Lord Ravensdale Portrait Lord Ravensdale (CB)
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My Lords, I declare my interest as a chief engineer working for AtkinsRéalis. I shall speak to Amendment 82.

In our debate on group 3, a lot of good points were made about one specific technology related to cyber: AI. However, as the noble Lord, Lord Birt, said in the debate on the previous group, quantum is the other area that needs attention as a specific technology. When I started here around seven years ago, I never thought that I would one day be talking about quantum mechanics in your Lordships’ House.

I recently heard the story of Heisenberg and his discovery of the uncertainty principle, almost 100 years ago in 1927. He was out in a park late one night, after a long argument with Niels Bohr, and he saw a row of street lights. He saw a person walking in between the street lights late at night. He would see them go past one light—you would be able to observe them—and then they would disappear into the darkness and they would then reappear at the next light. He realised that he could use that analogy for the behaviour of the electron: as it was being measured, it was there as a particle, but, when it was not being measured, it had to be considered probabilistically because you do not know where it is. In the same way, with a quantum computer, the value of the qubit, as it is called, is locked in only when it interacts with a measurement device.

This extraordinary powerful technology is now emerging. As an example, the Willow chip, which has recently been developed by Google, completed a benchmark calculation in five minutes. It would have taken the fastest classical computer in the world 10 septillion years—that is 10 with 24 zeros, I believe—to complete it. According to the Parliamentary Office of Science and Technology and the NCSC, in less than 10 years—perhaps even sooner than that—we could have a cryptographically relevant quantum computer that uses Shor’s algorithm to decrypt all communications that rely on the RSA algorithm on which we have relied for decades for all of our bank transactions, state-level communications and so on. This is an area of technology that is moving extremely quickly, and it is not just one about which we will have to worry at some point in the future. So-called “harvest now, decrypt later” attacks could be used to decrypt sensitive information in the future.

That brings me to the amendment. It is quite a simple, straightforward one, which goes forward from the discussions on how, given the changing nature of these technologies, it is perhaps not appropriate to have specific technologies and timelines in the Bill. However, as the Minister has already brought out, the statement of strategic priorities is a powerful tool to ensure national join-up, including across those regulators within the remit of the Bill.

We have 12 regulators and each one could approach quantum crypto—so-called post-quantum cryptography—differently. There will be huge benefits in really ensuring that regulators work from the same national signal rather than inventing their own PQC expectations individually. That would also allow them, if it can be brought out in the statement of strategic priorities, to plan their inspections, guidance, skills and capacity around the NCSC timelines, which is a plan ranging from 2028 discovery and initial plan through to 2035 when post-quantum crypto implementation is completed. That will also help with all those newly in-scope firms that will be coming within the remits of this legislation, giving the regulators a legitimate basis to raise post-quantum crypto with those new organisations early on.

I read back the Minister’s remarks at Second Reading, when she said that quantum crypto

“would be considered as part of that requirement by regulated entities, but would not necessarily be singled out as a specific technology in the regulation so that we keep these regulations up to date and matched to the cyber risks that individual entities face”.—[Official Report, 14/7/26; col. 622.]

I believe that this amendment would help strengthen and deliver exactly that. With that, I look forward to hearing from the Minister on her thoughts about this approach.

Lord Clement-Jones Portrait Lord Clement-Jones (LD)
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My Lords, I will speak to this substantial and rather disparate group of amendments, including Amendments 93 to 95 in my name, Amendment 10 tabled by my noble friend Lady Ludford, and a number of other amendments in the names of other noble Lords, including that of the noble Lord, Lord Arbuthnot, who, sadly, is in the Chamber as well.

Under Amendment 10, comprehensively introduced by my noble friend Lady Ludford, we would ensure that digital service providers manage risk arising from AI-driven fraud which, as she explains, represents over 40% of reported crime in England and Wales. I thought she made an extremely convincing case and I very much hope that the Minister takes what she said to heart and adds the very few words that are required to make this Bill much more secure with regard to the kind of phishing activity that she described.

