Universal Credit - Current Versions of Risks, Issues, Dependencies & Assumptions Logs

Waiting for an internal review by Department for Work and Pensions of their handling of this request.

Dear Department for Work and Pensions,

In the Commissioner’s decision notice (“DN”) FS50792926 related to a request for the Universal Credit RAID documents, at [25] and [26] it was stated:

“25. Due to the above the DWP revised its estimation of the time it would take to meet the complainant’s request for information. Its revised estimates are as follows, its original estimates (as above) are in parenthesis.

• RFI1 - Assumption log – Open – 4 hours (previously 5)
• RFI1 - Assumption log – Closed – 50 hours (previously 65)
• RFI3 -Risk log – Open – 9
• RFI3 -Risk log – Closed- 50 (previously a total of 65)

26. In addition to the above the DWP also provided answers to specific queries raised or asserted by the complainant:

Query
Normally RAID information would be held in separate formal logs or registers to allow for ease of access and updating. This could be MS Office documents (e.g. Word or Excel) held on a shared computer drive or in specific IT applications that allow access for people working on the programme or project.

Reply
“I can confirm that separate excel spreadsheets are used to log issues risks issues and dependencies”

Please note that the queries were questions submitted by the Commissioner to the DWP and the replies were the responses provided by the Department.

In light of the above:

RFI1: Please disclose the current version of the Open Universal Credit Programme Assumptions log.

RFI2: As the Universal Credit Programme Issues, Risks and Dependencies are logged in separate Excel spreadsheets, please disclose the current versions in Excel format (this will reduce the amount of time required to provide the information as it will not need to be converted to pdf).

Please note that personal information exempt under section 40(2) FOIA is specifically excluded from the scope of my requests.

S.12 advice re RFI2 – My request is for the current versions of the respective documents whether they contain open and / or closed entries. As I am requesting the current versions of the documents there is no need to check for accuracy, collate information / documents, cross reference information or remove anything. Please note that the costs for redaction cannot be included in an cost estimate.

Yours faithfully,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

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Mark Abraham left an annotation ()

John, you seem do have a good understanding of the DWP's ways and means of dealing with Universal Credit. I'm interested in learning more about that. Do you have any information you can share please?

John Slater left an annotation ()

Hi Mark,
I've been focusing on how the DWP Universal Credit Programme has been being run (very badly). I don't know much about the day to day experience of people who are claiming UC. The best sources I can suggest are:

- The response & documents I've had to my FOIA requests on here.
- Other FOI requests on WDTK.
- Searching Deposited papers on Parliament's library:
https://www.parliament.uk/depositedpapers
The DWP released UC Programme board papers on 12/09/19 & 29/01/19. There should be more published soon.
NAO Reports published over the years (available via the NAO website).

Other than this it's just a case of researching what you can find online.
John

J Roberts left an annotation ()

"Universal Credit: Welfare system to be delayed again with completion not expected until 2024"

https://www.independent.co.uk/news/uk/po...

no-reply@dwp.ecase.co.uk on behalf of DWP Central FOI Team, Department for Work and Pensions

1 Attachment

Dear John Slater

The date that the response is due for your request, FOI2020/04429, has
been changed to 23rd March

Kind Regards,

DWP Central FOI Team

We treat your personal information carefully. We may use it for any of our
purposes. To learn more about information rights and how we use
information, please see our DWP Personal Information Charter at
[1]www.gov.uk

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Dear [email address] on behalf of DWP Central FOI Team,

Thank you for the reply. As ever when Section 10(3) is being relied upon, I remind the Department of the Commissioner's guidance that even when extending for the public interest test it should provide its final response within 40 working days of my original RFI.

Yours sincerely,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

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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 'Universal Credit - Current Versions of Risks, Issues, Dependencies & Assumptions Logs'.

Whilst I appreciate that everyone at the DWP is extremely busy I believe if should still comply with its legal obligations. The Department should have provided me with its final response a week ago.

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

Yours faithfully,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

This is an automated confirmation that your request for information has
been accepted by the DWP FOI mailbox.
 
If your email is a Freedom of Information request you can normally expect
a response within 20 working days.
 
However please be advised that due to the current situation with COVID-19
we cannot guarantee a response within this timescale.
 
Every effort is being made to respond to FOIs as we would usually but the
current situation means that available Departmental resources will be
needed on other high priory areas.
 
We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.
 
Email FOI responses will be issued from [1][email address]
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no-reply@dwp.ecase.co.uk on behalf of DWP Policy Group Freedom of Information, Department for Work and Pensions

Dear John Slater,

Contact email: [1][email address]

Thank you for your Freedom of Information (FoI) request (FOI2020/04429).

We would like to apologise for the delay in responding to your FoI
request.

The DWP does endeavour to respond to FoI requests within 20 working days.
However due to the current situation with COVID-19 it has not been
possible for us to reply to you within this timeframe as available
Departmental resources are needed on other high priority areas.

We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.

If you have any queries about this letter, ple ase contact the department
using the email address and reference number above.

