Case Studies 1 – Work with Police Scotland
North Lanarkshire Council – Work with Police Scotland
Description of activity
Under section 84 of the Antisocial Behaviour (Scotland) Act 2004 (the Act) any landlord (or relevant person) falling within the scope of section 83 of the Act must be assessed as a 'fit and proper person' before being entered onto the landlord register.
North Lanarkshire Council ( NLC) wanted to establish a robust enforcement procedure to identify any landlord who fails to meet any of the criteria set out under Section 85 of the Act or any other material that comes to the attention of the local authority. The aim was to set up a process that would take account of all appropriate material whilst allowing the individual an opportunity to respond to any decision taken by the council.
NLC identified the need to incorporate a review panel and a mechanism to allow the dissemination of relevant information between all parties concerned. NLC also established an independent panel or committee to make the final decision on whether or not a landlord is a fit and proper person. This was to avoid bias, introduce impartiality and fairness in the decision making process.
How action was taken
The process was established following consultation with NLC Environmental Health Service and other council departments that have an input into private sector housing. This ensured every landlord applying or renewing their registration was assessed in terms of the 'fit and proper person' test and that other relevant services were able to check for any complaints or other information that may have a bearing on that landlord and their review status. Legal Services were also consulted to verify compliance with the 2004 Act and that the procedure was provided in a consistent manner.
NLC decided that a new two tier process should be introduced to deal effectively with landlords identified for review. A Fit and Proper Person Review Panel was set up to report any concerns or recommendations to North Lanarkshire Council's Corporate Services Licensing Sub-Committee. NLC considered that a balanced Fit and Proper Person Review Panel should include representation from a range of council services and external partner agencies.
Membership of the Panel included:
- Chairperson (Senior Environmental Health Manager)
- Housing & Social Work (Antisocial Behaviour Team Manager)
- Police Scotland (Local Authority Liaison Officer)
- Scottish Fire & Rescue Service (Local Authority Liaison Officer).
It was also recognised that the Panel would benefit from input from an advisory non-member, ideally someone in a position of authority who has a detailed knowledge of the landlord registration process and procedures within the Council. The Advisor's role is also administrative and includes furnishing the Panel with the relevant information arising from maintenance of the landlord register and the review list.
The Sub-Committee was set up exclusively to consider referrals from the Panel. It consists of two solicitors from North Lanarkshire Council's Legal Services, an elected member as Chairperson and several other elected members.
Upon receipt of a report from the Fit and Proper Person Review Panel, the Licensing Sub-Committee summon the relevant person or landlord to a hearing to account for any alleged misconduct as a fit and proper person.
NLC needed a robust and effective means of information exchange with Police Scotland. An intelligence mechanism was set up using the 'End of Day Reporting' (or EoDR) parameters on the landlord registration website.
Some landlords who fail to disclose relevant information which could affect their 'fit and proper person' status will have been approved. However, the legislation allows the local authorities to review that registration at any time where any material information subsequently emerges. Police Scotland intimated that there would be certain offences that would not be passed to the Fit and Proper Person Review Panel e.g. traffic or speeding offences etc. with identification for further scrutiny at their discretion.
NLC have measured the success of this approach by means of statistical reporting to the Scottish Government and validation through internal audit, utilising the service computer database. The process has attracted extremely positive comments and recognition from Police Scotland.
The key objectives were to:
- Ensure that all registered landlords (or relevant persons) are assessed using the 'fit and proper person' test criteria;
- Provide a structure and a process which enables continuous review and assessment of landlord (or relevant person) conduct;
- Remove any unfit landlord (or relevant person) from the landlord register, where required;
- Take enforcement action when any landlord (or relevant person) fails to comply with a Repairing Standard Enforcement Order.
In practice, the process needed to evolve to remain viable. Initially the EoDR list was passed through to the local intelligence unit at Police Scotland on a two weekly basis. Due to the demand on resources within the Police Scotland, there was a risk of this service being withdrawn. However, Police Scotland's representative on the FPPRP arranged for the EoDR list to be sent to another unit thus preserving continuity.
NLC also experienced some issues recording information accurately and deciding where this information was best held. To keep accurate records and prevent data loss, landlord details are now recorded on a review list as well as their own computer database.
The main consideration for NLC when devising this process was to agree an information sharing protocol with Police Scotland and to provide sufficient administration resources to cope effectively with Police checks at the outset.
