Submissions and Policy Recommendations
Every year, the Citizens Information Board contributes to public policy formulation by responding to policy consultations and preparing submissions. Many of these are in response to invitations by government departments and working groups undertaking a review of an old or a proposed new policy. These submissions are available for the following years.
Moneylending and Consumer Protection - CIB Submission to Central Bank
Publication Date: June 2018
In June 2018, CIB in conjunction with MABS prepared a submission in response to the Central Bank review of the Consumer Protection Code for licensed moneylenders. The review proposes new measures to enhance the protections that are in place for customers of licensed moneylenders. The submission stated that any review of the Code must be considered in the broader context of the alternatives available to low-income borrowers – noting that many MABS clients have few choices when considering credit options and are, thus, reliant on the moneylending sector. In this context, CIB highlighted the role of the Credit Union “It Makes Sense” loans, which CIB was instrumental in getting off the ground and the need to further expand the roll-out of these loans across the Credit Union Sector. An analysis of the repayment and arrears experience of MABS clients for this review indicated concerns around questionable lending, record-keeping and poor information provision amongst some moneylenders.
Advance Health Care Directives - Codes of Practice
Publication Date: May 2018
CIB responded to the HSE Consultation on Codes of Practice for: Health and Social Care Professionals, Designated Healthcare Representatives and a Code on How to Make an Advance Healthcare Directive. The requirement for these Directives (and associated Codes of Practice) derives from the introduction into Irish law of the Assisted Decision-Making (Capacity) Act 2015. The submissions welcomed the introduction into law of Advance Care Planning and commented on technical aspects of the three Codes of Practice – focusing on the use and definition of terms within the legislation, compliance and associated liability and the role of healthcare personnel in advance care planning. The need for recognition of the role of independent advocates in the Codes is noted, as health and social care practitioners will encounter advocates who will be assisting people with expressing their will and preference in cases where capacity issues arise.
Deprivation of Liberty: Safeguard Proposals
Publication Date: March 2018
This submission is a response to the Department of Health consultation on draft legislation on deprivation of liberty safeguard proposals. Legislative clarity is required on the issue of deprivation of liberty in residential facilities for older people, those with a disability or mental health issues in order to meet obligations under the United Nations Convention on the Rights of Persons with Disabilities. The submission notes that in all cases, deprivation of liberty should occur in accordance with due process of law, and subject to regular review and lawful challenge.
Future of Policing in Ireland
Publication Date: January 2018
CIB prepared a submission in January 2018 to the Commission on the Future of Policing in Ireland in response to a wide-ranging public consultation process. The insights provided were based on the experience that CIB delivery services have in reaching out to vulnerable and marginalised groups in Irish society - such as people on low incomes who are living in deprived communities, people with disabilities and mental health difficulties, Travellers, and new communities/ immigrants. Specific areas which CIB felt require additional attention from An Garda SÃochÃ¡na included dealing with illegal moneylenders, engaging marginalised and new communities and helping victims of abuse.