00:00 Hello, this is the Windsor Framework Unpacked podcast with the Trader Support Service and HMRC. I’m Shanker Singham, I’m the Customs and Trade Policy Lead for the Trader Support Service and I’m joined today again by Doreen Crawford, who is the Stakeholder Manager for the Trader Support Service, and by Simon Pettigrew, who is the Head of Strategy and Stakeholder Engagement for Northern Ireland Customs for HMRC.
00:33 We reflected previously on the Windsor framework in the previous podcast.
We’re going to carry on looking at some common queries. We’re going to focus a little bit today on the IMMI process. We’re now a month in to the to the Windsor Framework go live process so we’re going to look at how things are going. We’re going to look at the IMMI. We’re going to look at the TGP, the traded goods profile. And we’re going to talk a little bit at the end about ICS2.
01:01 So with that, I will kick off on the trends that we’ve been seeing since the 1st of May and I’m going to ask first of all, Simon, to sort of reflect from an HMRC perspective. What are we seeing the trader communities doing? Are there any useful bits of information we can share with our audience today?
01:24 Yeah. Thanks, shanker. I think from our side, as we said in the last podcast, the new arrangement was planned to take effect on the 1st of May and those have now come into effect. And from what we’re seeing, there’s been no significant disruption to the flow of goods, which is incredibly positive. And from a systems perspective, HMRC systems are continuing to work as normal. So CDS and GVMS for example are continuing to work in line with the new arrangements which is which is really positive.
1:58 We have also started seeing businesses make use of the new facilitations that came in. So you mentioned the IMMI there, we have seen several thousand IMMIs being submitted since the 1st of May and a good proportion of those have been submitted pre-movement, which as we discussed previously, that means that once the goods are in Northern Ireland, there is no admin to do. There is no supplementary declaration, so it removes all of that administrative burden that the business had been facing up until now for those particular movements and it means that those goods continue to move tariff free.
02:32 So that’s a positive that is as I said, not across every movement. So we are still seeing that some businesses are starting to adapt to that and adapt their processes and make use of that. So I think I think this is really helpfully timed to start talking through some of the things that can help businesses make these changes and adapt to the new facilitations. We also have seen some businesses using the Trader Goods Profile and we are again looking to sort of use this today to try and help businesses understand how they can make the most of these facilitations to remove and sort of facilitate the administrative burdens that they’ve been experiencing so far.
03:17 Great, and Doreen, the Trader support service TSS, we’ve been obviously we support traders not only in the existing processes, but the Windsor Framework processes when they went live in May. Are there any things that you are seeing from the way traders are using the TSS system? Anything that would be useful?
03:38 Yes, we have seen a change, but it nearly feels traders wanted to see the 1st of May come to see how things dropped. You know, and really like another shoe dropping, to see if there were going to be any changes. How prepared were they for the changes? And post and parcels obviously was the mandatory kind of change that came in the TGP and IMMI etc. as we know was an optional simplification with Windsor Framework.
04:11 So, if I can address the post and parcels first because again we’ve got lots of queries coming in around posts and parcels and what does a trader do? And we did feedback to them that they should go and talk to the parcel operator first and foremost, and then if the parcel operator needed to use TSS, they would kind of come and contact us. Simon, what was your feedback there from HMRC around the post and parcel?
04:36 Yeah. Thanks, Doreen. So you’re right. So this was probably the most significant change in relation to the 1st of May, when the new arrangements came in for goods moving via parcels under the Windsor Framework. Just to remind sort of listeners the context we’re working in, obviously it brought a new arrangements for both consumer parcels and business to business parcels. So, for consumer parcels, those can move without any need for a customs declaration, without any safety and security declarations and without any tariff, as long as they’re moving by an authorized carrier. In terms of how that’s went since the 1st of May, that’s went really well from our side. And speaking with our parcel carriers, they’ve not experienced any difficulties there.
05:28 We’re seeing goods move and people are feeding back that they’re receiving their parcels for consumer parcels in good time which is really positive. One of the things that we have seen a little bit of questions coming back around, is around when that that route can be used. As we said, anything that’s moving through an authorized carrier can be used, but there are, as we discussed last time, weight limits on that route. So for a parcel containing a single item, it can weigh up to 100 kilograms, and if the parcel contains multiple items, it can weigh up to 31.5 kilograms. That is on the business to consumer route, those two weight limits apply.
