SCVO Consultation response: DWP Universal Credit data sharing between DWP and local support providers

SCVO welcomes the Department of Work and Pension’s (DWP) consultation on Universal Credit data sharing. This is an important issue for Scotland's charities and voluntary organisations, many of whom support some of Scotland's most vulnerable claimants. Please note that with the consultation taking place over the winter break period, there hasn’t been enough time to consult with our membership. We understand other umbrella bodies such as the SFHA have expressed similar concerns. As such, we feel the implementation date of March 2015 is too soon. We will therefore provide high-level comments only. SCVO strongly agrees with a joined-up approach to social security support and the sharing of data to this end. However, the key principle for us is that claimants should by default have ownership over data held by them, at all points of their journey through the support system. We strongly disagree with any drive to force claimants to share personal data with other agencies under the threat of benefit sanctions. Some points to consider generally and in response to Consultation Question 5:

• We believe that individuals should hold their own data and share it where they choose. Individuals should not be forced to share personal details and take part in support work under the threat of having their benefit claim undermined
• Data protection is employed in the UK for a reason. Forcing individuals to share details with (unidentified) members of Service Delivery Partnerships will be a barrier to those who do not trust the system. When service involvement is mandatory the relationship between the service provider and claimant is compromised
• Mandatory involvement in a support scheme disempowers people i.e. “we know what is best for you”. We believe this can undermine the ability for people develop the self-confidence to be job ready
• As a result of particular vulnerabilities, many of the claimants our sector works with may struggle to understand the consequences of data sharing, or of choosing not to share personal data, even with support
• There needs to be more detail on the bodies who will hold the shared information and what they will use it for. This needs to be shared with the claimant from the very beginning allowing them to choose whether they share their personal data or not
• Section 4.2 proposes that the need for 'relevant information' to be shared will be determined on a case by case basis. Who will determine this, on what authority and under what scrutiny? Despite our deference to ownership of data by the claimants themselves, we recognise that in certain cases, information on individuals may need to be shared by others on their behalf. This needs the utmost care and scrutiny and should be the exception, not the rule

Contact

Ruchir Shah, Policy Manager 0131 474 6158 Ruchir.shah@scvo.scot

About us

The Scottish Council for Voluntary Organisations (SCVO) is the national body representing the third sector.There are over 45,000 voluntary organisations in Scotland involving around 137,000 paid staff and approximately 1.2 million volunteers. The sector manages an income of £4.4 billion. SCVO works in partnership with the third sector in Scotland to advance our shared values and interests. We have over 1300 members who range from individuals and grassroots groups, to Scotland-wide organisations and intermediary bodies. As the only inclusive representative umbrella organisation for the sector SCVO:

• has the largest Scotland-wide membership from the sector – our 1300 members include charities, community groups, social enterprises and voluntary organisations of all shapes and sizes
• our governance and membership structures are democratic and accountable - with an elected board and policy committee from the sector, we are managed by the sector, for the sector
• brings together organisations and networks connecting across the whole of Scotland
• SCVO works to support people to take voluntary action to help themselves and others, and to bring about social change. Our policy is determined by a policy committee elected by our members.^[1]

Further details about SCVO can be found at www.scvo.scot. [1] SCVO’s Policy Committee has 24 members elected by SCVO’s member organisations who then co-opt up to eight more members primarily to reflect fields of interest which are not otherwise represented. It also includes two ex officio members, the SCVO Convener and Vice Convener.