Dear Sir/Madam,

This is a request under the Freedom of Information Act. For ease of reference I am outlining my request in four parts.

1.

a) In a letter to the Public Accounts Committee in June 2016, available at https://www.parliament.uk/documents/comm..., it is stated that DWP's Analysis and Intelligence (A&I) Hub for Universal Credit "incorporates departmental and third party data sources, fused together through open source technologies". Please provide a list of departmental and third party data sources, and of the open source technologies used to fuse them, incorporated by the A&I hub.

b) In the same letter, it is stated that in the A&I hub "data trials are underway, focused on household composition, identity and housing: this includes evaluating the value of data from Land Registry, Valuations Office, the National Fraud Initiative, Credit Reference Agencies and the Metropolitan Police". Please disclose the results of these evaluations.

c) In the same letter, it is stated that "DWP will continue to work with third party providers in order to tackle household composition fraud and error. Data held by other organisations can potentially help DWP link adults to addresses, with analysis of resulting data helping identify ‘at risk’ cases, leading in turn to the creation of referrals for potential investigation." Please list all third party providers or organisations with which DWP has worked between 1 Jan 2016 and the present.

2.

a) In a document published in Nov. 2017, entitled "Fraud and Error in the
Benefit System: Background information and methodology", available at https://assets.publishing.service.gov.uk..., it is stated that "The Verify Earnings and Pensions (VEP) service lets business users across DWP access HMRC’s data through digital web services and delivers automation of some of the back-end processing". Please list the back-end processes which VEP automates.

b) In the same document, it is stated that "DWP engaged a specialist data company in May 2017 to help identify claimants with an undeclared partner". Please disclose which company this was, and whether the relationship with DWP in ongoing.

3.

a) In its accounts for 2017-8, available at https://assets.publishing.service.gov.uk..., it is stated that the A&I hub "uses new analytical tools to help identify, profile, monitor and escalate cases for investigation and is increasingly building a common knowledge-base of claimant behaviour, which supports ongoing risk profiling and helps manage risks of UC expansion." Please list these new analytical tools.

b) In the same document, it is stated that "We continue to trial new external datasets to risk assess the accuracy of UC claims and reduce what claimants and agents have to prove when they make a claim. A two year contract with an external credit reference agency introduced new data and is identifying potential ‘living together’ fraud. Work with other data providers is exploring how we can identify undisclosed capital." Please list all external datasets trialled, the "external credit reference agency" and all data providers referred to. In addition, please disclose the results or evaluations of the trials.

c) In the same document it is stated that "we have also begun a review of our information powers to identify any opportunities to strengthen them whilst ensuring that they remain proportionate". Please disclose the result of this review.

4.

a) In a hearing with the Public Accounts Committee on 9 July 2018, reference is made to a pilot of a text mining system to transform text into management information reports (http://data.parliament.uk/writtenevidenc...). It is stated that DWP "expect[s] to have completed the first run of the data mining by the end of the summer". Please disclose the evaluation of this pilot.

In making this request I am mindful of existence of the cost exemption in relation to locating (but not redacting) records. I have tried to make this request as narrow as possible, but in the event that you determine that it exceeds allowable cost to locate responsive records, I would be most grateful if you could respond to all questions which can be answered within the cost window.

In the event that you consider any information in the responsive documents to be exempt from disclosure, please redact that information with black boxes rather than snipping or excerpting from the documents.

I understand that under the Freedom of Information Act I am entitled to a response within twenty working days.

I would be grateful if you could confirm receipt of this request in writing as soon as possible. If you have any queries about the scope of this request, please do not hesitate to call me on 0203 892 7491 or email [email address].

Yours faithfully,

Crofton Black

Dear Sir/Madam,

I am writing with reference to DWP's response to my earlier request, ref FOI2019/07828, dated 25 March 2019.

I am requesting internal review of this response, in particular with regard to DWP's reasoning around the application of exemption 31(1)(a). For ease of reference I am numbering my points below in accordance with the number scheme laid out in the initial request and response.

In making this request for review, I am mindful of the ICO's guidance on the nature of prejudice, as outlined at https://ico.org.uk/for-organisations/gui...

"To decide whether disclosure (or confirmation/denial) would cause prejudice:
• you must be able to identify a negative consequence of the disclosure (or confirmation/denial), and this negative consequence must be significant (more than trivial);
• you must be able to show a link between the disclosure (or confirmation/denial) and the negative consequences, showing how one would cause the other; and
• there must be at least a real possibility of the negative consequences happening, even if you can’t say it is more likely than not."

1a) I requested a list of i) departmental data sources, ii) third party data sources and iii) open source technologies used to fuse them, as incorporated by the A&I hub. I request review of whether exemption 31(1)(a) has been properly applied here, whether the likely prejudice has been properly determined, and whether the public interest test has been properly carried out. I query whether a list of "open source technologies" used to fuse data sources can properly be said to fulfil the conditions to invoke 31(1)(a). I also query whether, without specific details of what a data source is being used to do and under what rules it is being interrogated, the mere disclosure of the name of a data set, whether from within the department or from a third party, could be prejudicial.

1b) I query whether it is not possible to release redacted copies of the relevant evaluations. I believe it is unlikely that the entirety of all text in all evaluations would be prejudicial, and that DWP should therefore release the relevant evaluations, appropriately redacted.

1c) As above, I query whether the mere disclosure of the name of a data provider, without any details of what interrogation is being made of the data and how this interrogation is carried out, can in fact be prejudicial.

3a) As above, I query whether the identification of tools can be prejudicial, given that I have not requested any details around how the tools are being used.

3b) As above, I query whether it would genuinely be prejudicial to give names of data providers and datasets; I query why DWP chooses to withhold the name of an external credit reference agency here while disclosing such a name in 2b; and I query why DWP is unable to release appropriately redacted versions of the results or evaluations.

Overall, I note that DWP has offered no analysis at any point in its response as to how it has carried out its public interest tests and how it has carried out its prejudice tests. As I have set out above, I believe these tests have not been carried out with the appropriate granularity, and the exemption has as a result been too broadly and unjustifiably applied.

Please do not hesitate to contact me if you require any clarification.

Yours faithfully,

Crofton Black