Councils are responsible for issuing more than 150 licences, consents, permits and registrations that grant formal or official permission to do something. These cover a diverse range of trades and activities, of which the best known are probably those that permit the sale of alcohol. Last year, we looked at the licensing of food businesses, and this year’s topic is ‘temporary event notices’ or TENs as they are commonly known. One key aspect of TENs is that they may be needed by ordinary citizens organising one-off community events, like street parties. Consequently, the responsibilities associated with holding a TEN, and the process required to get one, needs to be set out in terms accessible to the non-expert.
Shire districts, Northern Ireland districts and Welsh unitary councils
48% of councils tested provide a good or very good service for this task. Councils have a range of options for both presenting information about TENs and enabling the application process. There is good information on GOV.UK as well as an application option, although not one that strictly speaking can be described as ‘online’. Councils can also use templates and forms provided under the EU Point of Single Contact (PSC) directive that aims to open up Europe's services sector to cross-border competition. The EUGO service is now run by GOV.UK and businesses can follow that route to find information and apply online for this particular licence. Sometimes more than one of these options are used on a site, which has potential for confusion.
Check ‘coverage’ to see if your council has been surveyed. Go to councils page and select your council. Look for link to task report under 2017-18 results
Provide a good or very good online service based on this survey
Better connected rankings
*Discrepancies in the figures are due to rounding off
Councils are responsible for issuing more than 150 licences, consents, permits and registrations that give permission for different businesses and activities. The best known of these are typically those that permit the sale of alcohol.
Temporary Event Notices come under the Licensing Act 2003. They can be used to authorise relatively small-scale, ad-hoc events involving less than 500 people at any one time, involving sale or supply of alcohol; provision of ‘regulated entertainment’ including performances, plays or dances, live or recorded music, or a sporting event; and the sale of hot food or drink between 11pm and 5am.
One key consideration for councils presenting information about TENs is that applicants may be ordinary citizens organising one-off community events like street parties or an end-of-season football club barbecue. Consequently, the responsibilities associated with holding a TEN, and the process required to get one, needs to be set out in terms accessible to the non-expert. Some councils have clearly taken a step back and put themselves in the position of a first-time applicant.
As with many of our tasks, there is a fine balance between something that is over-complicated and something that has been over-simplified to the extent that the information becomes misleading. One council’s very brief TEN page states: ‘If you are planning an event, which includes alcohol, late-night refreshment or entertainment, you need a temporary event notice (TEN).’
This is adequate when used as an introduction to more detailed information, but can be misleading on its own given an event that includes free alcohol would not need a TEN unless other factors also apply. In another case, a site seemed to suggest that TENs were required for children’s parties if they included music and dancing.
Reviewers found several instances where it seemed likely that the service description was written by a licensing specialist, unaware that plain English helps avoid misunderstandings and unnecessary contact with council staff to seek clarity.
For example, many councils use the term 'tacit consent'. As this is not plain English, there is a danger that both heading and content will be overlooked if people do not understand the phrase. Many councils also referred to themselves in the third person (e.g. ‘you must apply to the licensing/local authority’), which is confusing in the majority of cases when that council is in fact the licensing authority - it may give the impression that are not.
Too many sites lifted content from legislation, rendering it almost incomprehensible as it was dominated by legalese. Another tendency was providing too much detail upfront about the different Acts and how they applied to different types of music, amplification and so on. This dilutes important, universal information involving costs, and notice periods, as well as slowing down task completion. Universal information should come first, followed by any content that is segmented for different audiences.
Many councils buried content in the impenetrable official guidance notes – typically read by very few people.. Salient content should be lifted from the notes, edited into plain English and incorporated as core web content. Other sites often linked to a 'summary' of the legislation, which always transpired to be the legislation in full. Again, this is impenetrable for most people.
Many councils use the EUGO template to give information on TENs. This practice is the result of the UK’s implementation of an EU services directive to harmonise the process of business licence applications across the EU – originally managed by the Department of Business and now by GOV.UK.
Use of the EUGO template is easily recognised by its non-plain English for example, ‘Does tacit consent apply’ and ‘Failed application redress’. Its adoption can be a mixed blessing. Councils presenting information in EUGO format were usually more comprehensive, making it easier to find answers to our questions, but for site users, a EUGO logo is no guarantee of quality – there were instances of fairly basic information being missed out, and the language used is not always customer-friendly.
Across all sites, information was often not provided about grounds for refusal of an application (only 40% of sites) or the penalties that may apply if a licensable activity goes ahead without permission (just 18%). Including this kind of information in the declaration at the end of the application process is ineffective.