This may be challenging for local authorities with large numbers of landlords. However, the procedure can still be utilised by checking a percentage or a random sample of the EoDR list each time it is generated and sent to Police Scotland. Implementing a process of continual review from the outset encourages consistency and compliance with central government policy. Any legislative changes to the 'fit and proper person' test require to be incorporated into the process, again to ensure consistency and to ensure all relevant material is considered.
In North Lanarkshire, there were a total of 226 separate referrals to the FPPRP during January 2013 to January 2016.
From this figure, 31 landlords were identified for further review with a recommendation that they be removed from the register. These landlords were referred to the Licensing Sub-Committee with the following outcome.
- 12 landlords were struck from the Register.
- 1 report was not accepted by the Committee.
- 9 cases were upheld and approved by the Committee.
- 3 landlords agreed to remove themselves from the Register without the need for formalities.
- 2 landlords failed to appear before the Committee and were being pursued.
- 4 other cases were pending, awaiting deliberation by the Legal Services team.
There are costs associated with providing an effective landlord registration scheme and its associated fit and proper person process. Locally these costs are absorbed internally amongst the participant services but in common with most funding sources, may be subject to review.
An algorithm depicting the potential inter-relationship of the FPPRP, Licensing Sub-Committee and Police Scotland and how the shared information process flow operates can be made available if this is helpful.
East Ayrshire Council
East Ayrshire Council has established a protocol with Police Scotland whereby the police will verify any convictions declared by a landlord or agent. The council are in regular contact with the police, and an officer sits on the enforcement group along with a Private Sector Liaison Officer, Private Sector Assistant, solicitor, and Antisocial Behaviour Officer. Meetings are held every 4-6 weeks to discuss landlords who have caused concern. The targeted scrutiny has resulted in 9 landlords/companies with criminal convictions being de-registered. Three linked companies were also de-registered and the police are pursuing prosecutions.
Dundee City Council
Dundee City Council has been working with Police Scotland to develop an Information Sharing Protocol ( ISP) to cover landlord registration, HMO Licensing and Antisocial Behaviour. This builds on a previous Antisocial Behaviour based ISP with Tayside Police. A Joint Officer Review group has been established with members from various departments within the council, Police Scotland and Scottish Fire and Rescue Services. A weekly list of new applicants and those reregistering is circulated to the group offering an opportunity for representations and comments to be made on any applications that cause concern.
Angus Council has established a protocol with Police Scotland whereby the Police will verify any convictions declared by the landlord or agent.
Moray Council's link to Police Scotland is now an invaluable part of the fit and proper person test. It helps provide clarity about convictions that would otherwise have been unknown. For example, landlords who only partially declare convictions, give vague details of the type of conviction as well as not declaring convictions at all, despite signing the declaration on the application form. The process allows for a much more robust test which significantly improves the quality of landlords in the sector.
Case studies 2 - Requesting additional information
East Ayrshire Council takes the view that in terms of the 'fit and proper' criteria there is a basis for requesting supporting documentation. Section 85 of the 2004 Act includes reference to whether the applicant has contravened any provision of the law relating to housing and also any other material relevant to the question of whether the person is fit and proper. The Council operates a proactive process to obtain information from tenants regarding management of their tenancy. Tenant questionnaires are issued to a selected number of tenants on a regular basis. If information is returned which suggests the landlord may not be complying with their legal requirements the case is reviewed and documentation requested.
Angus Council requests gas safety and electrical certificates as evidence to ensure they meet requirements, where they receive a complaint from a tenant.
East Lothian Council requests a range of additional documentation when a problem occurs or a complaint is received. This includes gas/electrical safety certificates; Energy Performance Certificate; Legionella Risk Assessment; AT5/tenancy agreement/inventory for the tenancy; proof that the tenancy deposit is protected; proof that they have permission from any lender to let the house; and that repairing standard duties have been met.
Case studies 3 - Provision of Advice and Assistance
Private Landlord Support Officer, Dundee
Overview of project
Shelter Scotland, with funding from the Oak Foundation, is currently undertaking a programme of work over the period 2015-19 to promote higher standards in the private rented sector in both the Dundee and Highland areas. This case study sets out Shelter Scotland's experience in the Dundee city area.