Yours sincerely,

DWP Central FoI Team

Department for Work and Pensions

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no-reply@dwp.ecase.co.uk on behalf of DWP Policy Group Freedom of Information, Department for Work and Pensions

Dear John Slater,

Our Ref: IR2020/15603

Contact email: [1][DWP request email]

Thank you for your Freedom of Information (FoI) review request.

You can normally expect a response to your FoI review request within 20
working days. However due to the current situation with COVID-19 it may
not be possible for us to reply to you within this timeframe.

The DWP will make every effort to respond to FoI reviews as we would
usually but the current situation may mean that available Departmental
resources are needed on other high priority areas.

We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.

If you have any queries about this letter, please contact the department
using the email address and reference number above.

Yours sincerely,

DWP Central FoI Team

Department for Work and Pensions

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no-reply@dwp.ecase.co.uk on behalf of DWP Policy Group Freedom of Information, Department for Work and Pensions

9 Attachments

Dear John Slater,

I am writing in response to your request for information, received 31st
January.

Yours sincerely,

DWP Central FoI Team

no-reply@dwp.ecase.co.uk on behalf of DWP Policy Group Freedom of Information, Department for Work and Pensions

9 Attachments

Dear John Slater,

I am writing in response to your request for information, received 30th
March.

Yours sincerely,

DWP Central FoI Team

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 'Universal Credit - Current Versions of Risks, Issues, Dependencies & Assumptions Logs'.

Thank you for your unexpected response of 09 April 2020 and for providing limited information.

There are numerous problems with the Department’s response:

Incorrect file format provided
My RFI2 stated that my request was for the Excel versions of the various files not PDF as supplied. The Department should also note that if these files contain information other than that supplied (e.g. closed items, notes, references to other files etc) then that falls within scope. Please supply the current Excel versions of the respective files, with all sheets, (see Innes v Information Commissioner [2014] EWCA Civ 1086) of the files without any editing other than the redactions being relied on.

Supplied Information & scope of my request
I must admit I was surprised for a programme as large and complex as Universal Credit that the:
- Risk register only contains 8 risks;
- Assumptions log is empty;
- Issues log only contains 1 issue; and
- Dependencies log only contains 12 entries.

Please confirm that this is correct. I am asking for confirmation as in the case FS50792926 (August 2019) the Department told the Commissioner it would take 5 hours “to locate and retrieve the information from the open Assumptions logs, pulling each strand log into one document and ensure that it is complete at the time that the requested information is being supplied.”

The Commissioner also asked the Department during her investigation:
“Normally RAID information would be held in separate formal logs or
registers to allow for ease of access and updating. This could be MS
Office documents (e.g. Word or Excel) held on a shared computer drive
or in specific IT applications that allow access for people working on the
programme or project.”

The Department responded:
“I can confirm that separate excel spreadsheets are used to log issues
risks issues and dependencies.”

If this means that if the UC programme has multiple current Excel spreadsheets for risks, issues & dependences then all of those fall within the scope of my request.

Redactions
The Department has not explained which exemptions apply to the various parts of the redacted information. Simply replacing information with “Redacted” without explaining the exemption being relied upon isn’t compliant with the FOIA.

The redactions are clearly excessive. For example, I can see no reason why every piece of information about certain risks, including dates, have been redacted.

S.31.1(a)
I do not believe that the Department has made out its requirements under the prejudice test to rely on this exemption. Due to measures such a multilayer security, including data encryption, that form part of the DWP security requirements (publicly available, e.g. DWP SS-018, dwp-ss005-security-standard-database-management-systems, dwp-ss030-security-standard-oracle-database-security and DWP SS-018 network security design standard) I do not believe that the prejudice claimed is real, actual or of substance.

I have no doubt that the UC IT is currently subject to regular cyber attacks and that manual processes are subject to attempts of fraud (published statistics show the suspected level of UC fraud). To make out its case here the Department will need to show a causal link between future attacks/fraud attempts and disclosure of the requested information. I suggest it will not be able to differentiate ongoing attacks/fraud attempts and those it claims are likely due to disclosure.

I suspect that the Department is actually concerned about the public perception of problems that do not reflect the narrative it has placed in the public domain around system security. An example might be the ongoing and very public problems with claimant identification verification. Bad PR is not covered by S.31.1(a).

Section 35(1)(a)
I suggest that this is an attempt to spread the scope of S.35 far beyond that intended by Parliament. Whilst it has been agreed that the development of Government policy is not always a fixed process what is being described by the Department clearly falls under implementation rather than Government Policy.

Section 40(2)
As my request specifically stated “Please note that personal information exempt under section 40(2) FOIA is specifically excluded from the scope of my requests” I do not object to these redactions as they fall outside of its scope.

Section 43(2)
The Department hasn’t come close to meetings its obligations under the prejudice test. This is a standard “boilerplate” response used by the Department numerous times before.

