FOI release

FOI22/23-095 – Edenred and the Insolvency Service

Updated 30 May 2023

Our ref: FOI22/23-095

Date: 05 December 2022

1. Re: Freedom of Information Act (FOIA) Request

Thank you for your email of 08 November in which you requested from the Insolvency Service:

This is an information request relating to the use of Edenred for a staff rewards scheme.

Please also provide the following information, broken down by financial years 2019-20, 2020-21, 2021-22

1. The types of vouchers or gift cards that the organisation receives from Edenred, either directly or via the Crown Commercial Service. For example, Edenred lists the following vouchers and gift cards: compliments card, incentive award card, childcare vouchers https://www.edenred.co.uk/en/reward-recipients/

2. Please specify the number of each type of voucher or gift cards purchased, and the monetary value of each. For example, the department may have received 100 vouchers worth £50, 50 gift cards worth £20 each
3. Please provide the number of staff to receive each gift card or vouchers and the monetary value of the gift cards or vouchers provided. For example, 50 staff may have received £50 compliments cards, 20 civil servants may have received £20 childcare vouchers

Please also, if possible, include the following information broken down by financial years 2019-20, 2020-21, 2021-22:

Monthly payments to the company Edenred.

Your request has been dealt with under the Freedom of Information Act 2000 (FOIA).

I can confirm the agency holds the information that you have requested and I have provided answers to your questions below.

Please note that The Insolvency Service has a reward budget; this is a defined figure that is set every year and forms part of the annual accounts. These accounts are audited and scrutinised by the National Audit Office and the latest report on them can be found here: https://www.gov.uk/government/publications/the-insolvency-service-annual-report-and-accounts-2021-2022

Any spend to our suppliers (such as Edenred) on reward for INSS staff will come from this reward budget rather than an in addition to it

Question 1 - The organisation does not receive vouchers and gift cards from Edenred but does facilitate the purchase and awarding of them via a reward code. Employees are awarded a reward code and can purchase compliments cards and vouchers through the Edenred website.

Childcare vouchers were available through Edenred however this service ceased accepting new members in 2018, existing members purchase childcare vouchers through a salary sacrifice scheme.

In response to Question 2,3 & 4, I can confirm that the agency holds this information but it is exempt from disclosure under S43 of the Freedom of information act. An explanation of the exemption can be found below.

Section 43(2) – Commercial Interests

Section 43(2) of the Act states that:

‘Information is exempt information if its disclosure under this Act would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it).’

Commercial interests and harm (prejudice)

In this case disclosure is likely to prejudice the commercial interests of Edenred and the Insolvency Service.  This is because the information is both commercially sensitive and/or likely to have an effect on any tendering or procurement process involving the Insolvency Service.

Edenred have a commercial interest in being able to quote and charge fair prices for their work. They work in the private as well as public arena and if we were to disclose our invoices it may be possible for competitors to work out how much Edenred charge for their services and thus undercut them in any procurement. The numbers of reward codes awarded has been withheld because releasing volumes could allow any competitor to calculate engagement levels giving them commercial insight and potential advantage.

The Insolvency Service’s commercial interest requiring protection concern its ability to achieve best value and its processes for ensuring competitive procurement and tendering activity. If Edenred’s costs were made public then competitors could inflate their prices to match what is already been paid to our suppliers, reducing the Insolvency Service’s ability to get value for money.

Public interest test

Factors supporting releasing the information

• Promoting accountability and transparency about decisions relating to the use of public money within the Insolvency Service.

Factors supporting withholding the information

• Undermining the agency’s ability to get a fair price for services; companies may seek to closely match the disclosed figures, and therefore wouldn’t offer best value for money.
• Publishing Edenred’s prices could have a negative financial impact their business.
• Publishing levels of engagement could give a competitor a potential commercial advantage.
• The information could put Edenred at a disadvantage in any future procurement of contracts with government departments.

Decision

On balance, I consider the public interest favours withholding the information at this time

Complaints

If you are not satisfied with this response and would like us to reconsider our decision by way of an internal review (IR) please contact our Information Rights Team at [email protected] or by post at:

Information Rights Team

The Insolvency Service

3rd Floor

Cannon House

18 Priory Queensway

Birmingham

B4 6FD

United Kingdom

You also have the right to contact the Information Commissioner’s Office (ICO) if you wish for them to investigate any complaint you may have regarding our handling of your request. However, please note that the ICO is likely to expect an IR to have been completed in the first instance.

Kind regards

Information Rights Team

The Insolvency Service

The Department for Business, Energy and Industrial Strategy, Official receivers and the Adjudicator are Data Controllers in respect of personal data processed by the Insolvency Service. For the details about how personal data is processed by the agency, please see the full Insolvency Service Personal Information Charter here: https://www.gov.uk/government/organisations/insolvency-service/about/personal-information-charter