The focus for the Dundee project is on working with and supporting private landlords to meet their legislative requirements and enhance their practice. Shelter Scotland acts as the host for the project working in partnership with Dundee City Council and builds on the existing strong links between the local authority and the private rented sector, with the Private Landlord Support Officer ( PLSO) being based within the Private Sector Services Unit of Dundee City Council.
The partnership between Shelter Scotland and Dundee City Council has enabled an innovative approach to raise standards across Dundee's private rented sector which pulls on the strengths of both organisations. The PLSO sits alongside both the enforcement and landlord registration teams, as well as other key colleagues such as Dundee Homefinders and Dundee Landlord Accreditation. This ensures that knowledge and best practice are shared effectively. No additional powers have been necessary to enhance the success of the project.
The PLSO has, amongst other things, developed landlord checklists which take landlords through the legislative requirements which apply to them as well as best practice. The initial checklist is sent out to landlords with all landlord registration approval letters and is advertised in quarterly newsletters and seminars for private landlords operating in the Dundee City Council area. The most popular queries to date have related to the landlord checklists, one-to-one support work, energy efficiency advice, common repairs and repairing standard, repossession paperwork and health and safety requirements.
The service has shown to be popular with 'accidental' landlords who are unsure of the legislative obligations and lack confidence, with a small portfolio size.
The quarterly newsletter which goes out to approximately 13,000 landlords and interested parties and seminars which are attended by on average 115 landlords on a quarterly basis remain a main source of referrals. The project is also diversifying referrals routes, for example by proactively contacting landlords who advertise property for rent informally online.
The service offered by a Private Landlord Support Officer
- One off advice – thistends to be bite size information on a specific topic. This is classed as low level support.
- One to one work – thisinvolves working with the landlord over a longer period of time, particularly in the case of new or inexperienced landlords. This is classed as medium level support.
- A development plan – thisinvolves the PLSO meeting with a landlord who has shown to have a gap in knowledge in one, or several areas. They will work through a development plan which monitors their progress through the course of the intervention. This is classed as enhanced support.
Tenancy sustainment - One of the more unanticipated consequences of the project has been the opportunity to work with private tenants and their landlords to try and help sustain tenancies.
Informal advertising - Private landlords in Scotland are now required to state both their landlord registration number and the rental property's energy performance certificate when advertising properties for rent. However, it is still commonplace for these details to be omitted from property to let adverts. Failure to provide this basic information can often be an indicator that the potential landlord is also failing to meet their legal obligations in other respects. Many 'accidental' landlords who have unintentionally failed to comply with the law will often seek on-going guidance and support from the PLSO due to this intervention.
Educating private tenants - The PLSO has in conjunction with 'Dundee Homefinders' created a simple tenant checklist in leaflet form for tenants to take to viewings. Tenants can note any concerns which will automatically be routed to the PLSO who will then make initial contact with the landlord, bring the issues to their attention and seek to work with them for resolution.
Key relationships have been developed with:
- Dundee Homefinders – The PLSO works closely with the local deposit guarantee scheme 'Dundee Homefinders', meeting with all their new landlords and also referring landlords to them where applicable.
- Home Energy Scotland – The PLSO is in frequent contact with the local Landlord Advisor in order to make landlords aware of the potential for energy efficiency upgrades in their properties, and how detrimental fuel poverty can be on their tenant's wellbeing and financial capability.
- Dundee City Council Housing Support Team - The PLSO refers vulnerable clients to the service, with the aim of this intervention to improve tenancy sustainment in the PRS – ultimately ensuring the success of new tenancies and saving existing tenancies. This is a good opportunity to have a presence in properties housing vulnerable private rented sector tenants.
In the first year of operation the Dundee project has taken on over 300 landlord cases and the Highland project over 200 cases. Feedback from landlords on the service provided has been very positive:
"My questions were answered clearly and I feel it's reassuring to know that in case of problems there are qualified people on hand for support. We are really most grateful for this, thank you."
"I had been attending the landlord seminars and was introduced to Laura, the Private Landlord Support Officer. I took her up on her offer of help and I could not be more thankful for her support. All my queries were answered and she explained the technicalities for me too. I would strongly advise any landlord that has issues to contact Laura."
