Recommendation 47

A related issue raised by the DWP was whether the data they collect from clients involves a consent process that limits their ability to transfer to other agencies, such as the Scottish Government. In our evidence session with the DWP, officials raised concerns that when taking a claim for Universal Credit, currently there was no indication to claimants that they may ‘share [claimants] information with the Scottish Government’.119 The Scottish Federation of Housing Associations noted in their written evidence that they felt the DWP should take a ‘more rational approach to data sharing and implicit consent.’120 The Scottish Federation of Housing Associations also pointed out the comments of the Information Commissioner’s Office from April 2019 when it gave the opinion that the ‘DWP appears to be taking an unduly restrictive view of the definition of consent under data protection’.121