06:10 So, worth bearing in mind that if you are moving a business to consumer parcel that is over those weight limits, so, we’ve seen some examples of people buying roof tiles to redo their house, or some other sort of heavy equipment that they’re using to sort of do home work etc. That wouldn’t be eligible to move under the consumer route. And in fact, the easiest route for those goods to move would then be under the UKIMS route, so they’d be eligible to move under the IMMI and would also be able to move tariff free because it’s moving to a consumer in Northern Ireland, so that’s definitely one of the things that we’ve seen a little bit of confusion about and I know we’ve done some work with TSS and making sure TSS advisors have the right guidance to advise businesses on that there.
07:05 So if, say, I couldn’t move it through my parcel operator because it is over that weight limit there and you’re saying you know, the best way to move it is with the IMMI. But again, I’d be having that conversation either the person I’ve bought the tiles off would be having that conversation with the carrier on my behalf, because you were getting the goods delivered into you, not the consumers. So again, it’s talking to that person you’ve bought the goods from who’s actually doing that delivery contract, that’s who have been having that conversation with, yes.
07:34 Yeah, that that’s totally right. So, the business who is supplying the goods and the people who are physically moving the goods, whether that is a parcel carrier as we would tend to see them as or a specific courier or freight forwarder, etc. whoever’s involved in those physical movement of the goods. It’s definitely something to have a discussion between those parties to make sure that we understand the quickest and most efficient route to move those goods and again to make sure the end consumer continues to receive those goods in a in a timely manner. So definitely would encourage the businesses involved in that supply chain to speak as part of that process.
08:15 The other side we said was around the business to business parcels. Where the arrangements that were in place for freight would also apply from the 1st of May, and that also includes the UK Internal Market Scheme and the IMMI where applicable for goods that are eligible. From our side, again, we have seen again goods continue to move. I think this was quite a significant change and we were very conscious of that from our side of things.
8:48 There have been some teething issues that we’ve been seeing in terms of businesses engaging with parcel carriers and some of the process, but we haven’t seen any indication of any significant disruption to the flow of goods. So we’re aware businesses are still seeing are still receiving the goods in Northern Ireland, but there may be some technical process issues in terms of engaging with parcel carriers and understanding their processes.
09:16 I think in terms of that, there’s a couple of things that we’ve seen emerge. I said, one of the things is businesses tending to use TSS for support and answering questions, but very, very conscious in the parcel scenario, TSS generally doesn’t support that movement. It would be the parcel carrier or express operator who’s moving the goods who’d be dealing with the customs process as part of their door to door service. So if you are moving or sending or receiving goods through a parcel carrier, I would really encourage you to speak with your parcel carrier to understand their processes and that’ll help you understand how they want to receive the relevant data, how they want to deal with any clearance instructions if the goods are at risk or not at risk, how they will obtain UKIMS, authorisations etc. and make sure the process is smooth and efficient. First, I think key thing I would suggest is if you are having any teething issues the first port of call should be the parcel carrier who’s actually moving the goods.
10:17 TSS and HMRC are obviously there to support on particular issues if there’s any need for clarification. But in terms of the process I would definitely encourage speaking with the parcel carrier. The second thing we’ve seen is around UKIMS, so, in the lead up to the 1st of May as part of our readiness campaign, we were encouraging businesses to apply for UKIMS as soon as possible and make sure that they were ready for the new regions coming into effect. We have seen in the lead up to the 1st of May and even after 1st of May businesses applying for UKIMS and we have tried to put out some comms to help businesses understand some key tips around making sure that process is smooth and efficient.
10:59 I think the big things I would say, are making sure that on your UKIMS application you provide as much information as possible about how you’ll make the determination the goods are for sale to or end use by a consumer in Northern Ireland, how you’ll hold that information in your records and make sure that is thorough and that will mean that the application goes through smoothly.
11:23 I would also flag that the biggest delay to applications currently is follow up questions and delays for businesses replying to follow up questions from HMRC. So, if perhaps you’ve not given all the information that’s required or it’s a little unclear in your application how you’ll make that determination, we might come back to you and ask for some additional information.
11:46 The time lag between getting that request out and receiving the information back has held up some applications, so I would definitely encourage you to look out for any follow up requests. Those requests will come via e-mail to the person who’s nominated themselves on the application form.
So please do make sure you’re looking out for them and responding in a timely manner. That way we can make sure that if you are applying for UKIMS you’ll get that as quickly as possible and start using that and make sure that mean that you’re eligible to continue move those goods tariff free and benefit from things like the reduced data set.