Costs or cost savings that arose from the project
It is important to note that the work of the PLSOs in both Highland and Dundee are both additional externally funded resources dedicated solely to improving practice among landlords in both areas. Crucially, dealing with issues relating to landlord compliance prior to the enforcement stage frees up the local authority's time and resources to offer tougher and more targeted enforcement.
Adding value brought to private rented sector properties through utilising services through organisations such as Home Energy Scotland takes a holistic approach and can help reduce fuel poverty and related costs.
Tenancy failure places large direct costs on local authorities. By reducing homelessness where possible the project has significant scope for making financial savings to local authorities.
Ways that good practice can be shared.
The existing modes of communication with landlords in Dundee such as the seminars and newsletters enabled the PLSO to hit the ground running and build upon the already strong links between the local authority and private landlords and agents across the city.
The project is currently a pilot project until March 2018.
The useful range of tools and FAQs developed by the PLSO are available on the Dundee City Council website.
South Ayrshire Council
South Ayrshire Council is also in the process of developing a post under a similar model to that used by Dundee City with the Shelter project. They see the importance of having an officer who is able to liaise with landlords at the onset of application. Many of the landlords in South Ayrshire operate 1 or 2 properties and may be unaware of the full range of regulation and legislation which they require to comply with. The aim is to fund this role through a support provider to look at a range of issues such as:
- Compliance with registration process and assisting to ensure properties meet relevant standards
- To source and find those landlords who may be unregistered in the area and support them through registration process
- To work closely with our Housing Options team with a goal of reducing the number of homeless presentations from the private sector
- To look at ways to support tenants who may be at risk of losing their accommodation
- To be able to signpost landlords and tenants to any relevant service that they may require.
South Lanarkshire Council
South Lanarkshire Council run forum meetings for landlords twice a year, covering a range of topics including, legislative updates, guest speakers as well as an opportunity for landlords to discuss issues with specialists/professionals dealing with the private rented market. Average attendance is 70 private landlords. These are supported by the issue of a twice yearly private landlord newsletter, distributed at the forums and made available at the Council's website.
The partnership arrangement with Landlord Accreditation Scotland ( LAS) ensures promotion of best practice. As at 31 March 2016, there were 1,068 accredited properties within the area.
In addition, SLC routinely facilitate landlord training, delivered by LAS. Two training sessions are offered as an incentive - the council pays for the first session attended. Courses are run in the afternoons and evenings, with a maximum of 30 landlords in each class. This creates a greater opportunity for maximising landlord attendance and ensures that any individual training needs are addressed.
Aberdeenshire Council produce leaflets for tenants and landlords detailing their rights and responsibilities. The leaflet is provided to every landlord who submits an application for a new registration and renewal. This is also emailed via bulk email. The tenant leaflet is posted out to every PRS property registered in Aberdeenshire and is distributed to libraries, public building, CAB and Council Offices. This is done every time the leaflet is updated. Both leaflets are updated every 1-2 years.
Case studies 4 – Action Plans
East Ayrshire Council
East Ayrshire Council has been using action plans since 2007. They have been very effective and have resulted in garden problems being dealt with and repairs being undertaken. If the property is managed by an agent and if the issue is not resolved the landlord is asked in for interview. This can be escalated to the Scrutiny Panel if required.
Fife Council encourages private landlords, who have been identified as poor performers regarding aspects of their rental practices, to undertake Landlord Accreditation Scotland ( LAS) Core Standard Training, as part of a Landlord Action Plan. The Landlord Action Plans are reviewed every six months at a meeting with the landlord.
Case studies 5 – Identifying unregistered landlords
Dundee City Council
At Dundee City Council, Enforcement Officers work within HMO Licensing and landlord registration, dealing with tenant complaints, identifying unregistered properties and liaising with other departments and services including Police Scotland and Scottish Fire and Rescue Services. Colleagues dealing with homelessness, the Housing Options Service and Housing Benefit all cross reference private rented cases with the landlord register. Unregistered landlords are also identified by checking the monthly data provided by the tenancy deposit schemes, properties that have been found as being below the tolerable standard and revenue/benefits enquiries all of which are received via the landlord registration email address.
East Ayrshire Council has enhanced cross service awareness by issuing all their Council staff with an electronic version of their newsletter. They also undertake random checks of advertised properties for registration numbers and Energy Performance Certificate information.
