Breeding – the impact of Breeding Licensing Regulations on Dog Breeders

Posted April 9, 2019 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for animals

            As a result of continuing concerns by the Kennel Club and the National Register of Pedigree Dog Breeders about the way in which licensing officers were interpreting the new Animal Licensing Laws (The Animal Welfare (Licensing of activities involving animals) (England) Regulations 2018) which became law on 1st October 2018, and in association with Holly Conway of the Kennel Club, David Cavill FRSA designed a survey to make public the extent of the problem and, particularly, the impact it was making on ‘hobby breeders’.  (For the record, ‘hobby breeders’ have been defined as ‘an owner who breeds from a bitch because they would like to have another puppy to take part in the canine activities with which they are involved, whether that be to show, to train for agility obedience or any other reason. That reason could be extended to include that they have another companion when one of their current dogs dies. The key issue is that they are not breeding specifically to sell dogs as a regular part of their annual income. Such hobby breeders are likely to have surplus puppies which they will want to find good homes for and they are entitled to advertise them and sell them. A reasonable ‘test’ for hobby breeder is that they will (usually) be retaining one or more of any litter to pursue their hobby.  Those who breed more litters than two each year may still consider that they are a ‘hobby breeder’ but will, of course, require a breeding licence.)

There has been much hearsay on social media and anecdotal evidence from breeders who have been affected but there has been very little hard data.  Survey has now closed but it addresses those problems. It is particularly interesting and important to note that those who replied were by no means all breeders of pedigree dogs.

Defra has said that at 1st October 2019 there were approximately 600 breeders licensed by local authorities under the old regulations.  The Kennel Club and Our Dogs were therefore very pleased that the survey generated 1,500 replies which clearly showed that breeders were taking responsible action by recognising that they were subject to the new laws disappointed with the revelations about the extent of the problem.  The Kennel Club has now completed its analysis of the responses and provided them to Defra who, we understand, were taken aback by the range of the misunderstandings by licensing officers and have indicated, though not promised, to take action.

Key Statistics

  • 75% of respondents get their information about dogs and breeding from the KC;
  • 89% of respondents consider themselves hobby breeders.
  • 85% did not have a dog breeding licence prior to October 2018. 50% breed less than 1 litter per year and 37% breed 1-2 litters per year;
  • 27% are ABS members – 90% for more than 3 years. ABS membership counted towards compliance history for less than 60% (59%) and as a result they achieved a 4-5 star rating. For 41% it did not and they received a 1-3 star rating;
  • One third had to comply with conditions such as planning permission; companies house registration; public liability insurance; implementing noise reduction measures; applying for business insurance and paying for business refuse collection prior to being issued a licence;
  • 65% do not rely on advertising pups for sale because they have waiting lists. Only 17% advertise on commercial websites and 25% on their own website. Over 80% use non-commercial websites such as KC’s find a puppy service (https://www.thekennelclub.org.uk/services/public/findapuppy) or the National Register of Pedigree Dog Breeders (www.ibreedpedigreedogs.uk)
  • Of those breeders who have been inspected by a local authority nearly half (46%) were not confident or not at all confident that their inspector was knowledgeable about dog breeding; almost half (48%) were not confident or not at all confident that their inspector understood the different between a business and a hobby breeder and over 40% (41%) were not confident or not at all confident that they understood or had applied a business test proportionate to their circumstances.

Survey Responses

The Kennel Club’s analysis and comments provided by respondents runs to 16 pages many of which repeatedly emphasise local authority officers’ lack of understanding of the concept of a ‘hobby breeder’, but we hope that this brief summary will provide readers with an understanding of the main features.

Most comments related to local authorities not recognising hobby breeders and advising any breeder who breeds even one litter to apply for a licence. This is a widespread misunderstanding which these Kennel Club believe needs to be addressed.  For instance Kings Lynn and West Norfolk Council do not appear to be taking any account of ‘hobby breeding’ as an exemption for requiring a license and take a very strict view that if anyone is selling a puppy for any money at all, it counts as a commercial operation. They refused to apply the ‘hobby breeding’ rules are breeder in the Shropshire Council area said she was told that she had to have a licence as she has an intention to breed’.  There were over one hundred similar statements one of which was that Birmingham City Council is actively looking for and even buying puppies to catch hobby breeders with the intention to prosecute them for having a litter and not being licensed.

The Business Test

There were similar misunderstandings about the Business Test. Over 40% of respondents were not confident or not at all confident that licensing officers understood or had applied a business test proportionate to their circumstances.  And the Kennel Club have concluded that ‘there is a systemic problem with the business test which was evident in numerous comments received’. This included Telford & Wrekin using the £1000 turnover business case, so they say that anyone breeding a bitch must have a license as even the sale of 2 cross breed pups will be more than £1000 and Bassetlaw Council saying that anyone selling puppies for more than £1000 will probably need a license.

Almost more worrying is that a third of respondents were expected to comply with conditions such as planning permission; companies house registration; public liability insurance; implementing noise reduction measures; applying for business insurance and paying for business refuse collection prior to being issued a licence.  The KC say that many breeders are clearly being treated as commercial businesses and being requested to jump through excessive hoops in order to receive a licence. This is resulting in many ceasing breeding altogether. The most commonly cited additional requirement breeders had to apply for was public liability insurance. There are however many others.              For instance, one respondent said that planning issues stopped her from applying and Durham County Council also expected to take DNA from every dog because they said they ‘wanted a dog DNA database in order to catch people who left faeces lying around’. A licensing officer in Kent said anyone with more than 3 breeding dogs had to be in commercial premises so in effect. They are advocating puppy farming while trying to close down home breeders.

One respondent reported ‘I have so far been prevented from applying for a licence as the local council insisted that I needed Planning permission for change of use. Architects drawings, planning application, acoustic survey and £7000 later they turned down the application on ridiculous grounds so this has now gone to appeal!’ And the

Throughout the survey it was clear that there was considerable confusion about precisely what was required of breeders by licensing officers and some appeared not to have read the guidance at all. The Kennel Club and say that this seems to be a  ‘one size fits all’ approach so that however small the breeders’ business, the red tape, bureaucracy and paperwork is what one would expect of a large business or even a commercial kennels housing many dogs.