Public Interest Test
As I have pointed out several times before the Department has failed to meet the mandatory obligations identified by the Upper Tribunal in Department of Health v ICO & Lewis [2015] UKUT 159 (AAC) and subsequently upheld by the Court of Appeal in Department of Health v Information Commissioner & Lewis [2017] EWCA Civ 374.

The statements provided by the Department about the public interest test are clearly standard texts that I have seen in response to other requests for information.

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

Yours faithfully,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

This is an automated confirmation that your request for information has
been accepted by the DWP FOI mailbox.
 
If your email is a Freedom of Information request you can normally expect
a response within 20 working days.
 
However please be advised that due to the current situation with COVID-19
we cannot guarantee a response within this timescale.
 
Every effort is being made to respond to FOIs as we would usually but the
current situation means that available Departmental resources will be
needed on other high priority areas.
 
We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.
 
Email FOI responses will be issued from [1][email address]
We recommend that you add this address to your email contacts otherwise
the response may be treated as Spam or Junk mail.  
 
Should you have any further queries in connection with this request do
please contact us.
 
[2]http://www.gov.uk/dwp
 
 

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no-reply@dwp.ecase.co.uk on behalf of DWP Central FOI Team, Department for Work and Pensions

Dear John Slater,

Our Ref: IR2020/18178

Contact email: [1][DWP request email]

Thank you for your Freedom of Information (FoI) review request.

You can normally expect a response to your FoI review request within 20
working days. However due to the current situation with COVID-19 it may
not be possible for us to reply to you within this timeframe.

The DWP will make every effort to respond to FoI reviews as we would
usually but the current situation may mean that available Departmental
resources are needed on other high priority areas.

We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.

If you have any queries about this letter, please contact the department
using the email address and reference number above.

Yours sincerely,

DWP Central FoI Team

Department for Work and Pensions

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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 'Universal Credit - Current Versions of Risks, Issues, Dependencies & Assumptions Logs'.
I write inn respect of my internal review request submitted on 13 April 2020.

I agreed with the Commissioner when she concluded that it is reasonable not to place the Department under undue pressure during these difficult times. However, it is now clear that the Department has had time to adjust to new types of working and is performing well.

Neil Couling has been extremely vocal on Twitter about how well the Department has coped with the massive increase in Universal Credit claims. In addition, a DWP Minister (Will Quince MP) has written an article on the Politics Home website (see URL below) claiming that “Universal Credit is one of the success stories of the coronavirus crisis”:

“More than two million claims processed since mid-March. Over 900,000 advance payments made, reaching the accounts of those in most need within days. A peak of 2.2 million calls taken over 48 hours. More than nine in 10 eligible claimants receiving their money in full and on time – up on normal times, reaching a new record.”

https://www.politicshome.com/thehouse/ar...

In light of the above I have written to the Commissioner requesting that she restart with her investigations into complaints I have made previous about the DWP responses. I say that that any further failure of the DWP to comply with statutory deadlines and guidance issued by the Commissioner is for the sole purpose of frustrating my requests and is therefore unlawful.

I would be grateful if the Department provided its response without any further delay. Should it fail to do so I will of course ask the Commissioner to intervene.

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

Yours faithfully,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

This is an automated confirmation that your request for information has
been accepted by the DWP FOI mailbox.
 
If your email is a Freedom of Information request you can normally expect
a response within 20 working days.
 
However please be advised that due to the current situation with COVID-19
we cannot guarantee a response within this timescale.
 
Every effort is being made to respond to FOIs as we would usually but the
current situation means that available Departmental resources will be
needed on other high priority areas.
 
We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.
 
Email FOI responses will be issued from [1][email address]
We recommend that you add this address to your email contacts otherwise
the response may be treated as Spam or Junk mail.  
 
Should you have any further queries in connection with this request do
please contact us.
 
[2]http://www.gov.uk/dwp
 
 

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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 'Universal Credit - Current Versions of Risks, Issues, Dependencies & Assumptions Logs'.

The department has failed to provide a response to my IRR of 13 April 2020 and my IRR of 10 June 2020. I have allowed for the impact of the Covid-19 crisis and can only conclude that the department is now using the crisis as cover to ignore its statutory obligations under the FOIA. If I do not receive a response without further delay I will complain to the ICO.

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

Yours faithfully,

John Slater

DWP freedom-of-information-requests, Department for Work and Pensions

This is an automated confirmation that your request for information has
been accepted by the DWP FOI mailbox.
 
If your email is a Freedom of Information request you can normally expect
a response within 20 working days.
 
However please be advised that due to the current situation with COVID-19
we cannot guarantee a response within this timescale.
 
Every effort is being made to respond to FOIs as we would usually but the
current situation means that available Departmental resources will be
needed on other high priority areas.
 
We kindly ask for your understanding during this unprecedented situation
and we will aim to deal with your FOI request as soon as is practically
possible.
 
Email FOI responses will be issued from [1][email address]
We recommend that you add this address to your email contacts otherwise
the response may be treated as Spam or Junk mail.  
 
Should you have any further queries in connection with this request do
please contact us.
 
[2]http://www.gov.uk/dwp
 
 

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