12:22 Couple of things to sorry, Doreen, just to unpack a couple of things from all of that. First of all, as we’ve said in the past and as we said in the previous podcast, this is not a with regard to IMMI and UKIMS, this is not a hard deadline in the sense that now we’ve gone beyond the 1st of May, you can’t change. So obviously we are encouraging people to continue to use these or to take advantage of these processes that exist. And as Simon mentioned UKIMS, you know you can carry on registering for UKIMS. I would point out in the current tariff environment around the world, if you’re moving things not at risk GB-NI, you’re insulated from that whole, you know, question and therefore it’s probably worth doing that and making sure you take full advantage of the of the not at risk category.
13:22 One other thing, Simon, on the parcel changes, and Doreen, you mentioned the importance of supply chain conversations, which is something we’ve stressed not only in this previous podcast but also in previous webinars, if you have, I mean you are, this is a group of people who are moving from one system, which didn’t really involve much process at all to a new system, and it may well be that there’s these goods of their business to consumer above the weight limit or business to business but they’re now moving as freight. So absolutely talk to your parcel, you know your FPO in the first instance but be aware that if things are moving as freight, there’s an existing process on the TSS that supports those movements. And we’re sort of very, very able to help people move their goods in a slightly different way from the way they’ve used they’ve used before, and simplifications do exist.
14:25 Yeah, I would agree there, Shanker. The change, the process is there, you know, it’s a change for people and it takes time for that change to embed in and to understand what the actual change means to your business or means to how we move goods and I think the one thing I’ve noticed over the last month is we have been given all this information for the changes and now all of a sudden they’re saying the changes come into play. It still is a big change to some businesses, but I think it’s very slowly dropping in that the changes actually aren’t as you know, a minefield as what they thought they were going to be.
15:09 You know, the more that we’re getting used to it and the more it’s becoming everyday practice, it is becoming easier for the businesses to apply them and the daily sort of like movement of goods into Northern Ireland, would you agree with that view?
15:25 I certainly would, I think what we are seeing as Simon, you know you talked about the statistics that we’re seeing and the people who are moving things. I think it’s pretty clear that there is take up of these new processes and I think you know, we’ll come on to talk about the TGP in a in a second, but I think our sort of overall reflection is look, these processes do make things more simple.
15:51 I mean if you’re moving something and you’re using an IMMI pre movement, then there is nothing that you have to do after the goods have moved into Northern Ireland and if you’re a consumer, importer, receiver of goods in Northern Ireland, that’s a significant benefit. So, we do think whilst there has been take up, I think there could be more and we will continue to educate people will continue to help people take advantage of these processes. And I think there is lots of advantage to be taken. That would be my reflection.
16:29 And just to add to that, Shanker, I think that’s right because we have, as we had seen some good take up of those from like early adopters who are making the change knowing that they were ready to take on that change and benefit from those new facilitations from the 1st of May. We are also still seeing some businesses who are maybe not changing their upfront process quite yet, again making sure that I think they weren’t sure or confident the system would work. So they didn’t want to risk any delays, so they’re still making use of these facilitations like the IMMI post movement. So they’re still not changing perhaps the pre movement side of things, but doing post movement, which means they’re still benefiting from the reduced data set and the tariff free movements. But again, that’s something that we are seeing businesses look to test whether that can shift to the pre movement side of things and they can then remove the admin post movement as well, so
I think we are seeing businesses test with what works for their supply chain and how best to benefit from these things now they are in place.
17:33 I’m going to agree with that, Simon. So I’ve been watching the TSS processes in the portal over the first four weeks and just to see what happened, how was it landing with our users? Because it was a big change for a lot of people and you know, we never got into really a settled state. So we’ve seen early adopters, who were really prepared, put a lot of work into this and we’ve seen that being really effective for them straight off the bat. And the only thing the businesses who were moving, were asking questions and had their UKIMS in place and we’re really confident their goods will remain in Northern Ireland.
18:15 So they started looking at using SPIMM because that was one of the other things a lot of questions we get is you know, if I’m using SPIMM and I’m creating an IMMI and I decide that the goods are going to be at risk after the point and we’re going no, you need to be 100% sure before you start this process these goods are being moved correctly.
