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.
When I submitted the same request five years ago, I was able to determine the following facts. Please ensure that your response includes relevant recorded information on the same topics.
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
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Dear Mr Paulley,
Please find attached the reply to your recent Freedom of Information
request reference number 4512:
DWP Freedom of Information Team
Dear Operations FOI Requests,
Thank you for the information.
This is an automated confirmation that your request for information has been accepted by the DWP FoI mailbox.
By the next working day your request will be forwarded to the relevant information owner within the Department who will respond to you direct.
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