Source · Select Committees · Work and Pensions Committee
1st Report – Safeguarding Vulnerable Claimants
Work and Pensions Committee
HC 402
Published 15 May 2025
Recommendations
1
Accepted
DWP failures have resulted in hundreds of serious harms and deaths to claimants.
Recommendation
DWP provides essential services that act as a lifeline to millions of people each year, many of whom are vulnerable and require additional support to access them. For this reason, when mistakes are made, it is possible that the severest …
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Government Response Summary
The government accepted the recommendation, stating it is open to a statutory duty to safeguard vulnerable customers and has completed a consultation on a new DWP safeguarding approach. The Secretary of State will make a statement in the Autumn outlining a new approach based on review findings, focusing on cultural change, renewed commitment, and systems-based approaches to safeguarding.
Department for Work and Pensions
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4
Accepted
Require Secretary of State to make statement on DWP's new safeguarding approach.
Recommendation
To signal a step-change to the public in the culture of the Department, and to improve accountability directly to Parliament, we recommend the Secretary of State for Work and Pensions make a statement to the House, setting out DWP’s new …
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Government Response Summary
The government accepted the recommendation, stating that the Secretary of State for Work and Pensions will make a statement to the House in the Autumn, setting out DWP's new safeguarding approach, including a clear intent to drive cultural change and renew commitment to safeguarding.
Department for Work and Pensions
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6
Deferred
Introduce statutory duty for DWP to safeguard vulnerable claimants department-wide.
Recommendation
We recommend DWP introduce a statutory duty to safeguard vulnerable claimants that applies to the whole Department, and for which the Secretary of State is ultimately accountable. The duty should have regard to factors such as the wellbeing of vulnerable …
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Government Response Summary
The government did not commit to introducing a statutory duty for safeguarding vulnerable claimants. Instead, it is engaging in a public consultation on safeguarding and establishing a Disability Advisory Panel, set to launch in summer 2025.
Department for Work and Pensions
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8
Accepted
Introduce requirement for Chief Medical Adviser to assess health impact of all significant DWP policies.
Recommendation
We recommend that as a part of a systems-based approach to safeguarding, the Department introduce an explicit requirement that all significant new policies and policy changes, including those that fall outside the disability service area, are assessed by the Chief …
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Government Response Summary
The government did not commit to the Chief Medical Advisor's team assessing all new policies for health impacts. Instead, it described existing ongoing efforts to improve accessibility, tailor services, and capture customer needs through updated processes and surveys.
Department for Work and Pensions
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10
Deferred
Publish Chief Medical Adviser's assessment of Pathways to Work Green Paper proposals.
Recommendation
In response to this report, we ask that DWP confirm that planned changes to health and disability benefits, set out in the Pathways to Work Green Paper, were prospectively assessed with respect to possible physical and mental 95 health impacts …
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Government Response Summary
The government did not confirm whether health and disability benefit changes were prospectively assessed for health impacts by the Chief Medical Advisor's team, nor did it commit to publishing any such assessment. Instead, it highlighted existing support services for claimants.
Department for Work and Pensions
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12
Deferred
Introduce a systems-based approach to safeguarding across all DWP policies and operations.
Recommendation
We recommend the Department introduce a systems-based approach to safeguarding, at all levels of DWP and in all policies. A systems- based approach should consist of developing mechanisms to ensure that safeguarding is explicitly considered at each point in the …
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Government Response Summary
The government committed to considering the recommendation for a systems-based approach to safeguarding when the detailed departmental approach is outlined later in the Autumn, without making any specific commitments at this time.
Department for Work and Pensions
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15
Deferred
Formalise and publish a clear, consistent definition of vulnerability in all DWP public documents.
Recommendation
DWP should formalise its definition of vulnerability and undertake work to ensure it is clearly and consistently communicated in key public facing documents, including its ‘Advanced Customer Support: Delivering support and transformation to help DWP customers with additional support needs’ …
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Government Response Summary
The government states its current definition of vulnerability and says it will consider publishing this definition as part of a safeguarding review, while being mindful of flexibility, rather than immediately formalising and publishing guidance.
Department for Work and Pensions
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16
Deferred
Add 'victims of domestic abuse' category to Universal Credit Additional Support Area.