One respondent said ‘I have re-homed most of my dogs since new regulations came out because I simply could not cope with the ridiculous rules and mountains of red tape’. Another wrote, ‘I applied for my Licence in November 2018. I received a phone call from the council asking for £435 before an inspection date could be booked. I received another telephone call a couple of weeks later making an appointment for two licencing officers and a vet to attend my property on 10th January 2019. When they arrived, the inspectors handed me their Guidance Notes for the application, the first time I had seen it. The inspection then took around four hours, working through 36 pages of the application form. About 10 days later I received a call from North Devon District Council to say that they had recommended my application for refusal, although I would have the chance to put my case forward to a committee meeting at a future date to be agreed. I was emailed a 49 page report, outlining the reasons for refusal. Since then it has taken approximately 35 hours to work through the report in order to supply NDDC with the information they require, mainly in written Standard Operating Procedure format. I am still working through the form but to date have put together over 50 pages of response. I do not employ any staff. On a personal level, I have found my experience to date with NDDC very stressful. They clearly have no experience of dog ownership on any level, and stated to me at the outset, they are licencing officers and are only interested in applicants meeting the licence criteria.’

Some local authorities appear to have no knowledge of the new regulations at all. A respondent in Bradford tried to apply for a licence and was met with blank stares while others say that the appropriate forms are not available while giving out conflicting information.  The Kennel Club have made it clear to Defra that it is not acceptable for any local authority to not have any indicators on their websites that the legislation has changed (many have incorrect and outdated information). Further it appears many are unaware of updated regulations even when breeders contact them.

Assured Breeder Scheme membership

According to the Guidance, ABS membership should count towards compliance history so that the star rating awarded (which affects the length of time the licence is allowed to run) should take that into consideration. In fact licensing officers were only prepared to acknowledge ABS membership in about 60 % of the cases where a four – five star rating was applied but worryingly, for 40%, membership, compliance history was ignored.

The Kennel Club has made it clear to Defra that ABS could not only save a local authority time and money but encouraging ABS membership provides the puppy buying public with a pool of responsible breeders. Disregarding the only UKAS accredited scheme undermines the intention of the regulations – which is to improve the welfare of puppies being bred and ensure puppy buyers purchase dogs from responsible breeders.  For instance North Devon District Council quote in their application form: ‘It must be noted the Kennel Club requirements and assessments are not as in depth and complex as this assessment’. Given that the criteria are actually based on the ABS this is clearly a total misunderstanding by the council.  In the instance quoted they wanted to see the ABS Inspection Report but it was not considered or taken into account in their decision making process.  Another respondent reported that their licensing officer did not accept ABS membership and they said, ‘We received a ‘0’ rating and were told that no star will be given till after 2020 even though we have been assured breeders since 2005.

In the Kennel Club’s opinion some local authorities have so misunderstood the regulations it could be damaging to the puppy buying public. They say, ‘If local authorities are not issuing star ratings, or issue only 1 star ratings for a good breeder then puppy buyers may be less likely to buy a puppy from that breeder – even though if rated by another local authority that breeder would be likely to achieve a much higher rating. This inconsistency is detrimental to the puppy market as it fails to assist people looking for good breeders’.  For instance Breckland Council have a policy of not giving stars to anyone and other local authorities have a policy of only giving a one year licence when the Guidance makes it clear that well-established breeders who fulfil the criteria for higher standards should be given a star rating which reflects the quality of their service.

There are also serious concerns about the licence fee.  One respondent reported,  ‘The fee is suddenly five times what it was last year and even though I was given 5* rating they will only grant a 12 month licence which means that in a year’s time I will have to pay a further £1400’.

Fundamental disagreements with minimum standards

There were several issues which responsible breeders fundamentally disagreed with specific criteria for the highest standards.  The result is that they are unable to gain a higher star rating. This shuts out a good source of puppies from the market and undermines the intention of the regulations, for good breeders to breed healthy dogs and for puppy buyers to know where to source them. In their submission to Defra the Kennel Club put forward a number of specific case studies to demonstrate the misunderstandings which are already beginning to appear endemic

North Devon

An ABS breeder applied for a licence with North Devon District Council. They had the inspection and were told they would get a 1 star rating providing some areas were dealt with – including vaccinations & labelling the fridge. They have been a member of the ABS since 2008 with no issues.

South and South West Local AuthoritiesLocal authorities in this area are advising breeders that they will require a licence if they breed and sell even one puppy and are taking no account of membership of the ABS.

Teignbridge

An ABS breeder applied for a licence from Teignbridge District Council having joined the ABS in 2013 and having had two ABS inspections resulting in a satisfactory outcome. She is a hobby breeder, who normally breeds two litters per year from home. She was advised however that she would receive only a 3 star rating because she has not undertaken an OFQUAL qualification and had been told that it was essential to complete this at a cost of £900 (there are a number of distance learning colleges which can assist breeders at considerably less than £900 Ed) in order to achieve a 5 star rating. However this is an ‘optional’ requirement of the local authority licensing conditions, intended for breeders who employ staff (which she does not). Further, the local authority informed her that they were not taking compliance with the ABS into account which is causing her to consider leaving the scheme and even stop breeding.

East Riding

East Riding Council informed an ABS member that their ABS history does not count towards their compliance history and as such the ABS member will not achieve any star rating until 2020.

Mid Devon

The Kennel Club have had four complaints regarding Mid Devon District Council as they are not taking into account ABS membership with regards to proof of compliance history and are insisting anyone who breeds even one litter (even if they keep some puppies from the litter for themselves) must be licensed and inspected annually – even if they only have a litter every 3-4 years. Moreover, they are not implementing the scoring matrix at all and so it is unclear as to how they can be issuing an accurate star rating.

Adur and Worthing

 

Adur and Worthing Councils launched a consultation on the AAL shortly after the new regulations were introduced. The AAL is intended as a prescriptive document. It is not open for consultation. What is more, they stated at the time they would adopt the new regime in ‘early 2019’ and so missed the implementation date of October 2018.

Guildford

Guildford Borough Council also issued a consultation on its licensing policy. Within this they stated: “Proof of the planning permission required for the relevant activity on the premises should also be provided”. This is additional red tape for low volume hobby breeders who will already have to declare their income to HMRC and provide public liability insurance.

Chichester

Chichester District Council wrote to us following communications they had been having with an Assured Breeder regarding whether they would require a licence. They stated in their correspondence to them that the majority of dog breeders would now require a licence because breeding and selling dogs with a view to making a profit or earning any commission was now licensed. However this is just one marker in HMRC’s badges of trade and so is not the case.