18:36 And once we get the confidence and the businesses have confidence that they know exactly how all this works, we’ve seen them do that post movement conversion. So, that’s when they move the goods as normal and then they get the declaration at the end, and they then convert that to the internal movement information record and that’s where they use that reduced data set. And we’re seeing traders nearly like cherry pick at this, and they’ll do one and then maybe over the next week, then maybe try 3, doing it like that. And then they get a wee bit more confident with it. And they actually then maybe go in and they try their Trader Goods Profile and they have a conversation with the support team here within the TSS and we show them how the TGP then can be used to populate that information so they don’t have to type. So then we see them maybe use a TGP in one out of their five or six entries that they’re filling in, and it’s again, we’re seeing this over the last four or five weeks, that confidence being gained.
19:39 So we’ve seen them try a few sup decs. We’ve seen them get those and have confidence in how that works for them in their business. Then we’re seeing them using their TGP to fill that in.
And now actually we’ve seen a few businesses in high numbers actually now moving this to pre movement because they have the confidence that the process is working they’ve been able to set up their business and collect the information where it’s needed and worked with their hauliers and they’re now able then and we’ve seen it successfully happen and the numbers are increasing for these particular traders where they’ve nothing to do post movement because it’s now all happening.
20:20 Now we are helping them maintain their TGP and they’re still, I’m not saying it’s perfect, but it’s really interesting to watch that confidence grow and when we’re talking to them, they’re saying that they were quite unsure, but they can see now where this has been really helpful. And they are saving time now whenever they have actually put it into practice. So, I thought that was a really interesting journey. Have you heard other tales of that, are you seeing it with the FPOs?
20:52 Yeah. I think on the point around parcels, I think obviously again, as I said, it was more of a significant change on the B2B parcels. So I think the priority was obviously just making sure goods weren’t significantly disrupted, which has been met, and I think now parcel carriers from our discussions with them are looking at how they can make their processes smoother.
21:17 So we’ve fed back some feedback from businesses on things like that and they are now looking at how they can make that process as smooth. So they are again in that same process as you say, making sure the system works, making sure goods keep moving, and now trying to figure out well, how can we make it as efficient as possible with knowing our customers and knowing how customers use their services.
21:41 So I think I think that’s quite right across the spectrum, people who are extremely ready, extremely confident being able to adopters, and the same in most worlds, where we’re making use of that upfront and from the 1st of May, when it went live and we are now seeing people starting to make greater use of these things. So yeah, I think that’s kind of replicated across the spectrum.
22:06 So I think the key take away from this section is you know, early adopters are taking advantage of these processes. Changes is always difficult. But you know now you know that the system is working. You know that early adopters are taking advantage of it. People are benefiting from it and therefore, I think if you’ve, if you’ve been a little shy about dipping your toe in the water, I think now is the time to jump in.
22:34 So with that, let’s you know, let’s talk a little bit more about the Trader Goods Profile because we did a series of webinars about this. We did talk about this. It’s a significant facilitation that HMRC has created so that traders can sort of make these movements more easily. They can store their data more easily, and there’s a lot of TSS population of data and other things that we do with the TGP to make sure that the process is as easy as possible. Doreen, do you want to just talk a little bit about the TGP now?
23:12 Again, the team have got a wide range of calls around TGP and the use of it since the 1st of May, so again just to address some of those pitfalls that and it’s not pitfall, it’s just really getting users to set it up correctly and it’s setting up the TGP within HMRC’s website, giving access to the TSS and making sure that you’ve registered under the CDS system as well with your UKIMS, that all those authorisations are all set up and linked. And again, if you’re not sure, phone in to the TSS and we will walk you through it and give you a hand to make sure that it all links nicely and all the systems to talk to each other.
24:01 So that’s one of the first kind of steps that we’re saying we get lots of questions around. And we’ve done lots of work in the background, but now people are trying to put it into practice.
And we’re more than happy to support there and get you set up correctly so that you can use it.
24:18 Then once they have their TGP, we’ve put in little tips and tricks and you’ll hear us ask talk to each other and we use this phrase ‘Are you IMMI ready?’ And it’s that there record that you’re creating for that there movement on the TSS, it will say if you’re ready and your records have been set up correctly it says true. So you know that your information has been set up and it’s been recorded correctly. Once you see that there are record saying true, you are ready to use that within any of your movements that are remaining in Northern Ireland under the SPIMM simplifications.
25:00 So that was the first thing, the set up and I’m sure, Simon you’ll agree that’s where we’ve seen a lot, a little bit of there was getting those setups created. For the TGP and the two systems talking to each other, yeah?