As regards the various amendments relating to skills, beginning with the workforce and competence deficit, in its latest 2025-26 workforce study, ISC2 reveals that 52% of UK cyber professionals identify skills shortages as their single greatest obstacle to regulatory compliance, with 58% of organisations facing critical skills shortages. Regulation without competence is what might be described as pure compliance theatre. That is why, on these Benches, we strongly support Amendment 15 in the name of the noble Lord, Lord Arbuthnot, which would place a direct statutory duty on regulated organisations to ensure that their security leads possess verified competence, alongside Amendment 114 from the noble Lord, Lord Holmes, which would require the Secretary of State to define the objective qualifications and independent criteria for appointing skilled persons.

We also see critical implementation blind spots in distributed infrastructure. In July, as documented in the “Analogue 72” Green Paper, which I have mentioned before, a small UK electricity generator was taken offline for four days following a suspected state-sponsored cyber attack. Because it fell below the statutory reporting size threshold, local responders had zero visibility of the disruption. If small distributed energy assets are paralysed, the compound threat to local grids is severe.

Amendment 82 tabled by the noble Lord, Lord Ravensdale, rightly addresses quantum decryption. I am afraid that, if we are not careful, we are back in the territory of technology agnosticism. I think that across the Committee we have a fundamental disagreement with the Government about that. Hostile states are actively executing “harvest now, decrypt later” operations. By requiring the Secretary of State to incorporate NCSC post-quantum cryptography timelines into strategic priorities, we would mandate preparation for quantum-resistant encryption across all critical sectors. We very much support the amendment tabled by the noble Lord, Lord Ravendale.

Amendment 93 in my name would introduces mandatory eight-week public consultations before secondary regulations or codes of practice are issued, protecting industry and SMEs from closed-door administrative creep. I think that is the kind of area where the Minister could give further assurance.

Amendment 94 in my name would establish a statutory presumption of conformity for organisations achieving ISO/IEC 27001 or Cyber Essentials Plus certification. This safe harbour would eliminate legal ambiguity, reward gold-standard cyber hygiene and free regulatory resources to focus on high-risk, non-compliant entities, while preserving the regulator’s right of rebuttal. As the Minister can imagine, this has considerable industry support.

In Clause 40, my Amendment 95 would shorten the legislative cycle from five years to three years. We also support the alternative in Amendment 95A from the noble Lord, Lord Arbuthnot, which probes an even tighter two-year window, and his Amendment 95B, which I have signed, which would ensure that future statutory reviews must explicitly assess third-party and supply-chain dependencies originating outside the regulatory perimeter. Furthermore, we support the noble Lord, Lord Arbuthnot, in his proposed new Clauses 174C and 174D mandating competency standards and annual workforce strategies—we are just sorry that he is not here and able to speak to those amendments—alongside Amendment 92B from the noble Viscount, Lord Camrose, requiring large businesses to report transparently on their cyber resilient plans.

We have not heard from the noble Viscount regarding the other Conservative Front Bench proposals, but we are sympathetic to the need to review information sharing and analysis centres, ISACs, under Amendment 169 and to expect clear regulatory funding plans under Amendment 174. Furthermore, holding the Government to their commitment under the National Audit Office’s 2025 report and the Cyber Action Plan, under Amendment 170, is important. However, we are less supportive of Amendments 173 and 175, which attempt to make commencement of the entire Act conditional on publishing the National Cyber Action Plan. In our view, that would potentially create a dangerous delay, holding our national resilience hostage to Whitehall paperwork when our hospitals and utilities need protection today.

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I thank noble Lords for their amendments, which touch on many aspects of implementation of the regime.
Lord Ravensdale Portrait Lord Ravensdale (CB)
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My Lords, can I clarify the Minister’s response to my amendment? She stated that the statement of strategic priorities should not refer to specific technologies, implying that it is difficult to change. The reasoning behind my amendment was precisely because the statement of strategic priorities is a more flexible instrument than having these targets in the Bill. I think there is no question of the threats posed by quantum cryptography and the need for better join-up. Can the Minister clarify her comments on the statement of strategic priorities?