East Lothian Council
Where East Lothian Council identify unregistered lets the details are passed to landlord registration for action to be taken. The Council are also signed up to many of the online property portals and websites, which will email out newly advertised properties on a regular basis. This then allows for registration numbers to be validated, EPC ratings checked and unregistered landlords identified. Tenancy deposit scheme information is also checked to identify unregistered landlords.
Fife Council carries out random checks via letting web sites, in-store adverts and local newspapers to identify unregistered landlords.
Midlothian Council landlord registration team are supported by a Housing Investigation Officer within the Environmental Health – Public Health team. Their remit is to deal with complaints regarding private rented properties, provide advice about landlord registration and landlords' duties, chase up late registrations, identify unregistered lets and liaise with colleagues in other council departments including Council Tax, Housing Benefits, Homelessness and work with letting agents operating within the Midlothian area. Through this work, Midlothian Council has identified and secured the registration of a considerable number of unregistered rented properties. They also make contact with landlords where the registration has expired and visit, if necessary, to identify whether the property is still being let and requires being re-registered.
Renfrewshire Council has employed an additional enforcement officer to identify unregistered landlords, linked to its Tackling Poverty Initiative. The officer has established information sharing systems with Council Tax colleagues as well Scottish Fire and Rescue and Health and Social Care officers (through the Council's Community Safety Partnership Hub). The officer also looks at the Land Register and advertisements to let properties in the press and internet to find unregistered landlords. Letting agencies have been challenged where registration numbers have not been included in advertisements.
The role of the enforcement officer also includes helping Environmental Health Officers make third party applications to the FTT, and includes undertaking inspections to determine compliance with the repairing standard, and liaising with tenants during the process. The information obtained by the enforcement officer informs decisions to issue Rent Penalty Notices or take other enforcement action.
Case study 6 – Disqualification Order
Fife Council (Private Rented Sector Team – Housing Service)
Mr M first made application for landlord registration in March 2008. There were several tenancy management and housing condition issues and his registration was placed under review. It was not until July 2010 that the landlord was removed from the review list, due to no further complaints and thus approved.
The registration was put back on to the review list in March 2012, again for tenancy management and housing condition issues, particularly in relation to the lack of Gas Safety Certificates ( GSC). Several attempts were made to meet with the landlord, who refused to engage. Tenancy management and housing issues continued, and requests for GSCs (both current and historic), were ignored.
The landlord registration expired in July 2013, and the landlord failed to renew. The decision was taken to try again to call him in for meeting. The landlord eventually agreed to attend a meeting in December 2013. He failed to bring all copies of GSCs with him as requested, but he did provide a renewal application for his landlord registration.
Due to the many attempts to obtain GSCs, and the landlord's failure to engage, it was decided that the only course of action left, was to prepare a case for submission to the Procurator Fiscal ( PF). In the meantime, it was decided that Mr M had failed the fit and proper person test, and in June 2015 his landlord registration renewal was refused. Mr M was notified of this in writing, advising him that he had a right of appeal. There was no response from the landlord. Subsequently his tenants were also notified of this decision in August 2015 encouraging them to seek housing advice.
Evidence used to build the case for disqualification
Copies of GSC were eventually received, but these were all current, and no historical certificates were handed in. This suggested that these had been done recently, and had never been in place before.
Witness statements from his tenants, confirmed that they still lived in the rental properties, and continued to pay rent, despite the landlord not being registered. Statements were also received from the Night Time Noise Team ( NTNT) confirming that anti-social behaviour was on-going at one of the properties.
Council tax checks and Registers of Scotland checks confirmed that the landlord still owned all 3 properties, and that they were all tenanted throughout.
The work to bring about the successful disqualification involved working in partnership both within and outside Fife Council. This collaborative working is summarised below.
Police Scotland – Intelligence and information relating to links to other landlords and practices.
Protective Services Technical Officers – visits, technical advice and compliance.
Night Time Noise Team – visits for noise complaints.
Procurator Fiscal office – advice and guidance.
Constraints of support and advice from other pertinent services, being provided in a timely manner – to allow the PRST to move the case forward efficiently. It was time consuming gathering all required evidence and making sure that all evidence was suitable for the PF and fitted in with relevant charges to take the case forward.
The process is currently resource intensive and can be deemed quite complex. This is currently being reviewed, locally.