Recommendation
We heard in evidence that when using the ‘Additional Support Area’ in Universal Credit, DWP officials are able to record support needs under the following eight categories: care leavers; armed forces; ex-offender; homeless or risk of homelessness; limited digital ability …
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Government Response Summary
The government did not commit to adding 'victims of domestic abuse' as a specific category in the Universal Credit 'Additional Support Area'. Instead, the response outlined DWP's ongoing engagement with and support for local and national Safeguarding Adults Boards.
Department for Work and Pensions
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18
Accepted
Introduce specific questions and a tick-box on benefit forms for vulnerability disclosure.
Recommendation
DWP should add a question to all benefit application forms that asks claimants if they would like to disclose anything about their personal circumstances, including medical or mental health concerns, that means they might need additional support, now or in …
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Government Response Summary
The government states it is already driving continuous improvement in identifying customer needs and providing tailored support. It highlights existing measures such as updated call scripts, new questions in ESA online claims for alternative formats, and identification of support needs in Universal Credit claims, which are continually refined.
Department for Work and Pensions
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19
Deferred
Implement policy for staff to proactively check vulnerabilities, engage claimants, and provide targeted training.
Recommendation
DWP should also implement a new policy making clear that staff have a responsibility to check proactively for vulnerabilities and engage claimants in regular conversations where they can share any difficulties they may be experiencing. For example, if a claimant …
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Government Response Summary
The government refers to its Green Paper and recent consultation on increasing engagement with claimants, stating it is currently considering responses to inform future policy development on this. It also highlights existing processes and training for staff to identify vulnerability, alongside developing a trauma-informed approach.
Department for Work and Pensions
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21
Deferred
Ensure Jobcentres provide equivalent comprehensive support to claimants as 'Help to Claim' service.
Recommendation
DWP must ensure that Jobcentres can provide as thorough a service as used to be offered through Help to Claim. We recommend that, in its response to this report, DWP sets out where the support offered in Jobcentres and through …
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Government Response Summary
The government responded by outlining steps to improve transparency and oversight of serious cases through new appointments to boards, rather than addressing the specific recommendation about Jobcentre support equivalence.
Department for Work and Pensions
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23
Accepted
Provide claimants with detailed information about available additional support and train staff proactively.
Recommendation
Upon first applying to benefits, and at each review point, we recommend DWP staff provide claimants with detailed information about the additional support available to them, which must include an indicative list of possible reasons which might lead to an …
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Government Response Summary
The government declines to provide detailed upfront information, citing user research that it can overwhelm claimants. Instead, they state they signpost information and staff are trained and equipped to check for needs and signpost support, exercising professional judgment.
Department for Work and Pensions
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24
Deferred
Ensure safeguarding publication is accessible and develop additional support toolkits for claimants.
Recommendation
DWP must ensure its new ‘approach to safeguarding’ publication is easy to use, signposts relevant support organisations, and is available in a range of languages and alternative formats. DWP should also develop an additional support toolkit to accompany this publication, …
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Government Response Summary
The government will consider the recommendation regarding its new safeguarding publication and accompanying toolkit when the details are outlined later in the Autumn. It notes that all DWP publications already comply with an Accessible Documents Policy for various formats.
Department for Work and Pensions
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27
Deferred
Commission regular surveys to understand DWP staff views on safeguarding policies and workload
Recommendation
We recommend DWP commissions or undertakes a series of surveys to understand how staff feel about the Department’s safeguarding policies, practices and their overall workload. The surveys should include questions relating to views on training and guidance; familiarity and confidence …
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Government Response Summary
The government agrees surveys are valuable and states the new Coaching Academy will capture structured feedback through surveys. It will consider how best to use existing and new surveys to inform safeguarding policy and service delivery, rather than committing to a specific series of surveys as recommended.
Department for Work and Pensions
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29
Rejected
Improve awareness of ACSSLs' roles and expand their capacity across Great Britain
Recommendation
We recommend DWP work to improve awareness of the work that Advanced Customer Support Senior Leaders undertake, including by setting out a full description of their role when publishing their new approach to safeguarding, and by promoting case studies. As …
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Government Response Summary
The government states current ACSSL resourcing is appropriate and additional roles were introduced, effectively rejecting the need to assess capacity or expand the number of ACSSLs. They commit to exploring ways to increase ACSSL visibility in future publications, but do not accept specific methods like promoting case studies.