Signposting sometimes proved troublesome. Homepages often feature a section called ‘Events’ or with ‘Events’ in the title – for example, Eden has a section called ‘Leisure, Culture and Events’. Whilst the majority of sites only list council-run or other public events here, Eden’s website is a good example of one which covers the breadth of this topic. Including a section on event organisation, it covers not only TENs, but also information on topics like events on council land, large-scale public events, street parties, firework displays and risk assessments.
Several sites only list TENs in the ‘business’ area of the website, requiring users to click this heading before they can see the topic of ‘licensing’ listed. This might seem the most logical place to put all licensing applications, but a quick glance at licensing registers for TENs shows they apply more to charity and school fund-raising events, rather than business applications.
Some sites tackle this by calling their business section ‘Business & licensing’, whereas others have explicit lists of common tasks or services under main headings on home and landing pages.
Ultimately, it’s important to clearly signpost from all the logical places people might look for this sort of information, as well as cross promoting other related content to make it easier for site visitors to find the information they need. Thinking across departmental silos may not come naturally to service managers, but it is essential that web managers reinforce the importance of doing this to their colleagues.
When a task has a name that is not in common usage – such as ‘Temporary Event Notice’ – web managers also need to be clear with page descriptions in their metadata. Many people are unlikely to know that they need a ‘temporary event notice’, so when this title appears in search results the page description needs to help them understand its relevance.
Very few councils (16%) had an online form for applying for a TEN, with most pointing to the GOV.UK process, often labelling this as an ‘online application’ in the same way GOV.UK does. In fact, what is provided is a responsive PDF that can be re-uploaded to GOV.UK for forwarding off to the relevant council. In these instances, sites have been marked as not having an online form.
Whilst the GOV.UK process is better for applicants compared to one that involves posting a downloaded form, it is not an online form in the true sense as councils still need to re-enter the data captured once it lands in their systems. It should also be noted that the GOV.UK process requires users to install the latest version of Acrobat, and is a little clunky given the council’s own payment system needs to be used for that part of the process.
Clearly, councils need to have a business case for creating an online facility for these applications, and in most cases there may be none, given that the GOV.UK facility does work. On this basis – and in line with the way online forms have been treated in other tasks – not having one for the TEN application is not a barrier to getting four stars, as long as the rest of the experience justifies it.
A wider and more interesting question to consider is the extent to which there should be greater collaboration between the Government Digital Service (GDS) and local authority digital teams over information and services on GOV.UK that concern local authority functions. In the course of our research around this task, GDS said that they were aware of the shortcomings of the GOV.UK application process for TENs, but there were no current pland to fix it. We also learned that some 54,500 temporary event notice applications went through the GOV.UK site process in 2015. Reviewers remarked that the few councils that had their own licensing application were much easier to use.
Advice given relating to the timing of TENs applications tended to be confusing and sometimes contradictory. Several councils clearly stated up front that TENs must be served at least ten days before the event, but failed to mention the option of a late TEN until reaching the very detailed application guidance notes. There was also little information provided ahead of starting the application about what would happen post submission.
Excellent all-rounder, and the first truly online application process I have encountered during these reviews. Only a contact phone number is missing from the service description. A most attractive council website, a joy to use!
Christchurch Borough Council
I was impressed that the licensing section for alcohol and entertainment had a page about street parties, making clear the circumstances in which a licence was needed, and also providing a link to a page on applying for a road closure for a special event. Very thorough. The temporary event page has some useful information but relies on the prominent GOV.UK link to answer several of our questions. Since it was clearly signposted I thought this was perfectly acceptable.
NB Christchurch is one of six district councils that come under the Dorsetforyou portal. All six sites get four stars for this task, but Purbeck and North Devon do not get the additional ‘recommended’ status because their application options are not as good as the others. Please see their individual reviews for further detail.
Eden District Council
Good information and excellent signposting via the events section.
Hinkley & Bosworth
Excellent clear information provided here on the web page that answers almost all of our questions in a concise and clear manner. An example for others to follow.
Lichfield District Council
This site provides a very good clear and concise introduction to the topic, describing the circumstances in which a TEN is needed. You are then directed to GOV.UK overview page to apply where the rest of our questions are answered. There is also a useful page on street parties, which I came across via the search.
Huntingdonshire District Council
Excellent clear introduction and then a link to GOV.UK overview that supplies the answers to the rest of our questions. Well signposted.
North Warwickshire Borough Council
Web-site answers all questions except that the online application form is via Gov.uk. Guidance is easy to read and in a logical order and locating the TEN page from the council's home page is straightforward. A definite model that others should follow.