FOI/202600521596 · FOI · not held
Social Security Scotland - Adult Disability Payment application processing disparities by language profile: FOI release
Information requested
Please provide all data broken down into three distinct comparative categories based on the client's recorded language preference, **"Communications needs indicator"**, interpreter requirement flag, or any equivalent language/communication field held within any SSS system (including but not limited to the SPM case management system, the online portal database, CRM, or telephony logs):
1. English, 2. Polish, 3. All Other Non-English combined.
Request for information 1:
SUBMISSION FUNNEL DISPARITIES — BY APPLICATION CHANNEL
How many ADP applications were initiated (Part 1 submitted) across these three language categories? Of those initiated, exactly what percentage successfully resulted in a Part 2 being generated and made available to the claimant?
Please break down the figures separately by APPLICATION CHANNEL:
i) Online portal ii) Telephone (without interpreter) iii) Telephone (WITH interpreter) iv) Paper form
(Note: Do not limit this to applications that generated a visible "error code". I am asking for the total conversion rate from Part 1 submission to Part 2 generation across all three channels.)
Request for information 2:
THE "SURVIVOR BIAS" PROCESSING TIMELINE — QUARTERLY BREAKDOWN
For applications where Part 1 was submitted during the financial years 2022/23, 2023/24, 2024/25, and 2025/26 (to date), please provide the median processing time (in calendar days) from Part 1 submission to final closure, broken down BY FINANCIAL QUARTER (from Q1 2022/23 to the most recent completed quarter) and into two separate sub-categories for each language group:
a) Applications that resulted in a final determination (Award/Rejection). b) Applications that were closed, withdrawn, expired, or otherwise terminated prior to a determination being made (e.g., due to system timeouts or alleged claimant inactivity).
(Note: Quarterly granularity is essential to identify seasonal spikes or periods following system updates. Aggregated two-year averages are insufficient.)
Request for information 3:
SYSTEM-INDUCED ABANDONMENT (Broad Catch-All)
Of all the applications initiated across the three language categories, what percentage were administratively closed, purged, marked as withdrawn, expired, or otherwise terminated prior to a final determination being issued, regardless of the specific internal closure code or reason recorded by SSS?
Please provide these abandonment/drop-off figures broken down into two distinct phases:
a) Applications abandoned/closed at Part 1 (failed to progress to Part 2). b) Applications abandoned/closed after Part 2 was generated but before a final determination.
Furthermore, for both phase (a) and phase (b), please provide a percentage breakdown of the specific internal closure reasons/codes used (e.g., 'claimant inactivity', 'withdrawn', 'timeout', 'failure to provide information', etc.) across the three language categories.
Request for information 4:
RE-DETERMINATION AND APPEAL RATES BY LANGUAGE
Of all ADP determinations made across the three language categories:
a) What percentage of determinations were followed by a request for re-determination? b) Of those re-determinations, what percentage resulted in the original decision being overturned in the claimant's favour? c) What percentage of cases escalated to the First-Tier Tribunal?
(Note: Disproportionately low re-determination rates for Polish-speaking clients, combined with high overturn rates when they do appeal, would indicate systemic discouragement rather than correct initial decision-making.)
Request for information 5:
DATABASE STRUCTURE VERIFICATION (Duty to Assist)
If SSS claims that language preference data is not stored in a structured database field that allows automated reporting, please fulfil your Section 15 duty by providing:
a) The Data Dictionary and Logical Data Schema for the SSS online portal, CRM, or primary client user profile databases, confirming how language preference is logged. b) A statement confirming whether any of your core client record databases (including but not limited to SPM, the portal, or CRM) record the client's primary language, interpreter requirement, or communication need as a searchable and reportable field. c) A statement confirming whether a non-English language flag or interpreter requirement triggers any automated routing, segregation, or placement of the application into a distinct processing queue (e.g., a "complex case" or "specialized" queue) distinct from the standard English workflow.