Defra were contacted regarding this particular conversation and wrote to our Assured Breeder to state:  “The key thing to focus on here is the operation of business as being the determining factor in cases where less than three litters are bred per year. This is where the business test comes into play, which will help differentiate those who are legitimate hobby breeders and those who are actually operating a business….. The business test is not stating that anyone who makes a sale or takes a commission is automatically in scope…”

Selby

Selby District Council has been in contact by one of our KC Assured Breeders in relation to their licence and subsequent complaint upon being told they would only be issuing a 1 year licence initially. The reasons given are:’As this is new to all of us, for the first year only we will issue one year licences only. This will give you time to ensure that you are meeting all of the required standards, ready for the next years renewal and give us the chance to see what additional work, if any is required to enable us to get our fee setting correct.’  It is worth pointing out that this one year licence came at a cost of £556.10. Furthermore, this breeder has been a member of the Assured Breeder Scheme, without issue, since 2008 and has been the only licensed breeder within this local authority area for some years now.

New Guidance?

It is unlikely that the current Guidance will be updated in the near future but Defra has suggested that they are prepared to circulate a Briefing Note in the near future which bring some of these problems to the attention of local authorities.  We can only hope that they read them but in the meantime it is hoped that guidance will be made available to breeders so that licensing officers can be shown it as and when necessary.

 

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Breeding – Background to the survey on the impact of licensing on breeders

Posted April 3, 2019 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for animals

Compromise is the best and cheapest lawyer – Robert Louis Stevenson

I created a survey for Our Dogs and the Kennel Club launched in February on the impact of the new Animal Licensing Laws on breeders. Like most of the previous attempts to legislate and/or control pet animals by introducing legislation to control breeders and dangerous dogs it is once again evident, however benevolent the intention, that our lawmakers find it very difficult to achieve what should be quite clear objectives without making the whole framework too complex for anyone to fully understand what is required or, as far as local authority licensing officers’ are concerned, creating chaos and confusion where non should exist.

Under the circumstances, it is therefore not surprising that the greatest legislative success in this sector by any government was almost by accident.  With the environmental Protection Act 1990 and the ensuing Environmental Protection (stray dogs) Regulations 1992 and the Control of Dogs Order 1992, the responsibility for stray dogs was transferred from the police to local authorities as an addendum, for the original Act was almost entirely about the disposal of waste and the definition of statutory nuisances. Almost overnight, stray dogs disappeared from our streets and those of us involved (Angela and I were then senior managers with The Dogs’ Home Battersea) were delighted to see that the numbers of dogs having to be destroyed dropping like a stone.  Nothing is perfect (and the whole framework surrounding dangerous dogs remains an appalling abuse both of dogs and the law) but since then we have had Control of Dogs Orders, the insistence that all dogs should be micro-chipped and a government moving forward on Lucy’s Law (the banning sale pets by a third party) too.

What is happening now?

But to return to the new ALLs:  It is not only breeders who have been impacted by this legislation and although it seems to me that most of the major concerns are around dog breeding, there has also been much discussion and concern about kennels and catteries, home boarding and day care centres.  The area which has seen the least upset are those pet shops which sell small pet animals such as hamsters and rabbits, reptiles and fish (most high street pet shops do not sell puppies or kittens) but it remains to be seen how the market will react to the future restrictions on third-party sales of puppies and kittens sold from trading kennels (which require a licence to sell animals) and large breeding establishments (which require a breeding licence) which currently supply those trading kennels.

My view has been for some time that in the future, trading kennels will begin to breed their own puppies while those large breeding establishments which we so often referred to as ‘puppy farms’, will begin to sell direct to the public.  We have already seen this happening in that T & S Four Paws in Barton under Needwood was raided by Trading Standards and Environmental Health Officers in East Staffordshire a year ago (the situation is current because the owners, Tina Paris and Stuart Ward, have just been fined well over £1000 each and to do 100 hours unpaid work as well as being ordered to attend sessions to improve their reading and writing skills – I assume that part of their defence was that they did not understand the documentation). They have also been disqualified from having or obtaining a Pet Shop Licence or a Breeding Licence for two years. What did they do? Their premises had a pet shop licence for selling dogs but they did not have a licence for breeding them. After a complaint about a puppy, licensing officers visited the premises and found that they not only did not comply with the licence conditions but they had begun breeding their own puppies without a breeding licence. This offence took place before the new regulations were introduced but demonstrates my point about commercial businesses taking what they see as sensible steps to stay within the law.  We can only hope that the new standards being applied will ensure that the quality of care and socialisation will be to acceptable standards but this is entirely dependent on the good sense of those employed by local authorities.  In the above case, and I suspect many others, they behaved impeccably but there is no doubt that, given the results of the survey, some leave a great deal to be desired in the extent of their understanding, knowledge and experience.

Red lines and grey areas

Many years ago I was a member of the small committee that wrote the Model Licence Conditions (MLCs) which were published in 1995 which have been in force for kennels and catteries for over 30 years.  As with any new guidance it took some time for all those involved to understand the more stringent requirements but there is no doubt that the quality of both service and environment has significantly improved over that time.  But I remember well having a long and protracted discussion with environmental officers in Cambridgeshire about what was then a brand-new and very beautiful cattery which had been built by a very experienced and sensible owner.  Her husband was a builder so it was built on sound foundations, of brick and was a courtyard style with a lovely garden and a beautiful pond in the centre.  The new MLCs required a sleeping area of X by Y but the block had been built (with underfloor heating which came on automatically when the temperature dropped below a certain level) with an area of X-1 (inch) by Y-2 (inches).  The argument went backwards and forwards for months with me saying that the space allotted fulfilled the requirements of the 1963 Act (which then defined the statutory requirements) and that the MLCs were not statutory and were advisory while the Environmental Health Officer concerned responding that if dimensions were included they had to be adhered to. As I remember, the issue finally went to court (this was before the current appeal process was in place) and I am pleased to say that the cattery is still there and continues to have a superb reputation.

This demonstrates how important it is that any statutory demand should allow for sensible judgement.  If the dimensions had been seriously inadequate or the cattery in question had also been characterised by poor care, inadequate paperwork or other physical shortcomings then the precise area would sensibly be one of the factors in refusing a licence.  As is was the only shortcoming some latitude should have been allowed.

Current problems

In the last few months I have been made aware of a number of difficulties faced by well-established premises that have fallen foul of the new regulations and the question of areas is now even more pertinent because the regulations are statutory.  For example Michelle Render of Elmsall Kennels tells Kennel and Canterbury Management, ‘Turmoil has been caused by the new legislation for kennels like mine that cannot be modified to the required sizes.  Although there has never been a complaint in our 14 years of trading we have therefore been given a low star rating’. (Just to recapitulate, the statutory regulations are quite basic so Michelle’s premises fulfil the criteria but licensees can only get a ‘star’ rating if they fulfil further, higher standards.)

