Recommendation 8

HM Government Not Addressed

DWP considers fully and responds to all data sharing requests from the Scottish Government. It has established a dedicated Scottish Devolution Data Sharing Board, which brings together DWP experts to fully consider any requests and ensure that responses are managed consistently and efficiently. This Board considers any legal constraints and how these could be mitigated, ensuring there is protection of claimants’ rights, clarity of purpose, proportionality of data shared, and a consideration of whether DWP is the most appropriate source for the highest quality, most up-to- date data available. DWP is already working with the Scottish Government to ensure a clearer understanding of data processes. To do this, the Chief Data Officers of DWP and the Scottish Government have previously established a regular forum to address all aspects of sharing data across the two organisations. DWP’s Data Sharing Policy Statement has been shared with the Scottish Government to enable clear understanding between both organisations, and to ensure consistency. Each data sharing request must be examined, and the data decisions must be made and discharged by DWP, as the relevant Data Controller, in line with its legal accountabilities. With respect to the Scottish Child Payment, it should be noted that DWP had already provided the Scottish Government with data relating to children under six in order for it to deliver the Best Start Grant. Those data were then reused by the Scottish Government for the first phase of the Scottish Child Payment. The same data are not necessarily as readily available for older children. It is important for Scottish Government colleagues to work with DWP to establish what data are available from DWP before finalising policy design and moving into implementation. Scottish Government should also be building their own datasets for future use. DWP has confirmed to the Scottish Government, the data it is able to share and has also directed the Scottish Government to the owners of other sources of data that would help Social Security Scotland ensure it has access to the most up-to-date information when it processes benefit claims. The recommendation that Social Security Scotland consider all mechanisms for acquiring their own data where possible if they are requesting data which DWP does not hold, is for the Scottish Government.