Ms Rosalind Carroll:

Deputy Eoin Ó Broin spoke about supporting most of the provisions included in the legislation and asked if there was any element about which we were a little nervous. We have set out the issues of concern in our submission. The main piece is that while we believe the legislation tries to get us to a path towards rent transparency, there is probably a little more we would do in that respect. One of the things missing from the Bill is annual registration. In the context of Deputy Pat Casey's question about investigations, the easiest way we can investigate is by having data in the first instance. We need a smart IT system to do a lot of the work for us. If we had data coming in on annual basis, we could use software to determine what rent increases were above 4%, what properties were exempt and so on, but in the absence of such a system, we will have to undertake a lot of manual work. While I understand the Bill is a pathway towards rent transparency, there are some weaknesses within it.

On the issue of simplicity, under head No. 5, one of the suggestions is landlords should be obliged to tell us about any change to a tenancy as it occurs. Failure to do so would be a criminal offence, but in terms of enforcement, that would not be very practical. How would we know whether a landlord had told us or not? How would we go about investigating it? Furthermore, in terms of proportionality, criminal sanctions for a landlord who forgets to tell us about a rent review might be too much. While landlords have obligations and need to be aware of them, the law has become so complicated that we need to be careful about keeping a streamlined approach. These are the two areas in which we have some concerns. While we support and agree with the vast majority of the Bill's provisions, we believe these two areas need to be considered further as the legislation is drafted, particularly in terms of implementation. We must ask how we can implement these provisions while keeping things simple. These are the two points I will repeat as we go through this legislation.

In terms of resources, we have sanction for 61 staff. We have 53.8 whole-time equivalent, which means that we have eight vacancies. As quickly as the Department gives us sanction, within the current economic space it is actually quite difficult for us to retain staff. It is primarily related to broader issues, including the fact that we are public servants and staff do not have access to wider competitions and so forth. Candidates will work in the Civil Service before they will come to work for an organisation such as the Residential Tenancies Board. Furthermore, ours is a small organisation, with only one person working in human resources. We have just gone to tender for a recruitment agency in order that we will be able to respond as vacancies arise or we receive sanction. We are holding people for too long. It is quite a big, open procurement process and the tender is valued at well over €25,000. It will, therefore, take us some time to go through it.

Members have probably heard a lot of talk about a two-year change management plan. Deputy Eoin Ó Broin asked if it had been discussed with the Department and the Minister. We have discussed it with them and the change management group has met on a number of occasions. Our main focus is on ensuring we will not do anything on the back of an envelope. We need to make sure we will get this right. The Residential Tenancies Board has started from a place where it had a really bad reputation because it was badly resourced in the first instance. We have done a lot of work to try to improve processing times. We do not want the standard of provision of our core services to drop as we take on new functions. We are, therefore, trying hard to get the balance right. In that context, we have commissioned an external workforce plan which will take account of this new piece. In that way, a body external to us will determine what we will require to do our job properly. The contract was initiated yesterday and the plan will be completed in a two-month period. The aim is to draw up the plan properly in order that it will cover not only this piece but also what the Residential Tenancies Board will require in the next few years. I cannot say what resources will be required because the issue needs to be examined properly against the backdrop of the 340,000 tenants in the system. The introduction of the GDPR, for example, has had a massive impact on our organisation because while we hold over 1 million records, we only have 60 members of staff. It is a real challenge for us. We are looking at all of these issues, including the compliance requirements for all organisations, as well as the new functions we have taken on.

It is difficult to provide a figure for the average number of cases per staff member. I have just said we have 53.8 staff members, but a large amount of our work is done through outsourcing. Our staff numbers were reduced dramatically, from 70 to 35, in 2013. As a result, we outsourced a large amount of the work. All of the front-line work is done in a customer care centre, including the handling of all calls, as well as some of the case assessment, document management and general correspondence work. Approximately 50 people are working on the contract within the call centre. We have another 74 panel members who are independent decision-makers. In order to maintain their independence, they are not employed directly by the Residential Tenancies Board, but they have a service level agreement with us. Overall, approximately 200 people are working for the organisation.

To break that down per case would be difficult because-----