Frankly, I am surprised that the Pet Industry Federation which has a section devoted to boarding kennels and catteries (the UK Kennel and Cattery Association) and the Association of Licensed Kennels (ALIKA) have not written and launched their own survey to see how the ALLs are working in their sector given that Defra have been impressed and appreciative of the Kennel Club/Our Dogs survey.  Perhaps it is time to create another especially for kennels and catteries. Back to several hours on Survey Monkey for me I think.  (NB:  This survey was launched in March 2019)

 

An unnecessary proposal which will discriminate against some owners of assistance dogs

Posted October 5, 2018 by davidcavill
Categories: pedigree dogs

I have found that when you are deeply troubled, there are things you get from the silent devoted companionship of a dog that you can get from no other source – Doris Day

Under the Equality act of 2010 you are considered disabled if you have a physical or mental impairment that has ‘a substantial and long-term’ negative effect on your ability to do normal daily activities. ‘Substantial’ is more than minor or trivial so, for instance, if it takes much longer than it usually would to complete a daily task like getting dressed is not classed as ‘minor’ or ‘trivial’. ‘Long-term’ means 12 months or more.  You automatically meet the disability definition under the Equality act from the day you are diagnosed with HIV infection, cancer or multiple sclerosis and there is also a classification regarding progressive conditions (those which get worse over time such as a breathing condition which develops as a result of a lung infection): All can be classed as disabled conditions.

If you are disabled you have rights to protect you from discrimination and you have these rights in almost every public aspect of your life including employment and education.  One area that is not included is travel because the complexity of making discrimination illegal as far as aircraft, buses and trains is simply too complicated. Many transport companies are making an effort to help disabled people but as demonstrated by a report in Which? Magazine recently there is still a very long way to go simply because of the technical difficulties involved in wheelchair users getting on and off almost all modes of public transport.

For well over 100 years it has been recognised that dogs can be not just helpful but often essential in assisting those who are disabled to cope with their disability.  During this time and particularly during the last 30 years, many organisations have been set up to specially train dogs for those people who would like a dog (not everyone wants to have a dog if they are disabled) and for whom a dog would be an asset. Guide dogs, hearing dogs for deaf people and support dogs for those who are wheelchair-bound are often seen on our streets and they are identified by their jackets which clearly indicate their role.  As I explained in a recent Speakers’ Corner, a number of those charities have come together to share expertise and to represent their interests and the interests of their users under the banner of the charity Assistance Dogs UK (ADUK) whose director, Peter Gorbing has become a powerful figure as far as disabilities issues are concerned as he has been an effective spokesman on behalf of disabled people. This has some disadvantages as there are some who feel that his approach appears to be especially protective of ADUK and this has inadvertently, although some affected say deliberately, complicated disability issues for a number of disabled dog owners.

Disability comes in two basic forms, those which are obvious and those which are hidden.

Less recognised disabilities

Physically disabled people who are wheelchair-bound or find difficulty in walking are clearly distinguishable from the able-bodied. Not being able to hear or see are ‘hidden’ disabilities to some extent but ones which are universally recognised and are well supported by dogs.  But there are a wide range of other hidden disability issues and these include: epilepsy (medical detection dogs can indicate if an epileptic fit is imminent); support dogs (for those with mental health problems including panic attacks); respiratory illnesses and those with cancer, HIV infection and multiple sclerosis where a dog can provide stability, comfort, companionship, emotional and sometimes practical support.

But for the present there are no well-heeled charities set up to provide canine services for those who feel they would be helpful and therefore no public recognition of the role that they play. For many people in this position they have dogs which they themselves have trained but which are not ‘officially’ recognised as support dogs by employers or schools and colleges which, in theory, they have a duty to do.

When this was brought to the attention of the Office for Disability Issues (based at the Department of Work and Pensions) a working group was set up to try and address these problems. I am told by the gentleman who was tasked with organising the working group that he knew very little about working with assistance dogs but made every effort to contact all those groups likely to be involved or affected and I am happy to accept his assurances – but as so often significant stakeholders were omitted (the Pet Education, Training and Education Council of which I am the chairman for one). There is an understandable tendency for government to look for advice from the most forceful and often well-funded groups (who naturally can not only afford to employ clever and intelligent PR people but have the resources to send them to such meetings) and this certainly appears to have happened in this case.  I am not for a moment suggesting that those clever and intelligent people do not have the best interests of those they represent at heart but as soon as government is involved the whole process becomes far more complicated (and expensive) than it needs to be.

Keep it simple – bureaucracy can be avoided

The solution being proposed by the working group appears to be to allow the setting up of a completely separate structure monitored by the Office for Disability Issues which would mean that both dogs and owners in the unfortunate position of not having currently ‘recognised’ disability where the ownership of an assistance dog would be helpful, be subjected to an external test of their and their dogs’ suitability.  I have had the opportunity to examine the test and its accompanying rubric and it is my opinion that it is unnecessarily complicated, poorly constructed and likely to be expensive. It would also greatly increase the stress being placed on owners who have more than enough problems to cope with anyway.

The original suggestion was that this test would be administered by just one non-statutory organisation who would exclusively train some of its members interested in taking part (follow the money ladies and gentlemen) and that, in their words, ‘as the character of dogs changes over the years’ the test would have to be repeated several times during the dog’s life.  It is not just the structure that is wrong, the foundation upon which it is built, is on sand not on sense. But there is some good news: the first is that nothing has yet been finally decided so there is still the opportunity to deconstruct the whole proposed edifice and the second is that those on the working group have sensibly decided that if any training of owners and dogs is to take place then it should not be confined to one exclusive group of trainers.  This would mean, in the sad circumstances of this solution going forward, that at least some competition will be introduced into the scheme.

But there is a much simpler solution which would take it away from government and the associated bureaucracy, is pragmatic, and fits in with the current structure of the charitable sector involved with assistance dogs. I believe that what should happen is that a separate charity should be set up (hopefully supported by the others already working in the field and ADUK) to train dogs and help owners who are affected by these specific and complex issues. It would automatically have the same status of the other charities and be able to flexibly and pragmatically solve the problems of those affected (and provide its own ‘approved’ badged jackets for the dogs) without being burdened by unnecessary administration.

Some stakeholders on the working group have asked that I become a member and I have been accepted. I will keep you informed as to progress.

