Dear Department for Work and Pensions,

I refer to the The Government Communication Service guide to communications and behaviour change - https://gcn.civilservice.gov.uk/wp-conte....

In particular, firstly, I refer to page 5: "Behavioural theory is a powerful tool for the government communicator, but you don’t need to be an experienced social scientist to apply it successfully to your work. "

I should like to ask what ethical guidelines are in place regarding the use of behavioural theory on claimants. What guidelines are in place to protect claimants from any potential adverse effects of trials and experiments using methods aimed at changing behaviours of claimants? And what method of gaining claimant consent (to be used as a subject in trials and experiments ) is used by the Department and by job centres?

Secondly, I refer to page 19, specifically:
"Behavioural principles
A Jobcentre work coach letter was re-designed to include a range of behavioural insights. The letter appealed to social norms by including the message that 7 out of 10 people found the training course had helped them with their job search. A verbal and written commitment that they will attend (I will attend this course on x day/time) was required to “lock” respondents into the event. The letter also emphasised that places were limited, highlighting the value of the event.
What was the impact?
Applying behavioural principles to the letter increased the attendance of young people at jobcentre interviews by 30% over a six week period, compared to the control group. The extrapolated return is estimated at £25,000 over a 12 month period."

Firstly, I should like to ask if the claim used "to appeal to social norms" - that "7 out of 10 people found the training course had helped them with their job search" - is actually true, or is it used only as an illustration, or an example of "applying behavioural principles" as an incentive? If it is true, is there evidence of the claim that 7 out of 10 people found the training course helped helped them?

Secondly, I should like to ask if there is any evidence that behaviour principles, behaviour change and positive employment outcomes are correlated. How does the DWP discern between compliance with conditionality rules, off-flow and employment?

Finally, I should like to ask what "The extrapolated return is estimated at £25,000 over a 12 month period" means. In what sense is it a "return" and how was the figure arrived at?

Yours faithfully,

Susan Jones

Dear DWP CAXTON HOUSE Communications,

You confirm that you have the information that I requested, but then claim that it would exceed the £600 limit to provide that information which you state is because of the "estimated cost of one person spending 3½ working days in determining whether the Department holds the information, and locating, retrieving and extracting it."

If you confirm you have the information, then surely that reduces the cost and time spent retrieving and extracting it to comply with my request.

I will however simply my request. Most people would expect that ethical guidelines, safeguards and the important matter of client consent to participating in Government trials and experiments on people needing welfare support is something that the DWP would have to hand - easy to retrieve and very important information that one would expect to be in the public domain in any case. But I can't find it.

I refer again to the The Government Communication Service guide to communications and behaviour change - https://gcn.civilservice.gov.uk/wp-conte...

In particular, I refer to page 5: "Behavioural theory is a powerful tool for the government communicator, but you don’t need to be an experienced social scientist to apply it successfully to your work. "

I should like to ask what ethical guidelines are in place regarding the use of behavioural theory on claimants.

What guidelines are in place to protect claimants from any potential adverse effects of trials and experiments using methods aimed at changing the behaviours of claimants?

And what method of gaining claimant consent (to be used as a subject in trials and experiments ) is used by the Department for Work and Pensions and by job centres?

Yours sincerely,

Susan Jones

Dear DWP CAXTON HOUSE Communications,

To clarify, I meant "simplify" my request, not "simply". Apologies for the typo.

Yours sincerely,

Susan Jones

Dear DWP CAXTON HOUSE Communications,

I refer to your first response: "Under section 16 of the Act we should assist you in helping you narrow your request so that it may fall beneath the cost limit. It may help to reduce the number of questions by refocusing it to only a few elements of the presently broad request. We will consider a fresh any revised request however we cannot guarantee that any revised request will fall within the cost limit."

I subsequently submitted a narrowed and focussed request in response, with just 3 basic questions from the initial FOI request. You responded by refering to my original request, and completely ignored my amended and narrowed down, shorter request.

I am therefore making a formal complaint that you did not address the reduced, simplified and narrowed down request. I am asking for an internal review.

I asked:

"I should like to ask what ethical guidelines are in place regarding the use of behavioural theory on claimants.

What guidelines are in place to protect claimants from any potential adverse effects of trials and experiments using methods aimed at changing the behaviours of claimants?

And what method of gaining claimant consent (to be used as a subject in trials and experiments ) is used by the Department for Work and Pensions and by job centres?"

You have stated that you do have this information. As I have considerably narrowed down the request to 3 very basic questions, the costs involved in retrieving and providing it ought to be quite minimal. It's also a very reasonable request. The DWP works with some of our most vulnerable citizens. It is especially important that in light of the current experimental nature of behavioural theories, and the current trialing of the new government health and work programme, that there are ethical guidelines and safeguards in place to protect vulnerable clients, and also, that there is a mechanism for gaining informed consent from clients who are subjects of trials and experiments.

These are issues that researchers within the medical sciences and social sciences have to consider every day. Using behavioural modification ("behavioural change theory") methods on citizens without their consent and without engaging their deliberative processes has enormous ethical implications.

The British Psychological Society , for example, has strict code of conduct and human research ethics - http://www.bps.org.uk/sites/default/file...

And I refer to the Helsinki Declaration regarding medical research - http://www.ncbi.nlm.nih.gov/pmc/articles...

The Geneva Declaration - https://en.wikipedia.org/wiki/Declaratio...

And the the Nuremberg code includes such principles as informed consent and absence of coercion; properly formulated scientific experimentation; and beneficence towards experiment participants - https://en.wikipedia.org/wiki/Nuremberg_...

These are just a few examples of codes of ethics regarding human research.

There are a wide range of legal and Human Rights implications connected with experimentation and research trials conducted on social groups and human subjects. My request for clarification that there are ethical guidelines, safeguards and protections for subjects and basic consent mechanisms in place and the details of what they are is therefore a very reasonable one.

Yours sincerely,

Susan Jones

Dear DWP Strategy Freedom of Information,

I am writing further to my request for an Internal Review regarding my FoI. To clarify, my complaint is that the original request was refused on the grounds that it would exceed £600. However, the response from the Department indicates incorrectly applied costs, as despite confirmation that the information I requested exists, the Department then added the costs of determining whether the Department held the information as part of the costs. It isn't likely that the original request "represents the estimated cost of one person spending 3½ working days in determining whether the Department holds the information, and locating, retrieving and extracting it." The estimated costs of finding, retrieving and extracting the information were unsupported with any accompanying cogent evidence.

I subsequently shorted my request, and the Department responded to my initial response again, without consideration of my amended and shortened request. The shortened request was for 3 closely related/interconnected, pieces of information, all related to a code of ethics regarding research, the costs of finding and retrieving this could therefore be easily reduced. In fact the related information I asked for is what one would expect a government department to have under effective records management, and to be relatively easily retrievable.

Again, no evidence of costs was included, and the response I received to my second submission wasn't related to that submission, it was the same response I had for my first request, despite the fact my amended request was much shorter with significantly fewer and more focussed, questions, those I did ask are closely related. The Department also failed to explain how I could can bring my request within the acceptable cost limit, which is a breach of section 16.

Section 16 of the FoI Act places a duty on public authorities to provide reasonable advice and assistance to applicants. I was not provided with "advice or assistance." I was not asked if I prefer to narrow my request in an alternative way (this is a breach of the section 16 duty to advise and assist).

I haven't received any information at all from my request, and I am dissatisfied by both responses which addressed only my first, longer request, I had no response to the amended and shorter, more focussed version of the request, or further advice about how to reduce costs of my request.

Yours sincerely,

Susan Jones