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Lord Arbuthnot of Edrom Portrait Lord Arbuthnot of Edrom (Con)
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My Lords, I apologise for having spent less time in Committee than I would have liked, but I have been speaking on the Public Office (Accountability) Bill. I am grateful to those noble Lords who I suspect have been speaking to amendments on my behalf.

Amendments 15A and 15B are about the designation of critical suppliers. New Regulation 14H says:

“A designated competent authority may designate a person … under this regulation if P supplies goods or services directly to an OES for which the authority is the designated competent authority”.


The Bill expands this regime to cover additional organisations and creates a new framework for designated critical supplies. That is good, and it recognises that essential services depend on organisations that go far beyond the direct infrastructure of the critical organisation itself; everything is dependent on everything else. However, the critical supplier test is focused on suppliers providing goods or services directly to a regulated organisation. That ignores the concept of a supply chain with several tiers of suppliers. These amendments are intended to address that. Therefore, I beg to move.

Lord Ravensdale Portrait Lord Ravensdale (CB)
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My Lords, I will speak briefly to my Amendment 16. In my view, the central problem is that, if I am small or medium-sized firm, I cannot currently tell with any confidence whether I am within the scope of the Bill as a critical supplier. Small and medium-sized enterprises are the lifeblood of our economy, and we need to approach with caution any ambiguity around their inclusion in the Bill. I took note of what the Minister said at Second Reading, when she said that:

“They can be regulated if they are designated as critical suppliers, for which there will be a high bar for designation”.—[Official Report, 14/7/26; col. 622.]


That was helpful, but what exactly is that high bar?

To give noble Lords an example of regulation legislation that is not defined, I come back to one noble Lords are likely to be familiar with: the infamous IR35. With that, the uncertainty and costs of getting it wrong were high in the regulation, so firms applied a blanket under which everyone they engaged with had to be inside IR35 and had to be treated as an employee. IR35 addressed a real problem, but the test was judgment-heavy and getting it wrong was expensive. That was why many organisations stopped making case-by-case decisions and applied a blanket policy, which meant that far more were caught by the regulation than was intended. I remember many years ago, as an engineer, spending a lot of time trying to fill in IR35 determinations and not doing engineering, which was a frustration at the time. It led to many issues with finding the right new skilled resource that we required to undertake the work.

I am sure that the Minister will say that the criteria will be set out in secondary legislation, but there will be a long period of uncertainty, and the IR35 example helps illustrate the risks. I took a look at the impact assessment and some of the costs were laid out. For example, if a firm is within the scope of this legislation, it is looking at physical security costs of perhaps £114,000 and cyber security spending—potentially of £190,000 a year. The impact assessment could not say how many SMEs may be designated within this legislation. All of that uncertainty is a cost, because it means that, if firms are uncertain about whether they are going to included, they may delay investment. In fact, they may overprepare; they may take on additional costs, which has wider implications to the UK economy, or they may walk away from public services. They will not want to go for these contracts because of the risk they may fall under this legislation, and that could potentially cause the same grit in the wheel of the economy that was seen in IR35. There is a case here for providing in the Bill at least some additional definition on what a critical supplier is; that is what my amendment intends to do.

English Football: Independent Regulator

Lord Ravensdale Excerpts
Monday 25th April 2022

(4 years, 4 months ago)

Lords Chamber
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Asked by
Lord Ravensdale Portrait Lord Ravensdale
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To ask Her Majesty’s Government when they plan to introduce legislation to create an independent regulator for English football.

Lord Parkinson of Whitley Bay Portrait The Parliamentary Under-Secretary of State, Department for Digital, Culture, Media and Sport (Lord Parkinson of Whitley Bay) (Con)
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My Lords, the Government have endorsed the principle that football requires a strong independent regulator to secure the future of our national game. I am pleased to say that we will publish the government response later today, where we will set out plans to reform radically the governance of men’s football in England, accepting the 10 strategic recommendations of the fan-led review. Any legislation required to put an independent regulator on a statutory footing is of course subject to parliamentary time.

