Work and Pensions & Inland Revenue Longitudinal Study
It is just so hard keeping up to date with all the potential privacy threats by all the UK Government departments:
The Department for Work and Pensions Longitudinal Study was announced in Parliament in a written statement by the Secretary of State for Work and Pensions Andrew Smith on the 16th December 2003:
"The Secretary of State for Work and Pensions (Andrew Smith): From January 2004, the Work and Pensions longitudinal study will link benefit and programme information held by the DWP on its customers, with employment records from the Inland Revenue.
This follows the Employment Act 2002 which introduced new data sharing provisions. This opened the way for the DWP to receive more data on employment from Inland Revenue and use the information for more purposes. The DWP and Inland Revenue have been working together to enable this data sharing to take place and to develop safeguards for the initiative.
The Work and Pensions Longitudinal Study will be used to perform a range of statistical and research analyses, as well as being used for some limited operational purposes, to give the Department further opportunities to evaluate the effectiveness of its businesses. It will, for example:
- provide statistics, management information and research on the success of Jobcentre Plus in helping people into work and keeping them in work;
- help to evaluate individual DWP policies and their impact in the short, medium and long-term;
- help to ensure that pensioners receive the money they're entitled to;
- aid in the investigation of benefit fraud; and
- improve targeted information and marketing to clients.
The DWP have a legal and ethical responsibility to ensure that the Work and Pensions longitudinal study is used appropriately. We have, therefore, developed a set of safeguards around access rights, system monitoring, storage/retention of the information and vetting new uses. Information on this and a full range of the study's uses, has been placed in the Library and on the DWP website at http://www.dwp.gov.uk/asd/longitudinal_study/ic_longitudinal_study.asp"
Some obvious questions not answered by the Safeguards section of the DWP website:
- By inviting new "business cases" to be judged, it seems that there is no limited scope to this "Study". Should it in fact be more properley decribed as open ended "Gateway" process, permanently linking the DWP and IR databases, which will never end ?
- Where is the publicly available Privacy Policy under which this study will take place ?
- The study has already started in January 2004, so who exactly is serving on the Ethics Committee and how can they be contacted ?
- Will this just be a random selection of records from the Department for Work and Pensions and the Inland Revenue, or will it attempt to analyse and cross reference all of them ?
- How often will the combined datasets be compiled ? Will this be on a batch basis, or on demand ?
- Will external academic or commercial consultants be used to conduct this study, or will access be confined to civil service statisticians and IT staff ?
- Will the Inland Revenue be given reciprocal access to the Department for Work and Pensions records ?
- With whom will the combined datasets be shared, and why ?
- How long will such combined datasets be retained for ?
- Will such combined datasets be destroyed once the statistics have been aggregated ?
- Will explicit individual permission be sought from each person whose data is to be analysed by this study or not ?
- Will individuals have to play ?10 Data Protection Act roulette in order to ascertain if their records have been "studied" yet or not ?
- Why is abuse by DWP employees only considered to be an internal disciplinary offence, and not to be prosecuted criminally under the Official Secrets Act, especially as the individually identifiable data is to be Protectively Marked at the level of "Confidential" ?
"Work and Pensions Longitudinal Study - Safeguards
The following details the safeguards DWP have put in place to ensure we are being seen to be behaving responsibility with the data within the Work and Pensions Longitudinal Study.
Restricting access
Only those with genuine business needs are allowed access to the data and that access is kept to the minimum level necessary for the purposes of the Department. All users will be asked to submit a business case. Three versions of the data will be kept and accessed as follows:
Version 1 - fully identifiable, 24 year history, accessible only by those who will be linking in the Inland Revenue data;
Version 2 - anonymised, 24 year history, available to analysts for statistical and research purposes;
Version 3 - fully identifiable, 1 year history, used for operational purposes (most notably fraud and error).
Ethics Committee
An ethics committee will be established to consider proposals which have a significant ethical dimension. The Head of Data Services in DWP will be responsible for day-to-day decision-making on access to the data. The Ethics Committee will monitor the decisions and will advise on those decisions which the Head of Data Services has referred to the Committee. The Committee will consider expert legal advice and will be made up of statistical and research experts as well as representatives of employers and individuals.
Quarterly publication of the uses
To ensure that DWP are accountable to the public for all work on the data, an internet and paper-based list of uses (existing and new) will be published every 3 months.
Monitoring user activity
Any users with unusual patterns of activity will be picked up and monitored using specialist software. Illegal and unethical misuse of the data constitutes a breach of the terms and conditions of DWP employment and can result in disciplinary action and ultimately dismissal.
Monitoring the uses of data
DWP will monitor which records and data items are being used and ensure that Inland Revenue supplies only the minimum number of records and variables necessary for effective use for operational and analytical purposes. This review process will take place every 12 months.
Public access rights
Individuals will be able to request a copy of the data DWP hold on them for operational purposes within the Master Index of the Work and Pensions Longitudinal Study. Data protection printouts are available from the IAD Information Centre (0114 2098024).
Involvement of the Information Commissioner
DWP have consulted with the Information Commissioner's Office on the above safeguards, and will continue to do so, with the view that the Information Commissioner will audit the Work and Pensions Longitudinal Study during 2004/5.
Contact point for further information:
email wpls@dwp.gsi.gov.uk
Call IAD Information Centre on 0191 2255563"