Department for Work and Pensions
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30
Rejected
Create an external system for benefit advisers to directly refer claimant concerns to ACSSLs
Recommendation
The Department should also develop a more systematic route through which benefit advisers can contact ACSSLs directly, when and if they have a serious concern about a claimant. DWP should consider creating an external equivalent of the internal system it …
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Government Response Summary
The government rejected the recommendation for a new systematic route for benefit advisers to contact ACSSLs directly, stating that existing channels are sufficient and ACSSLs are not intended to replace frontline services. They highlighted existing ACSSL external relationships and rising external referrals.
Department for Work and Pensions
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32
Accepted in Part
Mandate DWP representation on Safeguarding Adult Boards and duty to refer vulnerable claimants
Recommendation
We recommend the Government make it a statutory requirement for all Safeguarding Adult Boards to include DWP representation. As part of its statutory safeguarding duty, DWP should also have a specified duty to refer vulnerable claimants to other agencies, including …
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Government Response Summary
The government plans to publish the Memorandum of Understanding. They support increasing DWP representation on Safeguarding Adult Boards, with ACSSLs currently on 80%, but do not commit to making it a statutory requirement or establishing a specified duty to refer vulnerable claimants.
Department for Work and Pensions
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34
Rejected
Remove the MP filter and grant PHSO power to investigate systemic issues proactively
Recommendation
We agree with the PHSO that the MP filter should be removed, and that the PHSO should be granted the power of initiative so that it can investigate known and systemic issues, more effectively support public services and extend access …
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Government Response Summary
The DWP rejected the recommendation, stating it lacks the authority to remove the MP filter or grant the PHSO new powers, as these changes require primary legislation from Parliament. They also noted no clear evidence that removing the filter would improve outcomes.
Department for Work and Pensions
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36
Not Addressed
Devise a systematic way to record and annually publish serious harms and deaths
Recommendation
We recommend the Department work with its Chief Medical Advisor, DWP’s Caldicott Guardian, and coroners to devise a way to record more systematically all cases of serious harms and deaths where the individual affected was in receipt of working-age benefits. …
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Government Response Summary
The government noted the Chief Medical Advisor's existing involvement in public Coroner reports and stated it is reviewing and exploring how to strengthen their roles, and how the Caldicott Guardian will be included in ethical data considerations, but did not commit to systematically recording or annually publishing all cases of serious harms and deaths.
Department for Work and Pensions
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37
Accepted in Part
Ensure Caldicott Guardian inclusion in all future DWP service procurement processes
Recommendation
We welcome the action taken by the Chief Medical Advisor to appoint a Caldicott Guardian in order to aid transparency and to ensure DWP handles claimants’ data safely and ethically. However, we are concerns that due to other organisations, the …
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Government Response Summary
The government states that the role of Caldicott Guardian is evolving and the department is currently exploring how the Guardian will be included in wider departmental ethical data considerations, including relevant commercial contracts.
Department for Work and Pensions
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39
Accepted in Part
Improve transparency of DWP's serious mistake learning processes with the PHSO
Recommendation
DWP should work with the PHSO in the next six months to improve the transparency of the processes it uses to learn from serious mistakes and failures, including Internal Process Reviews, the Independent Case Examiner, and the Serious Case Panel. …
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Government Response Summary
The government rejected the specific recommendation to work with the PHSO on transparency, stating it's DWP's own responsibility. However, DWP committed to fulfilling this responsibility by planning to publish findings from Internal Process Reviews to support transparency and improve understanding.
Department for Work and Pensions
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40
Rejected
Introduce an independent body to investigate serious harms in DWP case mishandlings
Recommendation
However, even if the Department improves transparency, we are still concerned that the process in DWP amount to it marking its own homework. Therefore, in the longer term, we recommend DWP introduce an independent body to investigate serious harms, to …
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Government Response Summary
The government welcomes the recommendation but does not commit to introducing a new independent body to investigate serious harms. Instead, it highlights existing measures, such as an independent member on the Clinical Governance and Excellence Board and a Serious Case Panel chaired by a Non-Executive Director, as providing oversight.
Department for Work and Pensions
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Conclusions (18)
2
Conclusion
Not Addressed
We note that in April 2022, the Equality and Human Rights Commission (EHRC) and DWP were working to improve DWP’s treatment of disabled benefit claimants in accordance with a legally binding section 23 agreement. We further note that the EHRC launched a formal investigation into DWP in May 2024, which …
Government Response Summary
The government's response discusses its openness to a statutory safeguarding duty, consultation findings, and a future statement on DWP's new safeguarding approach, without directly addressing the Committee's conclusion about the ongoing EHRC investigation or its decision to defer recommendations.
