Customer Compliance Department

Doug Paulley made this Rhyddid Gwybodaeth request to Adran Gwaith a Phensiynau

This request has been closed to new correspondence from the public body. Contact us if you think it ought be re-opened.

Roedd y cais yn llwyddiannus.

Dear Department for Work and Pensions,

Please supply the following.

1) The function(s) of the Customer Compliance Department

2) The structure of that department

3) Copies of formal guidance to Customer Compliance Officers on conducting investigations and interviews

4) Information on the responsibilities, powers and rights of Customer Compliance Officers

5) Information on the responsibilities, powers and rights of "customers" when being interviewed by CCOs

6) The typical conditions and structure of CCO / customer interviews, both in customers homes and at DWP offices

7) Any materials as to why information relating to the Customer Compliance department and its operations is apparently not available to the public in DWP / Jobcentre Plus publications or websites

Yours faithfully,

Doug Paulley

DWP Adelphi Freedom-of-Information-Request, Adran Gwaith a Phensiynau

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DWP Adelphi Freedom-of-Information-Request, Adran Gwaith a Phensiynau

2 Atodiad

Dear Mr Paulley

Please see attached response to your FoI request.

Kind regards

Central FoI Team

dangos adrannau a ddyfynnir

Gadawodd Doug Paulley anodiad ()

Interesting. To get the key bits out of the documents, that might be of interest to people who have received letters about customer compliance interviews etc.,

1) it's not a criminal investigation and won't be done under caution

2) the interview is to be "robust and challenging", such that the officer doesn't have to accept initial answers as being the truth

3) they gather information from you and any documents you supply, which then goes to a Decision Maker, who makes a decision about any action to take

4) they impress on you that you have to comply from now on

5) they have to give you at least 3 working days notice, and they have to arrange this within 15 working days of them receiving a referral (5 days for "prepayment cases" whatever they are). They can get special circumstances for an unannounced visit ONLY where they suspect you're in a couple, you're a "prepayment case" and a financial assessor has warned you you will be visited at some point.

6) The most common "triggers" for their involvement are:

:- suspicion that you might be living together as a husband and wife or as in a civil partnership

:- you're recently separated

:- you have been self-employed

:- you have sanctions on your benefits

:- they think you've been working without declaring it.

7) Where they think you're not declaring your work, they specifically are not allowed to contact the employer before interviewing you, and must obtain permission to do so at the interview. If you refuse permission they must not contact your employer, as they say it breaches human rights to do so. Similarly, if you deny working for the employer, they must not contact them.

8) "1. The aim of the Customer Compliance interview is to:
• discuss the case having regard to the reason for the referral;
• obtain accurate information from the customer;
• conduct a full review of the customer’s circumstances; and
• reinforce customer responsibilities."

9) they take a signed statement from you at the interview, either that you write or that they write and you sign (or, if you refuse, that they write and they sign)

10) for "living together as..." cases you can request the interview stops for you to consult with your "other half", then a second date will be set

11) you can have somebody with you for the interview

12) you can request to record the interview and they MUST accept your request

13) if you don't provide relevant documents at the time they can insist you provide them within 10 working days

14) you can refuse to say anything in the interview, in which case they will just terminate it

15) if the interview is in your home you can ask the interviewer to leave at any point and they have to do so

16) if you don't turn up for an interview, they must automatically offer you another one; if there's good reason for your inability to attend the second one (with or without notice) they have to offer another.

17) Where an allegation is malicious they can abandon the investigation

18) the Decision Maker makes any decisions (a tautology I know), not the person who comes out who just gathers info

19) 5% of cases are selected for "process checks" to ensure that the Compliance people have done what they should have

20) The Compliance Officer will normally undertake the interview on their own; but for their supervision, they will occasionally be accompanied by their manager

Gadawodd Doug Paulley anodiad ()

The updated guidance, i.e. Up to date version of the above, is at

NB: " Regional Management do not have the authority to overrule the guidance on the recording of
interviews. If a customer indicates that he intends to record a telephone conversation or
interview and the individual involved is uncomfortable about being recorded, the matter should
be raised with their line manager who could arrange that another member of staff who is less
concerned about being recorded can take the telephone call or conduct the interview." (from )

Gadawodd Richard Taylor anodiad ()

A number of comments have been removed from this thread because they did not comply with our policy on annotations:

This is not an appropriate place to discuss benefit claims or complaints about DWP.

Online discussion forums covering this subject include:

Please do not post annotations describing your own personal experiences and complaints.


Richard - volunteer

Gadawodd Jim Allison anodiad ()

In cases where a Compliance Officer visits because of an unfounded allegation of fraud, which proves to be malicious, it does not go back to a Decision Maker, the Compliance Officer has the authority to deal with it.

Jim Allison
retired Welfare Rights Lawyer

Gadawodd J Roberts anodiad ()

'5) Information on the responsibilities, powers and rights of "customers" when being interviewed by CCOs'

You may be interested in some of this:

In RS v Secretary of State for Work & Pensions (ESA) [2021] UKUT 112 (AAC) the appellant's interview under caution concerning an alleged overpayment is provided at paragraph 6:

The Judge identifies 'two particularly worrying shortcomings' regarding the interview (para. 7).

He is also critical of the DWP for its 'sub-optimal handling of the matter' (para. 1). He singles out the 'screen prints' provided by the DWP observing:

'They must show something relevant. Otherwise, why supply them to the tribunal?' (1c)


'It is not for the First-tier Tribunal to try and decode the Rosetta Stone of DWP screen prints. The DWP’s obligation to supply all relevant documentary evidence necessarily incorporates an obligation to provide that evidence in an intelligible form.' (1c)

The judge rejected the Secretary of State's request to have the case remitted to the FTT:

'51. ...Upper Tribunal case management directions made it clear to the parties that they should prepare their cases for the final hearing on the basis that the Upper Tribunal might ultimately re-make the First-tier Tribunal’s decisions. The parties have had a fair opportunity to present their cases on the facts. I am also conscious of Mr S’s need for closure of this matter and I accept what he told me at the hearing of the worry and anxiety caused by having this matter ‘hanging over’ him.'

'61. I shall end by pointing out that the Secretary of State has a power, not a duty, to recover the remaining overpayment from Mr S. It is open to Mr S to argue to the DWP that, in the light of the way in which his case was handled, the overpayment should not be recovered or that a reduced amount should be recovered. However, Mr S should note that decisions about whether to recover an overpayment do not attract a right of appeal. The right of appeal concerns the question whether an overpayment is recoverable, and the amount of the recoverable overpayment, and those matters have now been dealt with by this decision.'