Don’t Panic about the new Data Protection Act

Posted April 24, 2018 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for animals

Data is a precious thing – Tim Berners-Lee (creator of the Internet)

I have long believed that for a small business (and most kennel businesses are small) the need to computerise everything is minimal.  The footfall of the average kennel is unlikely to be much more than 30 each week unless you have associated activities such as a grooming room or shop, although of course, there is a tendency for everyone to turn up at once so it sometimes seems much busier than it actually is.  Under those circumstances it is much easier to provide a new client with a printed card on which they write all the details which can then simply be dropped into card index drawer than for the receptionist, whoever that may be, to turn to the computer and painstakingly insert a dozen fields while three or four owners are waiting to either deliver or collect their pets.

It is often suggested that computerisation gives you access to a range of useful reports and this is true but, frankly, how many kennels need to print out a list of medication when any owner or member of staff worth their salt will know the dog or cat well enough to remember what it needs and, in any case, a board with each dog’s details in the kitchen area is more than enough to ensure that each pet is looked after properly.  If you think about it a diary, a website, an email address, a telephone number and a simple spreadsheet to calculate income and expenditure is really all that is necessary.  However, using a computer has gradually become a symbol of modernity and we seem to use them whether or not they provide the best process in any given set of circumstances.

If this is the way your kennel and/or cattery has been administered then you did not need to have any concerns about the first Data Protection Act of 1998 for it only applied to a limited extent and it has been generally recognised that information such as name address and telephone number was generally part of the public record so not regarded as ‘personal’.   In fact, even if that basic information was held on computer and included an email address it was still not regarded as a problem.  However as from May 28th, 2018 this is now longer the case and any data you hold in whatever form is subject to the new General Data Protection Regulations.

Don’t Panic

Do not panic: it is not as bad as it sounds.  If you think about it is it all perfectly straightforward and reasonable but you do need to comply because by its very nature the Internet is an open source for information and the same techniques used by Facebook, Amazon and the rest to track you to bring you advertisements which they feel will be of interest to you are likely to be used to measure your activity online and will highlight those who are not registered or not complying.  So I recommend that you apply for the aim is sensible: to allow individuals to stay in control of their personal information and to ensure that those organisations that hold your personal data protect it, use it responsibly and do not sell it or distribute it without your permission.

If you are already registered you will have received details of how to update your registration.  Otherwise the first thing to do is to register.  You will almost certainly need to do so but you can check by going to this link and answering the questions posed https://ico.org.uk/for-organisations/register/self-assessment/ .  At the end of the short survey you are told whether or not you need to register or not and if you do, you are licked directly to the registration page.  It takes about 15 minutes to complete so is not onerous or complicated.   However, please note you will be asked to identify one person within your business who is going to be responsible for data protection.  In most businesses it will be the proprietor but in larger organisations that responsibility may fall to Human Resources or a senior manager.  You will also see that business owners have a responsibility to ensure whoever it is, thoroughly understands what is required of them: there are fines for not fulfilling the role properly.

Remember that if a separate business uses your premises then they will have to register too.  For instance, some kennels lease their grooming room and others have a field that they let out to a training club – just direct them to the link above even if they are a not-for-profit club or society.  If such activities are part of your business then one database is sufficient of course.

What you need to do

The next stage is for you to list all the data about your clients which you actually need.  I totally approve of this requirement because I get extremely irritated with those intrusive requests for information such as my age, education and ethnicity whether it is from government or any other source.  You may find that you are, without realising it already asking for more detail than you need.  Name, dogs/cats owned (you will need their details), address, telephone numbers, email address and contact details of a responsible person who can be contacted in an emergency is really all you need for any client.  What you do not need are details of their peccadillos: in fact you are now not allowed to keep personal notes about clients (‘always ‘picky’, handle with care’) and as you are duty bound to provide all the information you hold about a client on request (for free – you may not charge for so doing so) it is probably not wise in any case.

All data must be held securely so your computer must have a password, filing cabinets or card indexes must be locked and keys removed and kept safely when the office is unattended.  You should also instruct any staff with access to personal data of the importance of keeping them safe.  Mentioning staff – their stored data falls under the GDPA too so must be secure and held safely.

Next you must inform your clients about what data you are storing and why.  You do not need to contact them them but after 28th May you should have a leaflet/form to hand to each client for them to complete. I have created an example for you to amend and use. If you sign up to the National Register of Boarding Kennels and Catteries (www.iboarddogs.uk – it is free to join you can download an editable word processing copy which you can amend to your own requirements.

Within the data protection notice I have tried to include all the points demanded by the legislation so you do not have to keep any other records of what you do and how you do it.  ‘Keep it Simple’ has always been my mantra and just because the legislation seems complicated does not mean we have to do any more than absolutely necessary. Incidentally, if you do contact clients with any marketing or general advertising, you need to ensure there is an opt-out button within the mailing.

Data Protection Notice and Permission to hold contact details for all clients of (insert business name as filed with the General Data Protection Register)

To comply with the current legislation on data protection we must tell you what personal data we hold about you, why we hold it and have your permission to retain it.  We store data about clients to ensure we can contact them by mail, telephone or email:

  • in an emergency
  • about booking reminders
  • our regular newsletter
  • any special offers

You can opt-out of any marketing contacts if you wish by ticking the appropriate box on the form below.

Any data we hold will not be provided to any other person or business except as required by law.

  • You may request to see all the personal data we hold on you (we are allowed 30 days to provide it)
  • We only keep your data for the reasons outlined above
  • We destroy your data if we have had no contact with you for (x) years
  • For the smooth and efficient running of xxxx kennels we need to keep a record of
    • Your name
    • Your Address
    • Your landline and mobile telephone numbers
    • Your email address
    • Contact details of another responsible person in case of emergency
    • The details of your pet/s
    • The name and telephone number of your veterinary surgeon

For us to be able to hold these records we need your permission so please complete this form and hand it to our receptionist.

Your full name: ­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­­_____________________________________

Your email address: __________________________________

I agree that ( xxxx kennels) may contact me, my veterinary surgeon or my named emergency contact as necessary

In an emergency

To remind me of appointments/bookings

Our Newsletter*

About offers and services which may be of interest to me*

*I understand I can opt out of further marketing contact at any time on request.

