This is an HTML version of an attachment to the Freedom of Information request 'Recording DWP interaction by the public'.

link to page 1 link to page 2 link to page 2 link to page 2 Recordings by claimants during 
interviews, telephone calls etc 

General 
Claimant publishes recording on the internet  
Text to include in letter to a claimant intending to publish, or who has 
published telephone/video recordings on the internet 

General 
Claimants may seek to record a telephone conversation or an interview with 
DWP either openly or covertly using digital recording devices such as 
cameras, microphones and mobile phones.  There are a number of reasons 
why the Department should stop this happening in open plan public 
spaces. Jobcentre Plus has particular guidance on this here. 
A key concern is that if the claimant is visiting DWP premises such as a 
Jobcentre, and is using, or intends to use, their recording equipment, in an 
open plan area they could record other claimants’ personal information. This 
is not acceptable.  
If the claimant insists on recording their interview, a private interview 
room must be used.
 Where such a facility is not available on site and no 
other solution is possible, arrangements to use an alternative Jobcentre Plus 
office will need to be considered. 
Staff should also be aware that interviews can be recorded where it is a 
“reasonable adjustment” requirement under the Equality Act 2010. If 
necessary speak to your local Disability Equality Adviser who can 
facilitate this.  

If a claimant indicates that they intend to make a recording of a conversation 
or interview and staff involved are uncomfortable about being recorded, the 
matter should be raised with local management. Another member of staff who 
is less concerned about being recorded can take the call or conduct the 
interview. This may take time and a future appointment may be necessary.  
A claimant may resort to threatening to record, or actually record, telephone 
calls or interviews as a last resort if they are unhappy about the way they 
have been dealt with by DWP. It may be more appropriate to resolve the 
underlying service issue in which case they may not feel the need to record 
their dealings with DWP. 
Letter to be issued to a claimant before a recording takes place (bear in 
mind the possible need for alternative formats (where available) for 
disabled claimants).    


link to page 2 You should alert the claimant that recording a conversation, may mean that 
they take on legal obligations they are not aware of.  A letter [here] should 
be issued to the claimant before the interview begins. (Or in the case of 
already recorded telephone conversations as soon as possible 
afterwards).  

Claimant publishes recording on internet 
In spite of guidance and warning notices about claimants not making 
recordings in open plan public spaces, some may well do so without 
permission and they may occasionally publish videos, photographs, voice 
recordings etc of interviews or conversations with DWP staff on the internet.  
If so they are exceeding the private and domestic use of such information 
permissible under the Data Protection Act 1998. In this event, you should 
write to the claimant adapting the letter below (for example, change the first 
sentence to read; It has come to the attention of the Department that you 
intend to/have published on the internet recordings of your business with 
DWP
.) 
Consider contacting the relevant Internet Service Provider (ISP) and ask them 
to remove any such recording. Often the ISP will comply and remove the 
content, though the claimant may still post the recording on a different 
website.  
The benefits of contacting the ISP(s) may be outweighed by the lack of impact 
the content will have and so may not be proportionate or justifiable. However, 
this will depend on the nature of the material and each case must be judged 
on its merits. The Complex Case Advisory Service can advise in individual 
cases where material has been published without consent and members of 
staff have concerns about their own personal privacy or health and safety. 
For guidance about the Department’s own routine recording of telephone calls 
with claimants please click here
Text to include in letter to a claimant intending to publish, or 
who has published telephone/video recordings on the internet: 

You have asked to have your interview with Departmental officials recorded. It 
is your right to do so.  
However, you should know that you are entitled to record your business with 
DWP if the recordings are to be used by you for domestic purposes only, 
that is your personal, family, or household affairs (including recreational 
purposes), 
Publishing the recordings on the internet, or in any other way, may not be 
treated as a domestic purpose and may indicate that you are acting in law as 
a data controller under the Data Protection Act. If you intend to make the 

contents of your recording publicly available you need to notify the Information 
Commissioner of your actions.  
The Information Commissioner is Parliament’s independent regulator of the 
Data Protection Act and he may take formal enforcement action to ensure 
your compliance with the Act. It is a criminal offence for a data controller 
to process personal information if they have not registered this with the 
Information Commissioner.
 
*[Please confirm to me that you have understood this letter and that no 
[further] use of the material will be made on the internet. If not we intend to 
alert the Information Commissioner to your unacceptable behaviour].  
*[If you are not satisfied with the service that you have experienced from 
Jobcentre Plus/ PDCS* then arrangements can be made for you to discuss 
your concerns with a senior manager. Please let me know if you wish to 
arrange such a meeting.]  
* delete as appropriate