Powers used and outcomes achieved
Mr M's case first went to court in November 2014 and he was charged under section 93 (1) of the Antisocial behaviour etc. (Scotland) Act 2004 (a separate charge for each of the 3 properties) and under section 36(3) (c) the Gas Safety (Installation and Use) Regulations 1998 (a separate charge for each of the 3 properties), making a total of 6 charges in all. He was found guilty and fined a total of £540.
However, the landlord continued to rent out all 3 of his properties, despite not being registered. Tenancy management issues were still on-going, and many instances of anti-social behaviour from some of his tenants. Fife Council therefore made the decision to return to court, in October 2016 and ask for a Disqualification Order.
The case went to court in April 2017, after being deferred from a February 2017 hearing date. On this occasion the landlord was fined £500 and a Disqualification Order for a period of 12 months was granted. This is the first Order of its kind in Scotland.
The PRST has held a multi-agency follow up / review meeting to consider all next best actions on how the Disqualification Order can be policed.
Consideration is being given by Fife Council Housing Service that the tenants will be eligible to present as unintentionally homeless, albeit additional priority points will not be awarded.
Fife Council Technical Officers will visit all three of the landlord's properties to assess if tenanted and the condition of the properties
The local PF office has provided a written input explaining that there is no specific offence of acting in breach of a disqualification order, rather continuing to act as a disqualified (unregistered) landlord will be reportable to the PF as a breach of section 93 of the 2004 Act. The Standard Prosecution Report template has been further amended to address the specific offences in section 93 of the Antisocial Behaviour etc. (Scotland) Act 2004 and the local PF Deputy has offered to attend and provide a presentation on reporting to them.
Further multi-agency review meetings will be held, involving PRST, Protective Services (Technical Officers), Police Scotland, Legal Services, Procurator Fiscal's office, HM Revenue and Customs and any other relevant partners with a professional interest.
Case study 7 – Enhanced Enforcement Areas
Glasgow City Council
The EEA designation applies for a period of 5 years and provides Glasgow City Council ( GCC) with a number of enhanced powers in the area, including:
- to require a relevant person to provide the local authority with an enhanced criminal record certificate;
- to request that documents be produced for inspection (such as a current insurance policy, gas safety certificate etc.); and
- the right to inspect a property.
In order to achieve EEA status, GCC has worked with a range of local partners to develop a strong evidence base which supported the need for such additional powers. Evidence submitted to Scottish Ministers documented that the area concerned suffered from a high concentration of private rented housing, that it was of a poor environmental standard, suffered from overcrowding and a prevalence of antisocial behaviour.
Since receiving EEA status in Govanhill, GCC have used the additional powers to request that all landlords within the designated area produce documentation for inspection. Over 90% of landlords have responded to the request, with many obtaining their first gas or electrical safety certificates as a result of the additional powers and therefore helping to drive up safety standards in the area.
A private landlord forum has been established within the EEA, where GCC officials are able to engage with landlords on a range of issues and build relationships in order to work towards solutions. As part of this work, GCC has seen a sharp increase in the number of private landlords within Govanhill who are undertaking landlord accreditation – again helping to improve overall property and management standards in the area.
A report on progress being made within the Govanhill EEA will be submitted by GCC, to Scottish Ministers.
Specific case study
A landlord who owns and lets one property within the EEA was written to on the 12 and 30 August 2016 requesting certification and a disclosure Scotland check as provided for in the EEA agreement. He failed to meet the terms of these requests.
In addition to this, the property was inspected as part of the EEA and on 03 August 2016 a closing order was issued in respect of this property being below tolerable standard as the electrical installations were not deemed safe and in good working order.
The tenants have been found alternative accommodation though liaison with other agencies including homelessness services. The house has now been closed and secured.
The landlord was referred to the Licensing and Regulatory Committee on 23rd November 2016 to consider his suitability to continue to be a registered landlord.
A total of 9 landlords (6 – Govanhill) had their registration refused or revoked at that Licensing and Regulatory Committee meeting on 23rd November, this includes in relation to the landlord and property mentioned above.
As the owner can no longer act as a landlord, and has failed to engage regarding their future intentions, it is anticipated that a Compulsory Purchase Order will be pursued.
Email: Gary Mitchell, Gary.firstname.lastname@example.org
Phone: 0300 244 4000 – Central Enquiry Unit
The Scottish Government
St Andrew's House