25:18 So yeh Doreen, I would definitely agree. I think that is definitely one of the things that’s important to make sure businesses have taken the necessary steps to make sure they are ready to use that so giving the relevant permissions to TSS, ensuring anyone who’s accessing the Trader Goods Profile on their behalf, so perhaps that haulier customs agent, for example, have access to it, and indeed enrolling with CDS. So, taking those steps before the TGP is used is definitely an important thing to make sure businesses are doing.
25:53 So, Doreen, you know on the TGP as Simon sort of mentioned it just now, in a sense the TGP sort of operating as a sort of, or could operate as a way for people to have these conversations that we keep encouraging them to have between hauliers and suppliers and receivers and so on of goods.
How do you see those conversations occurring and also talk a little bit about the, you know, there’s a lot of different systems that we’ve been talking about and I know we have a tendency to sometimes confuse people with the number of systems that we’re talking about, but sometimes these systems interact in ways that are really good for the trader, right?
26:32 So you talked about the TSS. There’s traders ensuring that the TSS has access to their TGP, ensuring that the haulier has access to their TGP. You know, talk a little bit about how you know those can be used to make the overall process that you have to go through to move goods from GB to Northern Ireland a lot smoother.
26:52 Yeah, so the fact that we have the two systems and they contain information that’s interchangeable between the two, because that’s how it’s been built and that the information is actually a foundation for core information within the record for the movements of the goods into Northern Ireland. So if you’re a business Shanker and say I am a supplier into a business in Northern Ireland, and I supply say candles, and candles into a gift shop, and I send this the same kind of candles on a regular basis.
27:37 So rather than me having to sit and type this out, I can update my TGP because the systems have been set up to talk to each other and the systems have been set to really let you put in your commodity code, you’ve got help from the HMRC systems there within the TGP you can categorise your goods within that again with support from the digital support from HMRC. And when that information classes into the TSS. Because you’ve given all the authorisation.
28:08 Within the TSS we’ll check the information for you as well to make sure that it that aligns and that means you only do it once and that information passes backwards and forwards and every time you move your candles you can hit the little tick box within the TSS portal that says do you wish to use TGP? Yes. And then you pick what candles it is that you want to pass across and that will just put all that information for you all of the time. So, you never have to type in those ten fields that you do every single time. With your commodity code and all the different fields that it’s going to collect and to make sure it’s got the right description and things like that because it’s already in your TGP.
28:56 The other thing is you can use your own goods description, can’t you? You can. You don’t need to use a pre sort of you know pre cooked one, you can sort of use whatever one you’re familiar with and use in your own business. So you know, I suppose one way to look at TGP is for those people who are regularly move goods, it’s almost like traders master data, isn’t it? It’s something that sits there and enables you to repeat movements and so on without having to do things you know all over again.
29:28 Yeah, it’s nearly like you can use your internal stock numbers, you know, so you can match this up really easily. And you know those trade, you call them a skew number, etc. And again, you can use those within the TGP for ease for your own reference and it will pull in that the commercial you know
customs description for you. So no, HMRC has tried to build this to be as usable as possible and again with the two systems talking to each other, we can interchange it.
29:58 And I suspect it’s the kind of thing that over time will get more and more valuable and more and more useful. So with that, let’s talk about ICS2 and obviously there are changes that are coming, you know, many of these changes have, you know, nothing to do with the Windsor Framework they’re just changes that happen in the world of customs, you know, generally. And ICS2 is a European change that is a change to the European safety and security system. Which does apply in in Northern Ireland, so you’ll be familiar with the old ICS Northern Ireland system.
30:32 We’re moving to ICS2, which is a new system which has slightly different requirements. So, Doreen, do you want to just talk about and Simon also just talk about some of those changes and those new requirements. That we have there and particularly I think for the purpose of this discussion how some of the things we’ve been talking about earlier on, particularly the TGP, can be helpful to hauliers and others who have to satisfy some of these new commitments.
31:04 Yeah, so the introduction of ICS2, as you said, is not connected to Windsor framework but there is an interesting synergy, I’m going to call it synergy, between what is required and what has been created by HMRC for the Trader Goods Profile. And it’s the fact that the commodity code and goods description are now required going to be required as part of the ICS2 data that’s going to be collected when the goods move into Northern Ireland. So ICS2 is a system that kind of collects information and we call it the Entry Summary Declaration here in the TSS, or externally it’s also known as the Safety and Security Declaration. And it’s basically it tells you what the very distinct level of what goods are moving. And who’s moving them and when they’re moving?