Lord Ravensdale Portrait Lord Ravensdale (CB)
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My Lords, as a supporter of Derby County Football Club, who as a team have shown tremendous spirit again adversity in the past months, I followed the fan-led review closely. Does the Minister accept that the time to legislate for an independent regulator is now, in the forthcoming Queen’s Speech? Further delays will add to the risk that the proposals will be watered down or simply not happen. What plans do the Government have to introduce a shadow regulator before legislation takes effect, which was also one of the key recommendations in the fan-led review?

Lord Parkinson of Whitley Bay Portrait Lord Parkinson of Whitley Bay (Con)
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As the noble Lord will know, the Government continue to engage closely with the English Football League about Derby County Football Club. Speaking so close to the gracious Speech, I hope that he will forgive me if I do not anticipate that, but the full government response to the fan-led review—which the Government commissioned —is published this afternoon. We have accepted all 10 of the strategic recommendations put forward by Tracey Crouch and the review. My honourable friend the Sports Minister will be setting out further detail in another place.

Covid-19: Broadband

Lord Ravensdale Excerpts
Monday 5th July 2021

(5 years, 2 months ago)

Lords Chamber
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Baroness Barran Portrait Baroness Barran (Con)
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The issues relating to being on the wrong side of the digital divide, as the noble Lord described it, are more complex than simply the tariff or how rent might be set up: they include digital skills and confidence, on which this Government are working very actively, as set out in our tech-savvy nation report.

Lord Ravensdale Portrait Lord Ravensdale (CB)
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My Lords, regions like the Midlands have both a strong regional partnership in place, focused on digital connectivity, and gaps in national digital rollout, which are stifling the economy. Will the Government prioritise region-wide action to accelerate digital connectivity, and will they work with the Midlands Engine to deliver on levelling up digital for the region—its local authorities, businesses and communities?

Destination Management Organisations

Lord Ravensdale Excerpts
Tuesday 8th June 2021

(5 years, 3 months ago)

Lords Chamber
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Asked by
Lord Ravensdale Portrait Lord Ravensdale
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To ask Her Majesty’s Government what assessment they have made of the role destination management organisations can have in support the recovery of the (1) national, and (2) international, visitor economy from the impact of the COVID-19 pandemic; and what support they are providing to such organisations.

Lord Ravensdale Portrait Lord Ravensdale (CB) [V]
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I beg leave to ask the Question standing in my name on the Order Paper and, in so doing, note that I am co-chair of the Midlands Engine APPG.

Baroness Barran Portrait The Parliamentary Under-Secretary of State, Department for Digital, Culture, Media and Sport (Baroness Barran) (Con)
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My Lords, in March the Government commissioned an independent review of the destination management organisations in England to look at these issues. The review is ongoing and will report later in the summer. It will make recommendations on how DMOs might best be structured and funded to support the post-Covid recovery of the tourism sector. Last year, the Government provided £2.3 million in financial support to England’s DMOs so that they could continue to carry out vital business support roles during the pandemic.

Lord Ravensdale Portrait Lord Ravensdale (CB) [V]
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I thank the Minister for that response. Local connections and knowledge of place are key for DMOs. Does the Minister agree on the importance of community-based action for DMOs and that freedom from hierarchical structures is key in helping them undertake their role effectively—for example, freedom from the constraints inherent in local government structures and strengthening connections with LEPs, town funds and future levelling-up opportunities?

Baroness Barran Portrait Baroness Barran (Con)
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The noble Lord will be aware that there are several different models of DMO, but the Government recognise the point that he makes about the important role that DMOs currently play in supporting local communities, sharing their expertise and building connections across destinations. The review will consider the points he raises, taking into account current examples of best practice, and will make recommendations based on that.