Social Security Scotland - staff guidance for refusal of Adult Disability Payment on identity grounds: FOI release

Information requested

PERIOD: 21 March 2022 – 30 May 2026

PART 1 – SECRET ORDERS TO CUT COSTS

1. All written directives, performance targets or "management expectations" to SSS staff to reduce ADP approvals to meet budget.
2. All emails/Teams messages of senior managers with "budget savings", "cost control", "approval rate target", "fiscal sustainability".
3. All minutes where Ministers discussed ADP spend pressures.
4. All correspondence between Cabinet Secretary for Social Justice and SSS CEO on reducing ADP expenditure.

PART 2 – IDENTITY TRAP REFUSALS

5. Annual totals of ADP applications refused solely for "identity not verified" 2022/23-2025/26.
6. All guidance, checklists and training slides used to refuse on identity grounds.
7. All complaints and appeals where identity was the refusal reason, with outcomes.
8. All internal audits of identity refusal rates by local authority.

PART 3 – COLLAPSE OF APPROVALS

9. All analysis explaining fall from 69% approval (2022 launch) to 53% (Oct 2023).
10. All current data on approval rates for 2024/25 and 2025/26 to date.
11. All comparisons of ADP vs PIP approval rates (PIP 50% Oct 2023).
12. All documents discussing ADP's founding principle of dignity and fairness vs falling rates.

PART 4 – DELAYS AND SABOTAGE
13. All reports on ADP processing times exceeding 12 weeks, by month.
14. All internal emails about "clearance time backlogs", "staff shortages", "intentional slowing".
15. All instructions to staff to pause or delay decisions.
16. All complaints from MSPs about ADP delays.

PART 5 – WHO KNEW
17. Names/titles of officials who signed changes to decision-making guidance affecting approvals.
18. All submissions to Ministers warning approvals would drop below PIP levels.
19. All Ministerial responses authorising continuation

PART 6 – DWP "ENEMY" NARRATIVE
20. All communications referring to DWP/PIP as "hostile", "enemy", "Westminster system", "cruel".
21. All media lines comparing ADP favourably to PIP after Oct 2023

PART 7 – LEGAL AND COVER-UP
22. All legal advice on compliance with Social Security (Scotland) Act 2018 principles after approval fall.
23. All draft statistics where approval data was removed or reworded.
24. All FOI responses on ADP where information was withheld under cost limits.
25. All WhatsApp/Signal messages on corporate devices re ADP costs (if held).

PART 8 – IMPACT
26. All equality impact assessments on effect of lower approvals on disabled people.
27. All data on increased appeals to tribunals due to ADP refusals.
28. All lessons-learned reports on ADP implementation failures.

Response

Your request for information 6 -

In response, please see documents -

• ‘FOI519124 - Deny Adult Disability Payment based on part 1 of an application’
• ‘FOI519124 - The individual's identity needs authenticated and verified’.

In addition, we publish our ADP Decision Making Guide on our website; Adult Disability Payment decision making guide - Social Security Scotland

Your request for information 10 and 13 -

The information you have requested is available from our website. Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the Social Security Scotland website, then please contact me again and I will send you a paper copy; Adult Disability Payment statistics to 30 April 2026 - Social Security Scotland

Section 12 – Cost of Compliance –

We have considered all your request, separately. However, we have concluded that there are interconnected parts that require interrogation of the same data sets to collate the information to respond.

The Scottish Information Commissioner advises that if one or more parts or questions of the request require interrogation of the same information, then we can conclude that they are interconnected and the cost fee can be applied across these.

We have concluded that providing a response to your requests for information 1, 2, 3, 4, 5, 9, 11, 12, 14, 15, 16, 18, 19, 20, 21, 22, 23, 25, 27 and 28 would require extensive searches of interconnected information across:

Email mailboxes,
Teams Messages
Corporate System
Structured and unstructured records

This would involve manual review and interpretation of large volumes of material across a period of more than four years held by many staff members.

Therefore, while our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing the information requested for these parts would exceed the upper cost limit of £600.

Under section 12 of FOISA public authorities are not required to comply with a request for information if the authority estimates that the cost of complying would exceed the upper cost limit, which is currently set at £600 by Regulations made under section 12.

As an example of the type of searches we would need to conduct in order to retrieve the information you have requested; based on a sample size exercise conducted of our Chief Executive Officer’s mailbox, we conservatively estimate that 40,000 emails would need to be manually reviewed as a bare minimum, to provide a small part of the information you have requested.

You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600, such as by reducing the scope of your ask to specific questions or reducing the time period sought to a quarter, for example. You may also find it helpful to look at the Scottish Information Commissioner's 'Tips for requesting information under FOI and the EIRs' on his website at: https://www.foi.scot/how-do-i-ask

In response to part 24, we do not publish FOI responses that have been fully withheld under section 12 of FOISA. We do however publish full and partial (including where section 12 has been applied in part) responses to Freedom of Information requests submitted to Social Security Scotland on our website. To locate and retrieve all responses that fall within the scope of your request, we would need to undertake an extensive manual exercise to retrieve the information. To do so would exceed the upper cost limit for complying. As part of our duty to advise and assist, all published responses can be found here;
Publications - Social Security Scotland

Section 17 – Information not held –

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not hold some of the information you have requested. This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested in the below requests for information.

Request for information 7 –

Linking the relevant data sets is not possible without undertaking new and complex analysis. Further processing times breakdowns are not available without specialist staff members designing specific coding to undertake the required complex analysis, something which we are not required to do under FOISA.

Request for information 8 -

This information is not held by Social Security Scotland. This is because an internal audit of this data has not been carried out.

Request for information 26 -

Social Security Scotland follows a holistic approach to Equality Impact Assessments (EQIAs) that take a wider look at the benefits we deliver to the people of Scotland. As such, we do not hold an EQIA on your specific ask.

Section 38 – Personal data –

Your request for information 17 -

An exemption under section 38(1)(b) of FOISA (personal information) applies to the information requested for part 17 because it is personal data of a third party, ie the names of individuals who signed changes to guidance and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.

About FOI

The Scottish Government is committed to publishing all information released in response to Freedom of Information requests. View all FOI responses at https://www.gov.scot/foi-responses.

FOI 202600519124 - Information Released - Document 1

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PDF

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93.0 kB

FOI 202600519124 - Information Released - Document 2

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77.4 kB