32:03 So it’s basically the carriers, the shipping lines, the hauliers would be responsible, the air companies etc. are responsible for all this information going across borders. And it’s not customs information per se it’s again, it’s just information about what’s moving across. So now with ICS2 there is additional information that’s going to be required for goods moving into Northern Ireland and that’s going to be a six-digit commodity code. Whereas if you’re moving standard goods using any of the SPIMM benefits for the reduced data you’re already getting the standard good six-digit so straight away you can, your TGP if you’ve set up will help feed that information to your haulier.
32:46 Goods description is going to be required. Again, that goods description has already been set up in your goods profile if you have one, and so you’ll be able to take a benefit from that to fill in that information on ICS2. If you’re using the TSS, you need information about the carrier, their EORI, name and address, you need consignee consignor importer exporter. All information that’s collected.
And it’s now some of it’s now mandatory for ICS2. The TSS is going to try and help you populate that and again automate it as much as possible and to make it as simple as possible.
33:27 So again, we have a webinar. Actually, there’s one later on today and we have another one.
So this is the 3rd of June. We’re doing this recording guys and there’s one today. So go back and watch that recording. It will be in the NICTA website and we have another one for actually using the TSS portal and it’s in early July. So keep an eye out on exactly what to do in the portal and that’s really important for hauliers especially. Because they are naturally the people that fill in that information.
33:57 Simon, again, if I could bring you in there, the hauliers are responsible for what we call their Entry Summary information. And again, this is where ICS2, again, is for encouraging those conversations to happen in the supply chain for this additional data. Again, would you encourage that and follow that on?
34:24 Yeah, definitely. I think this brings into a really good focus at those conversations do need to happen as I say. The data that’s required for the goods movements are sort of broadly aligned as a six-digit commodity code which is aligned with standard goods on the IMMI good description, which is on the IMMI. I think the big difference here is when that’s given in the supply chain, I said the hauliers will need that before the goods move.
34:50 And obviously, it’s not the hauliers responsibility to classify the goods, although they are the ones who, for RoRo movements, be submitting the Entry Summary Declaration, as you see, they don’t own the goods. So they will need those conversations with the supply chain to make sure they received the relevant data to make sure goods continue to move smoothly and efficiently. So I would definitely make sure that you are having those conversations with your supply chain. Make sure they have the routes to get the data. And as we said, TGP is a really helpful route to get that data because you don’t have to do on a per movement basis, you give them the good description that links to your profile and all of that information like commodity code like other things as available and all you would have to give them on top of that is like the standard commercial information they would do anyway.
35:39 And as you say that could also help businesses with the transition to think about how this works with the end to end process of oh well, right now having done the IMMI pre movement, in fact if I’ve got to give that data up front to TSS or to HMRC can I do that IMMI pre movement and how can I then make sure that the relevant people have the data to do that so would I do that as a business who is sending goods and give the information to the haulier would my haulier or a customs agent be doing that on my behalf? How does that all the work? And who has the relevant information to make sure that that is all in place?
36:19 So I think it really just goes to show I think those conversations as we were saying before 1st of May are also really important to make sure that they’re happening ahead of ICS2 coming in. Which I’m not sure if we said the date but just for awareness, the end of the deployment window is 1st of September for ICS2 so need to also make sure businesses are sort of cognizant of that date to work towards.
36:43 So if you’ve got a TGP and you allow TSS, you know access to it, we can make the process for using IMMI and SPIMM a lot easier. But if you make your TGP available to the haulier, you can make the process for ICS2 a lot easier as well for the haulier, so you know, as Simon said, you know, this is all about data; who has it, when it needs to be transferred and you’ve now got a data repository that you can kind of use for that. So that’s why we’re strongly recommending people take full advantage of the of the TGP.
37:19 Well, thank you very much Simon and Doreen. I think the major take away from this is, take a look again at the simplified processes. Just make sure that if you can take advantage of them, you are taking advantage of them. Make sure you’re taking advantage of the TGP and have an eye on September and ICS2 requirements coming in and do look at our webinars on ICS2.
37:44 So that’s all from us in the Windsor Framework Unpacked Podcast series. I’m Shanker Singham.
Thank you. Doreen Crawford and Simon Pettigrew for your contributions today.
