Our Ref: FoI 1075 / IR 224. Your Ref: Date 16 June 2017

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1 Central FoI Team Caxton House 6-12 Tothill Street London SW1H 9NA Our Ref: FoI 1075 / IR 224 Your Ref: Formatted: Indent: Left: 0.06 cm Date 16 June 2017 Claimants-Rep request e9eeb7@whatdotheyknow.com Dear Mr Lotz, Thank you for your Freedom of Information request received 15 March 2017 and your follow-up dated 04 May 2017, in which you said Freedom of Information 15 March 2017 Can the DWP please provide element1 (the DWP team- -addresses) as described in para13 of the DWP submission (in case EA/2016/0262) from in the original form, i.e. all current such addresses-- from the third-party-supplier. + only if this is within the cost-limit, please also include element2 (the teamnames/descriptions) where these are readily available, + element3 (the locations) where these are readily available. But please note, that I am happy to extend the cost-limit by paying for a few extra hours. The below section "My Expectations" shall form part of this request too. If you still need more clarification or encounter a problem, please ask me immediately. My Expectations: If I may elaborate on what I expect regarding descriptions + locations (i.e. element2+3): When I set up a personal or generic/group address in e.g. hotmail or gmx, I am asked not only to select the -address, but also to provide my name or description (of the group) in the firstname + surname fields, + I am usually asked for a postcode or physical location. I expect the same principle to apply to the -addresses that the third-party-supplier holds for the DWP. I expect these details to be stored in the metadata. Where these fields are empty, I expect them to be left empty. I do not expect the DWP to go search for it manually or by sending out an to all team- -addresses, or similarly ridiculous proposals. I expect that adding the queries for element2+3, will only add maybe about 2hours (as they can probably simply be integrated into the query for element1). I do not consciously impose any obligation on the DWP to go through all team- addresses that are so supplied by the third-party-supplier. + I am aware that redactions should not come out of the cost-limit. But being mindful of the DWP's own sensibilities, I

2 like to allow them 1sec per -address for all necessary redactions/exemptions/etc. (-- this is 1sec per -address, not per different type of redaction or exemption that the DWP seek to apply). That said, I calculate the costs as follows: Retrieval of element1 = (less than) 7hours Adding element2+3 = 2hours Redactions etc. = (less than) 8hours I like to add, that I am prepared to pay, if the costs run a few hours over the limit. But my calculation suggests, that --even if it would take 3times as long to add element2+3-- it really shouldn't breach the cost-limit." Internal Review request 04 May 2017 Please read the whole request including the section "My Expectations". Unless a substantial disclosure of the requested information is imminent, the requester hereby asks for an internal review of the handling of this request. As already submitted with the original request (on ) the requester states: " 8) With regard to section36, I understand the DWP's position as follows [...]. The DWP argues: ' Claimants are already provided with DWP contact details if they want to challenge a benefit entitlement decision they disagree with. The key point here is that DWP, as a very large customer facing department, has in place well established and transparent communication channels for use by its wide range of customers. Releasing into the public domain many thousands of internal addresses would thwart that strategy to the detriment of the customer and the Department's ability to deliver an effective and managed service. ' 9) My response is, that I strongly disagree with the assumption that claimants are already provided with sufficient contact details. 10) While I have no interest in making the service less effective for claimants, I believe the current strategy only reflects the DWP s goal of minimising its own legal risks + legal responsibility, which ultimately leads to unaccountability. 11) Much of the current DWP strategy involves electronic forms (eforms). However, there are several reasons why eforms are unsafe and inappropriate. Most importantly this affects the accuracy of the captured information, as eforms limit the reality that they are trying to capture to what the eform designer was able to think of and allowed to include. + information that is inaccurate (at input, due to input-limitations or oneway-navigation) or that is stored out-of-context is likely to lead to a serious misrepresentation of the circumstances of the person submitting the information. With eforms submitters are prevented from rectifying such issues as any misrepresentations would remain unbeknown to the submitter, or oneway-navigation would not allow for an opportunity to do anything about this. For a more detailed list of issues please see the following article: 12) I am also concerned that the current DWP strategy does not only not-care about, but does actively endanger claimants' well-being + financial security + above all claimants' ability to back up their case, when they are wrongly accused of a failure to comply or when they appeal a decision (e.g. at social security tribunals) as well as their

