Folkestone & Hythe District Council (FHDC) has released fresh numbers on how often it sends Council Tax debts to private bailiffs — and they don’t line up with figures the council itself published earlier this summer.
In a response to a Freedom of Information (FOI) request, FHDC now says the number of households/accounts referred to enforcement agents was:
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2022/23: 906
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2023/24: 644
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2024/25: 1,299
It also says the number of referrals/instructions (counting each instruction, even if multiple per account) was:
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2022/23: 1,432
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2023/24: 977
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2024/25: 2,085
Yet in July 2025 the council told a separate FOI requester that 2022/23 saw 948 households and 1,446 referrals. Those newer totals are lower than what the council published in July for households (906 vs 948) and lower for referrals (1,432 vs 1,446). FHDC has not provided a reconciliation; it says simply that no explanation is recorded.
How the Council Says It Counts
In unusually candid wording, FHDC explains that it does not trust a system report to count referrals. Instead, officers compile figures manually from weekly “pre-lists” of cases about to be sent to bailiffs. Those lists are checked by a corporate debt team leader, a data file is created, and a separate “Bailiff posting Total” spreadsheet logs:
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a count of unique Council Tax accounts in each file, and
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a count of liability orders in each file (an account can have several).
Crucially, the council spells out a limitation: “households/accounts referred” is the count of unique accounts in each file — not unique accounts in the year. In plain English, if the same household appears in two different weekly files in the same year, it can be counted twice in the annual total (even though within each file duplicates are removed).
FHDC says it prefers this manual approach because users can apply the wrong codes in the revenues system, which would make a pure system report unreliable; officers correct those errors, but retrospective changes mean a report “run today” might not match the situation at the time.
What The Log Shows: 131 Bailiff export runs in 2022/23
Alongside the narrative, the council released an audit sheet for the NEC (Northgate) job RRV990 – “Bailiff Interface Out.” The log we analysed covers April 2022 to March 2023 and records 131 export runs used to generate the files that feed the manual spreadsheet.
Breakdown of those runs by bailiff short code in 2022/23:
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CDER_BAU: 48 runs
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CDER_CTR: 23 runs
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CDER_TRACE: 1 run
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NWLN_BAU: 39 runs
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NWLN_CTR: 20 runs
The parameters captured in the log confirm the mechanics: enforcement stage, from-date, bailiff short code, commercial/domestic flag, court session ID, include headings. Runs were weekly with ad-hoc additions for court sessions — exactly as FHDC describes.
What this tells us: FHDC’s annual totals are stitched together from many weekly files across multiple bailiff codes. Because the council doesn’t deduplicate across the whole year, the “households/accounts referred” figure can over-count residents who appear more than once in different files.
(We’ve published a month-by-month run chart and the per-bailiff run tables from the RRV990 audit the council released.)
Two Public Figures, two sources – but no matching CSV
The FOI asked FHDC to supply both the 2023 Money Advice Trust (“Stop the Knock”) return for 2022/23 and the July 2025 FOI figures, plus the underlying CSV extracts used to produce those totals. The council relied on FOIA section 21 (“information accessible by other means”) and pointed to online case references:
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Case 00163424 – the 2023 “Stop the Knock” response
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Case 00252756 – the July 2025 FOI reply
However, when asked for the actual extracts that sit behind the published totals, FHDC did not provide CSV files. Instead, it listed the fields that the RRV990 job can output (account number, liable person, addresses, amounts, liability order ID, dates, contact channels, email, etc.) and confirmed that direct identifiers exist in the source feed. That is not the same as supplying the pseudonymised CSVs requested, so on this part the council’s disclosure is partial.
On the targeted audit trail for the 2022/23 totals used in 2023 and in July 2025, the council referred to the RRV990 sheet. The sheet shows run times, creators and session IDs, but it does not identify which specific subset of runs was used to produce the 906/1,432 totals versus the 948/1,446 totals — again leaving the central discrepancy unexplained.
Enforcement Agency Split
FHDC’s new figures split the activity between its two contractors:
Households/accounts referred (per-file unique, not annual unique)
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2022/23: CDER 482, Newlyn 424
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2023/24: CDER 377, Newlyn 267
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2024/25: CDER 844, Newlyn 455
Referrals/instructions (liability orders placed)
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2022/23: CDER 678, Newlyn 755
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2023/24: CDER 557, Newlyn 421
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2024/25: CDER 1,319, Newlyn 766
These splits broadly match the RRV990 activity pattern we can see in 2022/23, where CDER and Newlyn both have frequent “BAU” runs and additional “CTR” (court-related) runs.
Why It Matters
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Transparency: The public has been asked to rely on two different 2022/23 totals published by the same council within two years, with no recorded reconciliation of the difference.
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Method: FHDC is clear it uses a manual spreadsheet because it doesn’t fully trust the system. That is honest — but it also raises normal data-quality questions: if deduplication stops at the file level, an annual figure labelled “households/accounts referred” can mislead.
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Policy impact: Bailiff referral counts feed into national campaigning and local scrutiny about the use of enforcement against people in arrears. Over-counting risks overstating how many households are involved; under-counting risks minimising the scale of hardship. Either way, the method needs to be transparent, replicable and auditable.
What The Council Should Now Publish
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A single, reconciled statement for 2022/23 that sets out the definition used and bridges 906 ↔ 948 and 1,432 ↔ 1,446.
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The pseudonymised CSV extracts underpinning both the 2023 submission and the July 2025 reply — as requested — with a short data dictionary.
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A clear, public definition going forward:
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Are “households/accounts referred” annual-unique people, or per-file unique counts aggregated?
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Which event date controls inclusion (instruction date, placement date, first action date)?
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How are re-referrals and court bulk moves handled?
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Until then, readers should treat headline totals with caution: FHDC’s own paperwork shows that the counting method can inflate “households/accounts referred” when cases appear in multiple weekly files.
Notes on Our Analysis
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We analysed the RRV990 audit sheet the council supplied. It logs 131 “Bailiff Interface Out” runs between April 2022 and March 2023 across CDER and Newlyn codes (BAU/CTR/TRACE).
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The council’s new totals for 2023/24 and 2024/25 are taken from its FOI reply (and cannot be independently verified from the 2022/23 audit sheet alone).
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FHDC says no reconciliation document is held explaining the 2022/23 discrepancy.
If FHDC provides the underlying CSVs it relied on, we’ll re-run the counts using annual-unique definitions and publish a line-by-line reconciliation.
The Shepway Vox Team
Dissent is NOT a Crime