Signature ___________________________________

Clients must tick the first two boxes.  Ticking the subsequent boxes is optional

 

David Cavill is a Fellow of the Royal Society of Arts and of the Institute of Directors, Studies Coordinator of the Animal Care College (www.animalcarecollege.co.uk) and wrote the College’s Diploma of Kennel Management.  He has managed a very large boarding kennels and cattery and owned a small kennel and cattery too.  He edited, revised and finally rewrote Sheila Zabawa’s Running Your Own Boarding Kennels, published by Kogan Page now, in its fourth edition.  He administers a series of information sites for the pet industry which include http://www.iboarddogs.uk, www.igroomdogs.uk, http://www.itraindogs.uk  and http://www.ibreedpedigreedogs.uk

 

 

Will the new restrictions on Dog Breeders be effective?

Posted March 20, 2018 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for anmals

All human progress depends on over-reaction – Libby Purves

On the other hand you may also like to consider the relevance of:

Many a good argument is ruined by some fool who knows what he is talking about – Marshall McLuhan

As chairman of the Pet Education, Training and Behaviour Council (PETbc) I am a member of the influential Canine and Feline Sector Group (CFSG) which brings together the main participants in the pet welfare quadrille who have provided the foundations of the largely excellent animal care and welfare legislation in the United Kingdom.  The CFSG includes all the major charities including the Kennel Club and the Governing Council of the Cat Fancy among other smaller players.

You will no doubt have noticed in reading that first sentence carefully that there is a touch of scepticism embedded within it.  I should therefore make clear that the ‘excellent animal care and welfare legislation’ phrase is accurate.  The UK has led the world not just in pet animal care but, largely through the Universities Federation for Animal Welfare (UFAW), in the welfare of animals used in scientific research too.  By and large the rest of the world has played ‘catch up’ so however much the charity lobby groups press for further reforms it is not for lack of achievement.  At the same time I use the reference to quadrille (an old and well-choreographed dance) because almost all these ‘stakeholders’ have their own focus and agenda, one aspect of which is to ensure there is enough money coming in through charitable donations to pay their staff (some senior staff are very well paid) and keep the organisation afloat.  They therefore come into the political arena with trolley loads of baggage from their trustees (and the committed senior officers – whom the trustees have appointed) which often makes agreement on the direction of progress a battle between different factions.

In some instances one might come to the conclusion that the legislation which has been passed by government has been in spite of rather than because of the commitment of the major players.  At the same time, the vast majority of smaller organisation live very much ‘hand to mouth’ so that the large ones, just like large companies, tend to mask the competition and through their superior marketing and advertising generate income at the expense of the smaller charities.  This means their views, and the views of individuals, hardly get a look in.

So although much progress has been made – the 2006 Animal Welfare Act which has resulted in the secondary legislation currently being introduced and which should be in place by the end of 2018 is an excellent example – there have been spectacular failures, particularly in in the legislation surrounding dangerous dogs and the various attempts to formally regulate the breeding of dogs.  Leaving the question of dangerous dogs aside for the moment (those of us who believe we may have some answers have never been listened to either by the stakeholders or by the government), the question of breeding and puppy sales has been the subject of immense media interest since Michael Gove, the responsible minister at the Department of the Environment, Food and Rural Affairs (Defra) announced that the new statutory regulations being brought in later this year will finally solve all the problems.

I am afraid that it will not.  To complicate matters many Stakeholder experts and lobbyists have convinced both many MPs and the media that the legislation is much too complicated and while this is certainly true the simplistic answer they are putting forward, Lucy’s Law (the idea that third-party sales of dogs would be illegal), is unlikely to work either.  Incidentally, the Kennel Club supports Lucy’s Law and has signed up to the criteria for the new statutory legislation.

It must be stated categorically that the objective of both sides should be commended and supported, for its aim better protection for puppies and bitches.  No one disagrees with the aim; it is just that in practice, neither will be effective.  Incidentally, Mr Gove also announced that Defra was ‘exploring’ the question of a ban on third-party sales and has called for evidence: I would be prepared to make a substantial bet that this is a sop to the lobbyists and will simply not happen.

An argument built on sand

A pro-Lucy’s Law barrister, Sarah Clover, has argued very cleverly in its favour but unfortunately she has built her foundation on previous effective legislation controlling smoking and, to a lesser extent, drinking.  Her view is that the banning of third-party sales of puppies would have similar support but apart from her opinion she has no evidence for it and in any case, the circumstances are quite different.  Unless they smoke, most people dislike smoking so lighting up in a restaurant or any other public place is immediately frowned upon by the majority of people who are affected: peer pressure is what has ensured the success of the smoking ban.  People who come into contact with those who drink too much do not generally approve either: their comfort zone is being invaded and they have general support for the law regarding drunkenness and underage drinking.  In public, both situations are offensive but this is simply not relevant for somebody buying a puppy.

Buying a puppy is not offensive: in fact the vast majority of people love puppies.  Buying a puppy is a positive and emotional process which is fundamentally integral to the lives of many families and as most people are not disturbed by barking, fouling or biting (for most dogs behave remarkably well) then they would view Lucy’s Law as interfering and irrelevant: they would simply not report it.  Think about it – why would they?  Her other contentions also do not stand up to scrutiny because all that would happen if  Lucy’s Law were implemented is that the current ‘puppy traders’ who buy from ‘puppy farmers’ would simply change tack and become a ‘puppy breeders’.  We might also find that the current rescue organisations might even take the same route, as Lucy’s Law would almost certainly result in a considerable shortage of puppies to satisfy the current demand of approximately 750,000 every year.  As I have already implied, it is all about the money.

Three of the major stakeholders, BVA, Blue Cross and Dogs Trust support Lucy’s Law in principle (as do I) but recognise that its implementation is much more difficult than its supporters imagine and that the licensing system proposed by Defra has a better chance of achieving its objectives.

Are you ‘in the business of breeding dogs’?

Frankly, although I think that improvements will gradually occur as a result of this legislation in the long term it will not be fundamentally any more effective than previous attempts.  The main reason is that of complexity and omission.  For instance you may have noticed that in statements and rubric the government always use the phrase ‘in the business of breeding dogs’ and never ‘dog breeder’.  The reason for this is simple and straightforward: a breeder will not be considered to be ‘in the business of breeding dogs’ unless they breed three or more litters in a calendar year.  I have urged stakeholders to consider the idea that the criteria should be based on the number of puppies rather than the number of litters because three litters of Labradors may easily result in twenty or more puppies whereas three litters of Pomeranians may only result in six, so the ‘business’ is in no way comparable.  Not that it would make any difference in my opinion – but it would be more rational.

The criteria demanded of breeders ‘in the business of breeding dogs’ is very demanding and there is no doubt that even the most law-abiding amongst us will be tempted to try and avoid having to register.  This they will do.  In the same way as they avoid the Kennel Club regulation that a bitch should not have any more than four litters in her lifetime by occasionally adding an ‘extra’ bitch to a litter, they will register their bitches to the addresses of friends and relatives, only keeping and formally registering with the Kennel Club the ones that they wish to show or breed from.

