated by territorial authorities generally.
5.26
Sharing and standardising this information would result in more consistent and more comprehensive guidance on the requirements of the Act and how they will be administered. Including useful material developed by individual DLAs would produce a more relevant and helpful body of information throughout local government.
Training
5.27
The involvement of DLA staff in training licensees and managers can be a useful way to remind them of their responsibilities and what is expected of them. It can be a valuable means of promoting voluntary compliance.
5.28
Some useful training initiatives were in place. These included offering free training to licensees who belonged to accords,2 organising workshops, giving presentations at Licence Controller Qualification courses, and joining with the other regulatory agencies to train bar staff .
5.29
Involvement in training gives inspectors the opportunity to explain their expectations of licensees and duty managers, and this contact with staff who would shortly be working in licensed premises locally can form the basis for ongoing contact. Training is also one enforcement option available to the regulatory agencies in the event of identifying a breach of the Act or of licence conditions.
5.30
Given these benefits, we consider that training should be given appropriate recognition as one of an inspector’s core duties. As discussed earlier in this report, however, the limited time available for liquor licensing work may provide little scope for training opportunities to be taken.
Communication with licensees
5.31
Effective communication can help DLAs set out their expectations, promote licensees’ understanding of the statutory requirements, and encourage management practices that contribute to the responsible sale and supply of liquor. Opportunities include:
- periodic compliance visits to licensed premises;
- newsletters; and
- liquor liaison groups or licensee accords.
5.32
Periodic visits to licensed premises offer an important opportunity for inspectors to establish and maintain contact with licensees and their staff , remind them of their responsibilities, and check (and provide advice on) management practices. For example, such visits can be used to check the names of duty managers and remind the licensee of their obligation to notify the DLA of any changes.
5.33
As described to us, however, visits can often be short, and may consist simply of brief checks of compliance. As such, an opportunity can be lost to help promote responsible practice and offer advice and guidance. The approach by inspectors contrasted with that of public health services staff , whose visits were strongly focused on educating staff about good practice.
5.34
Publications are another way to communicate with licensees. Some DLAs issue newsletters, drawing breaches of the Act to the attention of licensees, and reminding them of their obligations. Media releases can be another useful way to reinforce messages about responsible drinking, about alcohol-related harm, and about penalties for offences such a serving minors. In some cases, inspectors had worked with licensees to develop voluntary guidelines for the responsible sale of liquor – such as “one-way door” policies,3 or protocols for large public events.
5.35
Some DLAs were using other opportunities to remind applicants of their obligations. One used the covering letter sent to the licensee or manager with the licence or certificate to draw attention to their responsibilities, while at another inspectors took forms for notification of managers with them on visits.
Timeliness of processing
5.36
All DLAs had licensing information systems capable of measuring and producing reports on the amount of time taken to process an application for a licence or manager’s certificate. Some measured and reported their performance in processing applications against targets (expressed as a number of working days). In a few cases, these targets were reflected in the performance agreements for inspectors or administrative staff . Targets were reasonable, with processing normally expected to be completed within a period of 6-8 weeks (allowing for inquiry and reporting from the Police and the Medical Officer of Health), although different DLAs had different targets. Some information systems also specified target timeframes for the completion of individual tasks associated with the licensing process.
5.37
Not all DLAs had timeliness targets or were measuring or reporting processing times. Inconsistent data was one difficulty faced in reliably calculating processing times for individual applications or trends over time. These calculations also need to take account of delays to the process that are outside the DLA’s control.
5.38
The processing of applications can be delayed for a number of reasons, and delays are common when the necessary documentation is missing. This makes it necessary to adjust the system to allow for interruptions to the process. Where possible, we measured timeliness ourselves from a selection of applications, and we had regard to delays outside the DLA’s control. In our view, DLAs were processing applications in a reasonable period of time.
5.39
Although many territorial authorities required a minimum period for processing applications for special licences, special licence applications could be submitted at short notice. Records we examined indicated that territorial authorities were responsive to these circumstances, and processed such applications promptly.
Licensee survey
5.40
For each of the 12 authorities we visited, we asked a sample of licensees to answer questions about the licensing process. We asked whether:
- the different responsibilities of the DLA, the Police, and the public health services were clear;
- it was easy to apply for a liquor licence;
- DLA staff were available and willing to help, and knowledgeable about the Act;
- they were told how long their application would take to be processed;
- they were happy with the time it took for a liquor licence or manager’s certificate to be issued; and
- they were consulted as necessary on any proposed changes to liquor licensing policies or practices that might affect their business.
5.41
We sent the questionnaire to 159 licensees, and 87 responded.
5.42
The generally positive responses confirmed the findings from our own examinations of customer service practices in the DLAs we visited. Analysis of the responses showed a general satisfaction with the information provided, licensing processes, the attitude and knowledge of staff , timeliness, and consultation.4
5.43
All DLAs would benefit from carrying out their own surveys of licensees. Only one was doing so. Its latest survey in 2006 asked about communication, satisfaction with services, information needs, accessibility, co-operation, fairness, and consistency. The results of that and previous surveys contained useful assurance and suggestions for improvement. In our view, seeking the views of licensees on the services provided should be a core component of every DLA’s customer service relationship.
1: For example, an application for a new on-licence must be accompanied by a plan of the building in which liquor will be sold, details of the business, a certificate of compliance with requirements of the Resource Management Act, and verification of compliance with the Building Code.
2: Accords are agreements that groups of licensees will work collaboratively towards common goals, which normally include a safer community with a reduction in alcohol-related harm.
3: "One-way door" policies are arrangements where licensees agree to close their doors to patrons after a specified time. The purpose is to prevent patrons from moving from one premise to another to continue their drinking, particularly in the early hours of the morning.
4: Comments from respondents sometimes related to the Act rather than to the practices of the DLA concerned. Respondents reported that the responsibilities of the three regulatory agencies were clear. Some noted difficulties in applying for a licence, with comments about the documentation required by the Act. Suggestions for improvement included clearer guidelines for processing applications for special licences, the opportunity to submit applications online, and more understanding staff .