DWP Central Freedom of
Information Team
Caxton House
6-12 Tothill Street
London
SW1H 9NA
John Slater
freedom-of-information-
xxxxxxxxxxxxxxxxxxxxxxx@xxxxxxxxxxxxxx.xxx
xxxxxxx@xxx.xxx.xx
DWP Website
Our Ref: FOI2022/87563
1 December 2022
Dear John Slater,
Thank you for your Freedom of Information (FoI) request received on 3 November. You
wrote:
“Re: Universal Credit Programme Board Papers Deposited 18 October 2022
Yet again the DWP has redacted some of the deposited papers without any attempt to justify
them.
RFI1: Please disclose the redacted information within the following documents (please note
that any information exempt under Section 40 FOIA is to be considered outside the scope of
my request):
- D-UCPB_27.10.20-3-Next_Phase_Product_Development.pdf
- F-UCPB_27.10.20-5-Help_to_Claim-Options_for_2021-beyond.pdf”
DWP Response
We confirm that we do hold the information you have requested.
DWP is not required to share FOI exemptions as part of the publication strategy, there’s no
requirement under the FOI Act to do that.
Turning to the specific documents you have asked us to publish unredacted I have set out
below our rationale for the redactions in each document.
On the Next Phase Product Development document small sections of the document had to
be redacted under Section 31(1)(a) as details of the system and processes that could be ex-
ploited by malicious actors were included in the document.
Section 31(1)(a) is a qualified exemption so having established that the exemption is en-
gaged we are required to consider the balance of public interest.
There is a strong public interest in DWP being transparent about the delivery of the Universal
Credit system and the details of senior official’s considerations about the development of the
system will inform understanding of the processes required to deliver Universal Credit.
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The document we have published serve this interest as only minor sections of the document
have been redacted.
The publication of the full unredacted document would reveal details of the UC system that
could be exploited by criminals to attack the system. The UC system is regularly subject to
cyber-attacks, many originating from outside of the UK. Revealing details of risks and counter
measures would result in a higher probability of these type of attacks being successful. And
we are confident, having received this explanation, you would not wish to aid and abet crimi-
nals in their efforts to defraud the system by further seeking to force the release of this mate-
rial. Having considered the balance of public interest we believe that there can be no doubt
that it is in the public interest to withhold the redacted material in this document.
Turning to the Help to Claim Options document. There are two separate related redactions
applied to this document. The section 43 redactions have been applied because the selected
elements redacted would be likely to prejudice DWPs commercial interests. The section 42
redactions are in respect of legal professional privilege.
Exemption 43 is a qualified exemption, so we have considered a public interest test relating
to the release of the redacted information. There is a public interest in DWP being transpar-
ent in its discussions around Help to claim. The published document goes some way to ful-
filling this public interest. There is a significant likelihood of DWPs commercial interests being
prejudiced if the redacted material was released. On balance we believe that the public inter-
est is best served by withholding the redacted material.
Exemption 42 is also a qualified exemption There is a case for legal advice relating to Help to
Claim being made public. The legal advice relating to Help to Claim is currently being consid-
ered as part of the ongoing development of the Help to Claim service. In these circumstances
the public interest is best served by redacting the selected paragraphs relating to legal ad-
vice.
If you have any queries about this letter, please contact us quoting the reference number
above.
Yours sincerely,
DWP Central Freedom of Information Team
Department for Work and Pensions
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Your right to complain under the Freedom of Information Act
If you are not happy with this response you may request an internal review by e-mailing
xxxxxxxxxxxxxxxxxxxxxxxxxxxxxx@xxx.xxx.xx or by writing to: DWP Central FoI Team, Caxton
House, 6-12 Tothill Street, London, SW1H 9NA.
Any review request should be submitted within two months of the date of this letter.
If you are not content with the outcome of the internal review you may apply directly to the
Information Commissioner’s Office for a decision. Generally, the Commissioner cannot make
a decision unless you have exhausted our own complaints procedure. The Information
Commissioner can be contacted at: The Information Commissioner’s Office, Wycliffe House,
Water Lane, Wilmslow, Cheshire SK9 5AF.
Website
: ICO FOI and EIR complaints or telephone 0303 123 1113.
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