Defra have also made it clear that they are not going to fund any of the extra work that is involved in in granting and checking licenses on the basis that the fees charged by the local authority will cover the costs.  If experience is anything to go by many local authorities will simply not bother and others will only pay lip service to the extra work involved.  It is relevant here to remind you that after a freedom of information request to a local authority recently, it responded that they had no licensed dog breeders in their area.  On examination there turned out to be over forty KC registered Assured Breeders, several of which bred a number of different breeds and should certainly have applied for a licence.

I very much hope that the raised profile of the importance of breeding sound dogs which has flooded the media in recent weeks will have an impact on the public’s perception of buying a puppy and particularly that they become more aware of the problems which occur in some Brachycephalic breeds which persist in those that supply the pet market despite the hard work that has been done by so many clubs and so many breeders.

It may be that I am becoming cynical in my old age but I am not holding my breath.

 

Lucy’s Law – is is feasible?

Posted January 16, 2018 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for animals

All persons ought to endeavor to follow what is right, and not what is established – Aristotle

 Perhaps a good New Year’s resolution would be to think before putting pen to paper or finger to keyboard.  Frank Jackson often used to use the writer’s trick of ascribing comments and conversation to his fellow drinkers at his local pub and it mattered not that some of the ides were extreme for they were not going beyond the readership of his column and readers were happy to sit back and take their time to consider the whole argument which was eventually brought around to a common sense conclusion.  We in the world of dogs were cocooned in our own macrocosm ‘with very little to distress or vex us’. My goodness – those were the days.

The occasional news story around Crufts, serious though they seemed at the time, were just storms in teacups leaving little mark on the wider public after a few weeks. These days however, although storms usually remain of teacup proportions, the constant and often irritating sniping on social media provides fuel for whatever fire is being lit by responsible lobby groups and organisations, in their attempt to make an impact on the media and those responsible for taking long-term decisions. The fundamental problem appears to be that responses are no longer nuanced but are increasingly seen as black or white.  This may be because of the textual shorthand encouraged by the speed of emails, messaging services and Twitter, as respondents can no longer be bothered to write a proper reply.

It certainly sometimes seems that those receiving information via social media have not properly read the original message and I cannot remember how many times, in the interest of accuracy, I have had to correct quite serious misinterpretations of statements made when easily checkable facts have been ignored.  Such misunderstandings occur even in the real world of newspapers, and you may remember the furore raised by my article about the consistency of standards because many made the assumption that I was ‘against’ a particular feature of a breed when this was absolutely not the case or the point.  A further excellent example is to be found in an article on my weblog (www.davidcavill.wordpress.com) which attempts to define the difference between line breeding and inbreeding.  Because it is read regularly it comes up high on search engines but many questions which arise from people who have found the article, make it quite clear that they have not read it for the answers are almost always in the text.

The temptation to ‘keep it simple’ is not always the best option

What makes sorting through the detritus of various threads for those looking for genuine discussion or information so difficult, is the tendency for respondents to provide mostly oversimplified solutions.  I have long been of the opinion that success is more likely if you ‘keep it simple’ but there are some problems which are so complex and have so many implications that simplicity cannot provide the answer.  A very good example is the recent discussion about the sale of puppies.  I should first state quite clearly that I believe that a puppy’s first home is its best home and it is in the greatest interest of both the owner and the puppy to have been bought from a responsible and thoughtful breeder who has provided the best possible health, nutritional and social care and will provide excellent advice and after sales service.  There is no question in my mind that if this set of circumstances could be legislated for effectively much would be achieved.  I am sure that there are few who would disagree with the principle other than those who are profiting from the fact that government is not minded to consider Lucy’s Law which would ban the third party sales of puppies.

It seems so simple and the idea, originally developed by my friend Marc Abraham, has been taken up by many lobby groups, which include the Kennel Club, Battersea, many MPs and campaigners from Jemima Harrison to Peter Egan and other well-known personalities.  Understandably, the concept is having an immense emotional impact and a massive following on social media as well as being widely reported in the national press. This is not surprising for, to take a direct quote from Marc, and here’s clue to the considerations expressed in this article, ‘We are going to use the power of the mob’.

Despite this, I should also state clearly my admiration for Marc and his campaign team who have worked tirelessly at the highest levels of government to promote what is an excellent concept. However, I must report that despite the hype and apparent support of many parliamentarians, it is unlikely that such a law will reach the statute book in the foreseeable future for the government believes that the forthcoming secondary legislation to the Animal Welfare Act of 2006 due next year (2018) will significantly improve the current situation (please don’t ask me why I know because, unfortunately, the reasons are confidential, but I do assure you it is the case).

Which takes me back to my theme, for those prepared to put their head above the parapet and point out some of the many practical problems and unintended consequences of implementing the idea, however informed and professionally qualified they are, are pilloried, accused of supporting puppy farming and not caring for animals.  This can hardly be said of Dogs Trust, Blue Cross (or me for that matter) but sniping at the various reasonable and thoughtful comments which have tried to put some balance into the discussions, makes no sense and just adds to the hysteria.

Dogs Trust is on our side

The worry is that the sensible and thoughtful views of organisations such as Dogs Trust are swamped by the emotional rhetoric which is allowed to swirl about in social and national media.  You would not think it, but Dogs Trust has made it quite clear that it is in favour of banning third-party sales.  I quote an unequivocal statement direct from its website, ‘Dogs Trust wants to see an end to third-party sales’.  However, the policy statement goes on to explain in careful, unemotional tones, precisely why this might not be the best policy at the moment.  I need not go into detail here for you can find their statement and carefully explained rationale on their website

www.dogstrust.org.uk/news-events/news/dogs-trust-view-on-sale-of-puppies

Suffice to say that one of their key reasons for their stance affects us in the world of dogs directly for they say, ‘We believe that introducing the ban at this time is not wise as it fails to deal with the root causes of the problem – a woefully low supply of puppies from ethical sources and any such ban will simply drive the trade further underground and make enforcement harder.  As long as the supply of puppies from responsible breeders’ falls short of meeting the growing demand in the UK, dishonest breeders will breed dogs to increase profits and evade the law once again making enforcement even more difficult.  We already know that this is happening now.