3 ability to prove that they had complied with requirements + submitted information (including notifications) in time. 13) + the ability to the team that deals with a claimant's case can provide evidence that is essential to a functioning modern justice-system. While it is overstated by the DWP's policy that is not secure, any that prima face was sent, can (as far as I know) by forensic analysis be proven to have come from one sender or not. This overstated argument in the DWP policy is therefore close to meaningless. 14) At present, claimants in general are not given dedicated -addresses of DWP teams that make decisions about their claims. For claimants to only be able to contact decision-makers after a decision has been made is unhelpful, + is prohibiting claimants from (being able to) submitting evidence before a decision is made + to do so at no cost, + at an instant, + to retain proof. is superior to the slow direct-mail, as it is free + instant, + DWP policy gives claimants often only a very narrow timeframe to bring their arguments, before (or between that they are being made aware of a problem +) a decision is being made about them, or before their money is being suspended. " Please also note the report submitted by NAWRA, which provides further evidence relating to the difficulties that claimants and their advisers experience when communicating with the DWP, and also comes to the conclusion that "The benefits [of accepting ] vastly outweigh any perceived risks. This is a free communication tool used by the Tribunal service and local authorities very effectively. It generates evidence of sending, whilst also proving receipts. It also helps ensure that at least outward communication (such as evidence sent by claimants) is kept and not lost." (page13) "This will have the effect of reducing barriers and helping to limit maladministration and lost evidence." (page21) DWP Reply As you will know, the information you have requested is held on the Department s behalf by a 3 rd party supplier and is not readily available from centrally held records. In order to comply with your request, the Department has retrieved the information from the 3 rd party supplier. The Department has identified 32,000 team addresses falling within the scope of your request. This list consists of a combination of public facing addresses and addresses which are solely for internal use. I attach a list of some of the public facing addresses we hold. Others will be sent to you in batches. This is explained in more detail in the background section below. Team addresses which are solely for internal use are however being withheld. Their release would, or would be likely to, prejudice the effective conduct of public affairs and are exempt from disclosure by virtue of 36(2)(c) of the Freedom of Information Act. This exemption is subject to a public interest assessment.

4 There is a public interest in increased transparency and accountability of public officials and in ensuring that DWP s customers are able to contact the Department effectively and easily. The Department already publishes all the contact details customers need when accessing any of the DWP services, on gov.uk. In addition, all correspondence issued to DWP s customers contains contact details, including an address and telephone number and are able to contact DWP before and after decisions are made. Release of thousands of internal addresses would risk undue interference in DWP s delivery strategy and make DWP more vulnerable to denial of service attacks. On balance the Department is satisfied that the public interest in maintaining the exemption outweighs the public interest in disclosure so internal s are being withheld. Background To be helpful we also provide background on how a team address is set up within DWP: A DWP user will complete an electronic request form, it is worth noting that this individual may not be part of the team requiring the team address. The details captured on the form are: The user s name, staff number, location and the name of the team address to be set up are provided. There is no mandatory requirement to supply the name of the team (or group) or the physical location. Equally there is no restriction on the naming convention of the team address (i.e. if the team is a JSA team, there is no requirement to include JSA in the name of team address) A DWP administration team then set up the team address. The details captured in the administration database are the team address and the location of the user. It is important to note that this may not necessarily be the location of the team. Equally the address database is for administration purposes only and does not have a reporting functionality. Once the team address is set up, the details link into the 3 rd Party Supplier database, who manage the service for DWP. The only detail held in the data base is the name of the team address and the location indicated by the requestor. The metadata does not contain any other information, such as the job title or the location of the team. Equally it is not apparent from this data whether the team address is for internal use only. As the information is not readily available, DWP has engaged with its 3 rd Party Supplier to identify and redact any team address that does not receive external s and are therefore deemed for internal use only. The

5 owners in scope for this FoI request were contacted to confirm they are for use by the general public, details of job title and location were then provided. Please note, not all team members are always situated in the same location. Obtaining this detail took a minimum of 1 ½ minutes per . The action taken to identify addresses which are solely public facing, locations and team names for public facing addresses has been extensive and time consuming. Given the volumes involved it has imposed a significant burden on the Department. You should be aware that, in addition, over 6,000 s have required redaction work to protect individual privacy. We estimate that the overall burden of dealing with this equated to 18 days of work (in reality this took much longer to accommodate follow up activity) We propose to send you the team addresses in batches to mitigate this impact. The Department may take this burden into consideration in the handling of any future requests you may submit in the future on the same, or a similar, subject matter If you have any queries about this letter please contact me quoting the reference number above. Yours sincerely DWP Central Freedom of Information Team