3
Conclusion
Accepted
It is striking that despite being engaged with safeguarding on a daily basis, the Department has never had a clear and coherent, public facing safeguarding policy or strategy. For example, that when making an internet search for “DWP safeguarding policy” or “strategy”, there are no clear results from Government webpages. …
Government Response Summary
The government is open to a statutory safeguarding duty and the Secretary of State for Work and Pensions will make a statement in the Autumn outlining DWP's new safeguarding approach, which will include a clear intent to drive cultural change and define its role in supporting those with safeguarding needs.
5
Conclusion
Accepted in Part
The Department has said that whilst it does not have a statutory duty to safeguard vulnerable claimants, it recognises it has a responsibility to support them and does so through other means. We remain concerned, however, that current practice is insufficient, and that public trust is sorely damaged. We received …
Government Response Summary
The government stated it is open to introducing a statutory duty to safeguard vulnerable customers and will publish its new DWP safeguarding approach in the Autumn, which will include a clear statement of intent for cultural change.
7
Conclusion
Acknowledged
DWP is more likely to prevent vulnerable claimants from experiencing harm if it first engages them in decision-making that affects them: their needs, the potential risks of proposals, and how those risks might be mitigated. We welcome the intention to introduce a trauma-informed policy framework and the work reviewing policy …
Government Response Summary
The government recognised the broad nature of vulnerability and stated that as part of a safeguarding review, it will consider publishing DWP's flexible definition of vulnerability.
9
Conclusion
Deferred
The Chief Medical Adviser (CMA) told us her team provided clinical advice to Ministers and was involved in assessing any potential policy changes put forward within White Papers or Green Papers; however, these assessments were not usually published, to enable Ministers to make decisions in a safe space. The Pathways …
Government Response Summary
The government did not commit to publishing the Chief Medical Advisor's assessment of proposals in the Pathways to Work Green Paper. The response focused on increasing engagement, staff training, and developing a trauma-informed approach.
11
Conclusion
Accepted
DWP is undertaking a major programme of reform via its green and white papers and several long-term strategies and programmes. This work presents a significant opportunity to improve safeguarding for claimants across the social security system. However, DWP must be alert to unintended consequences that could put claimants at risk, …
Government Response Summary
The government did not explicitly commit to new mechanisms for incorporating lived experience in policy design or proactively identifying unintended consequences of reforms. The response focused on existing practices for communicating information to customers, checking for support needs, and providing staff training.
13
Conclusion
Deferred
To ensure that it incorporates the expertise of people with lived experience of the benefit system, DWP should set up a reference group similar to the Greater Manchester Disabled People’s Panel to help shape safeguarding policy. (Recommendation, Paragraph 51) Defining ‘vulnerability’ and identifying additional needs
Government Response Summary
The government did not commit to setting up a reference group of people with lived experience (claimants) to shape safeguarding policy. Instead, the response focused on using staff surveys, a Coaching Academy, and frontline staff feedback to inform improvements.
14
Conclusion
Deferred
DWP’s existing description, or definition, of vulnerability in internal documentation encourages an open, flexible approach to determine when a claimant has additional support needs. However, the lack of a clear, consistent and public-facing definition of vulnerability could act as a barrier to understanding if and when individuals are entitled to …
Government Response Summary
The government acknowledges the issue and states its internal definition of vulnerability. It will consider publishing this definition as part of a safeguarding review, noting the need for flexibility.
17
Conclusion
Deferred
When it comes to identifying vulnerable claimants, the Department places too great an onus on self-disclosure. The nature of some vulnerabilities can make disclosure difficult. A lack of trust in the Department can further deter people from sharing their personal circumstances. Whilst DWP has sought to train staff to recognise …
Government Response Summary
The government responded to an unrelated point about the PHSO's MP filter and powers, stating DWP lacks the authority to change it and that it's a matter for Parliament.
20
Conclusion
Deferred
Ensuring vulnerable people have support to access the benefits they are entitled to is an essential part of delivering equitable welfare provision and an effective safety net. Since the removal of Help to Claim’s face-to-face service in 2022 it has become more difficult for some individuals to apply for Universal …
Government Response Summary
The government responded to an unrelated point about the PHSO's role in DWP's internal learning processes, committing to publish findings from Internal Process Reviews to promote transparency.