Just think about it.  Those who attack the views of Dogs Trust have almost certainly not read the text of their statement.  Had they done so they would surely realise that for once, one of the big charities is on the side of responsible dog breeders.  They have not taken the easy option of joining ‘the mob’: they are suggesting that the decisions regarding puppy sales should be based on evidence not on what appears to be an easy option.  This sounds sensible to me: what a shame it is that so many keyboard warriors do not take the time to think the implications through.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

Smoke and Mirrors

Posted November 14, 2017 by davidcavill
Categories: pedigree dogs

The Animal Care College – caring for people caring for animals

 

Democracy must be built through open societies that share information. When there is information, there is enlightenment. When there is debate, there are solutions. When there is no sharing of power, no rule of law, no accountability, there is abuse, corruption, subjugation and indignation – Atifete Jahjaga (The first female President of the Republic of Kosovo and the youngest ever female head of state to be elected)

I would like to introduce you to one of my 21st Century heroes.  The name will not immediately ring a bell but nevertheless when you learn more about him you will remember the negotiations with which he was involved.  He is Yanis Varoufakis.  He has been described as ‘the most interesting man in the world’ and ‘an outstanding economists and political analyst’.  Born in Athens in 1961, Varoufakis was educated in Greece before moving to the United Kingdom, where he studied mathematics at the University of Essex.  He received a postgraduate degree in mathematical statistics at University of Birmingham, and a PhD in economics back at Essex. He began his career in academic economics, teaching at universities in the UK between 1982 and 1988 before moving to Australia, where he taught at the University of Sydney until 2000. He returned to Greece that year to teach at the University of Athens, where he led a doctoral program and was promoted to full professor in 2005. Following this, Varoufakis had periods of advising George Papandreou before moving to the United States to teach at the University of Texas.

He is a highly regarded economist with a worldwide reputation and made a name for himself particularly in the development of ‘game’ theory which applies to a wide range of behavioural relationships and covers the science of logical decision making in humans, animals, and computers.  The reason for this lengthy introduction is to make it clear that Yanis Varoufakis is not just highly intelligent but has spent most of his life studying the way in which people and organisations behave so is more likely than most be able to negotiate his way through complex and difficult situations.

Now let me introduce you to Larry Summers.  He is an American economist, former Vice President of Development Economics and Chief Economist of the World Bank, senior U.S. Treasury official throughout President Clinton’s administration (he became Treasury Secretary in 1999) before becoming Director of the National Economic Council for President Obama. He is a former President of Harvard University – so pretty big wheel in politics as well as economics.

Larry Summers and Yanis Varoufakis met at an hotel in Washington DC in April 2015 and had a long and interesting conversation.  Yanis had just become Finance Minister of Greece on the grounds that he was best placed to ‘solve’ the long standing economic crisis between Greece and the European Union – a Quixotic task if ever there was one. During the discussion Larry told him, ‘There are two kinds of politicians: ‘insiders’ and ‘outsiders’.  The outsiders prioritise their freedom to speak their version of the truth.  The price of their freedom is that they are ignored by the insiders who make the important decisions. The insiders, for their part, follow a sacrosanct rule: never turn against other insiders and never talk to outsiders about what insiders say or do.  Their reward?  Access to inside information and a chance, though no guarantee, of influencing powerful people and outcomes’.  He then asked the fundamental question: ‘Yanis, which are you?’

Hidden agendas

This information comes to us courtesy of Yanis’s book, ‘Adults in the Room – my battle with Europe’s deep establishment’, which describes the hidden agenda of Europe’s civil service and exposes what goes on in its corridors of power.  His attempt to renegotiate his country’s relationship with the EU, despite the simple logic of his arguments, floundered and ultimately failed on the rocks of hypocrisy, collusion and betrayal.

Despite the commitment of the EU’s founding fathers to the future of Europe as an open, honest and democratic organisation devoted to the benefit of its members (and there is no doubt that there are benefits) it is now a bureaucratic ‘Castle’ run primarily for those on the inside.  Yanis’s reply to Larry Summers was that although he saw himself as an ‘outsider’ he was nevertheless prepared to be an ‘insider’ if this would achieve this objective of a sustainable Greek economy.  His position was a classic ‘I would not start from here’ for Greece should never have been allowed to participate in the Euro to begin with, but his failure was as much to do with the authoritarianism and absolutism of the EU estate as it was to do with Greece’s governmental failures.  In almost 600 pages Yanis provides carefully documented details of the way in which every avenue to sensible agreement was blocked and Greece was locked into an ever more effective straitjacket of increasing debt.

He comes to the conclusion that the EU bureaucracy can be compared to a parasite which is out of control and will eventually destroy its host ‘bringing the whole edifice tumbling down’.  This may or may not be the case but the book is nevertheless a brilliant forensic analysis of the structures that make up the EU and is worth reading by anyone who wishes to understand the way in which large organisations function, especially when there is no external moderating influence on the interests of those ‘in charge’.

Complex structures of society

The dichotomy between art and reality has long fascinated me (as it has so many others – an early influence was Colin Wilson’s, The Outsider) but it was much later before I realised there was a similar dissonance between politics and reality too (as in the trials of ‘K’ in Kafka’s, The Castle and the tribulations of Henry Miller as he tried to make sense of human behaviour).  So, long before I was involved in the world of dogs I was aware of the complex structures of society from the caste divisions enshrined in law in India to the subtleties of our own class system.

I have therefore always seen myself as an ‘outsider’, instinctively distrusting those who take it upon themselves to tell others what to do or how to think.  I freely admit that this instinct has been modified over the years as I have gradually understood that the complexity of society is such that regulation is important.  It would be wonderful if everyone behaved appropriately but as Richard Dawkins points out so succinctly in The Selfish Gene, although there is an instinctive human ethos to cooperate in circumstances where the community is under threat, in most situations people are more likely to behave in their own and their immediately family’s self-interest.  As a friend of mine never fails to point out, ‘interests never lie’.  Therefore, despite my innate ‘outsiderness’ I do think rules are important but I also believe that they should always be rational, subjected to tests of fairness and justice within their context, should be tempered with common sense and amended quickly when necessary.

We all have responsibilities and it matters not whether one is an insider or an outsider, a government minister, a representative on a town or parish council, a committee member of a dog training or breed club, a KC Board Member or have ambitions to judge Best In Show at Crufts, we should be prepared to be accountable, to work within the rules, and accept that our motives might rightly be examined.  In a society where the freedom to comment and criticise is continually being extended through social media, we must be ever more aware that our actions may come back to bite us if they have not been carefully thought through or are not seen to be in the best interests of those for whom we are responsible.