Dear Department for Work and Pensions,

1. Please provide copies of the following standard letters:

UCD157 Hardship payment payable
UCD158 Hardship payment not payable

2. Please provide a copy of any standard questions or questionnaire a claimant is required to answer or fill out when requesting a hardship payment.

Yours faithfully,

Martin Williams

Dear Department for Work and Pensions,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Department for Work and Pensions's handling of my FOI request 'Hardship Payments standard letters and questionnaires'.

1. You have refused each of the requests on a single s.12 FOIA ground. However, they should have been treated as separate requests (see Ian Fitzsimmons v ICO & Department for Culture, Media and Sport (EA/2007/0124, 17 June 2008)). Although each question related to hardship payments one was a request for letters you send whereas the other was for questions you ask. They are clearly not to any extent related to the same or similar information and therefore should not be aggregated. In those circumstances, the correct approach would have been to send me the documents requested at (1) of my request. Please do so now.

2. With regard to the s.12 FOIA ground refusing to provide the questions you ask a person who makes an application for hardship payments as they are embedded within the UC computer system and cannot be extracted without spending 3 1/2 days of working time, that is implausible: I suspect the officer concerned has not thought about how the questions might be obtained with far less effort than the laborious method proposed and rejected as too expensive. For example:

a) Reg. 116(1)(c) of the Universal Credit Regulations 2013 to "complete and submit[...] an application (i) approved for the purpose by the Secretary of State or in such other form as the Secretary of State considers sufficient". If there is a form of application which has been approved for the purpose, that form must exist in an accessible format for it to have been approved.

b) I strongly suspect that the contents of any question set would already have been used in an internal training product showing the information which is gathered during an application for hardship payments and would be accessible that way without much effort to obtain.

c) When the computer system was designed, then there would have been a specification saying what questions should be asked when someone applies for hardship payments and that must still be available without actually having to extract information from the computer system now designed.

d) Alternatively, there may be a technical specification for the computer system which sets out the questions asked and could be provided without spending 3 1/2 days extracting information from the computer system.

e) Even if every single question is not available using one of the methods above then perhaps you could simply send me the form of application which has been approved for making an application for hardship payments under reg 116(1)(c).

Please therefore revisit this refusal and consider the alternative methods of sourcing this information which would most likely take less than the 3 1/2 days claimed. If that is not possible then please simply send me the form of application approved under reg 116(1)(c). Given that whether a person has made a request for a hardship payment on the approved form could be an issue raised in an appeal against a refusal of a hardship payment, I would have thought the Department would need to be able to evidence what form they approved. I would also suggest that given this, there is a clear public interest in the approved form being released.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/h...

Yours faithfully,

Martin Williams