22
Conclusion
Accepted
Some vulnerable claimants require reasonable adjustments and additional support throughout their benefit claim. These adjustments are crucial to ensuring that claimants can successfully engage with the system, receive the support they are entitled to, and reduce the risk of unmet needs escalating to serious harms. However, many claimants do not …
Government Response Summary
The government recognizes the importance of informing customers about support but, based on user research, has streamlined initial information, signposting additional details for customers to access when needed, and relies on DWP colleagues, training, and tools to identify and signpost support.
25
Conclusion
Acknowledged
Incorrectly applied, policies intended to drive claimant behaviour and deliver value for money, such as sanctions and deductions, can create and exacerbate vulnerabilities. While DWP has checks in place that are supposed to ensure this doesn’t happen, the application of these checks is inconsistent. This can leave claimants facing substantial …
Government Response Summary
The Coaching Academy will aim to professionalise employment support through accredited training and provide platforms to capture structured frontline feedback, which will inform continuous improvement in training and delivery of service.
26
Conclusion
Acknowledged
The effectiveness of DWP policies that are supposed to protect claimants from harm is in large part contingent on Work Coaches applying discretion correctly and consistently. Discretion can be a valuable tool in the benefit system, but we are concerned that overreliance on discretion is placing an unreasonable burden on …
Government Response Summary
The Coaching Academy will aim to professionalise employment support through accredited training and provide platforms to capture structured frontline feedback, which will inform continuous improvement in training and delivery of service.
28
Conclusion
Accepted
Advanced Customer Support Senior Leaders (ACSSLs) form a core part of DWP’s safeguarding strategy and undertake significant public facing and operational roles. Despite ACSSLs playing a critical role in DWP’s approach 99 to safeguarding, there remains a lack of understanding, including amongst organisations that support claimants, about the work ACSSLs …
Government Response Summary
The government states current ACSSL resourcing levels are appropriate and additional roles were introduced to support them. They indicate ACSSLs actively promote their role and foster external relationships, and will continue to explore ways to increase their visibility.
31
Conclusion
Not Addressed
Effective collaboration between partners is essential to understand the complex needs of some claimants, to understand if they are at risk, and to identify if any interventions are required to assure their safety. The Department has taken some steps to improve the way it works with other agencies, led by …
Government Response Summary
The government states it will continue to strengthen partnerships with Safeguarding Adult Boards and increase DWP representation (currently 80%), and plans to publish the joint Memorandum of Understanding. However, it does not directly address the committee's finding that the department does not consistently refer vulnerable claimants to appropriate agencies.
33
Conclusion
Deferred
Many of the people making a complaint against DWP are likely to be in a vulnerable situation. Having a robust, clear and accessible complaints procedure is therefore crucial to prevent failures from reoccurring and to provide those affected with a means of redress. We are concerned that some vulnerable claimants, …
Government Response Summary
DWP acknowledges the recommendation to remove the MP filter, but states it does not have the authority to make such changes as the current arrangements for the PHSO are set out in the Parliamentary Commissioner Act 1967 which is a matter for Parliament.
35
Conclusion
Accepted
We remain concerned that the true scale of deaths and serious harms of vulnerable claimants is currently unknown. As set out by the Chief Medical Advisor, we recognise the complexity of these cases and that being in receipt of benefits does not automatically imply culpability of the Department. However, we …
Government Response Summary
The Chief Medical Advisor is actively involved in departmental responses to Coroner-issued Prevention of Future Death reports, and a review is under consideration to strengthen this role. The role of the Caldicott Guardian was established in DWP in 2024 and continues to evolve.
38
Conclusion
Acknowledged
If all other layers of safeguarding fail, and claimants experience harm as a consequence, it is essential that DWP learns from these cases. Furthermore, it is right that learning mechanisms are transparent, so that claimants and their families can understand what the Department is doing to prevent 101 these same …
Government Response Summary
DWP is committed to continuous learning to improve public services and recognizes its responsibility to learn when experiences for customers have fallen below expectations and to make changes that drive improvement. DWP plans to publish findings from Internal Process Reviews to support transparency and improve understanding of the system among customers and stakeholders.