Request for information 6:
FALLBACK: SECTION 17 TRAP
If SSS issues a Section 17(1) notice ("information not held") for questions 1-4, please confirm: How does SSS currently monitor compliance with its Public Sector Equality Duty (Section 149, Equality Act 2010) and its Social Security Charter commitments to "treat everyone equally, fairly and without discrimination" (Charter Expectation A.3) if it cannot disaggregate service delivery data by language/ethnicity?
Response
The data used in this response has been collated using the data field ‘Language preference’, which relates to the question asked in the application form on preferred language to be used in communications. It is not compulsory to answer this question, so we have a lot of blanks. As the default is English, we can assume that ‘blank’ equals English. However, we’ve presented them separately in our analysis because that’s how they’re categorised in our data.
Request for information 1:
While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have some of the information you have requested. This is because we are unable to identify those that used an interpreter.
This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.
Please see Table 1 of the attached document, which provides some of the information requested.
Social Security Scotland does not hold information showing whether submission of Part 1 resulted in Part 2 being generated or made available to the applicant.
Part 2 is routinely made available as part of the application process, regardless of the method used to submit Part 1.
For example:
Online applicants may complete Parts 1 and 2 during the same online session. Applicants applying by telephone are issued with a Part 2 form following their Part 1 application. Applicants requesting paper forms receive both parts of the application process.
As the specific measure requested is not recorded, this is a formal notice under section 17(1) of FOISA that the information is not held.
Request for information 2:
Please see Table 2 of the attached document, which provides some of the information requested.
While our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing some of the information requested would exceed the upper cost limit of £600.
We are unable to establish those denied at identify and verification, those who didn’t return a part 2 form, or those who were found to not meet the part 2 eligibility criteria, without specialist staff members designing specific coding to undertake the required complex analysis, something which we are not required to do under FOISA. Therefore, the only means of obtaining all of the requested information would involve manually checking over 300,000 determined applications.
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.
You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600. Unfortunately, due to the large number of cases that would require manual checking, it is difficult to advise how you might be able to narrow the scope of your request to bring it within the cost limit of £600.
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
An exemption under section 38(1)(b) of FOISA (personal information) applies to a small amount of the information requested because it is personal data of a third party, i.e. given the low numbers of applicants, we are satisfied that there is a realistic prospect that releasing the information risks releasing personal information, 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.
Request for information 3:
Please see Table 3 of the attached document, which provides some of the information requested.
While our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing some of the information requested would exceed the upper cost limit of £600.
We do not hold data on internal closure reasons such as 'claimant inactivity', 'timeout', 'failure to provide information'.
To enable us to determine the reason for an application being withdrawn or denied, we would need to manually access over 400,000 cases. 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.
You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600. Unfortunately, due to the large number of cases that would require manual checking, it is difficult to advise how you might be able to narrow the scope of your request to bring it within the cost limit of £600. 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
Request for information 4:
While our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing the information requested would exceed the upper cost limit of £600.
This is because we would need to manually check over 50,000 ADP redeterminations and appeal cases to determine the information requested. 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.
You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600. Unfortunately, due to the large number of cases that would require manual checking, it is difficult to advise how you might be able to narrow the scope of your request to bring it within the cost limit of £600. 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
Request for information 5:
The language preference is asked in the application form as “preferred language to be used in communications”. We can extract this captured information from our client record platform.
Request for information 6:
Social Security Scotland has internal management reporting processes and governance groups in place to monitor public sector equality duty compliance. Public sector compliance is reported on every two years through the mainstreaming equality reports. The report from previous years can be found via the dedicated page on our corporate website with the next mainstreaming equality report 2027 due to be published in June 2027.
The Charter Measurement Framework is published annually alongside our Annual Report and Accounts. It reports evidence on how Social Security Scotland and the Scottish Government are delivering on Our Charter commitments. Measures 1 to 7 are most relevant for the Charter commitments to "treat everyone equally, fairly and without discrimination".
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.
Detected exemption language
(Note: Disproportionately low re-determination rates for Polish-speaking clients, combined with high overturn rates when they do appeal, would indicate systemic discouragement rather than correct initial decision-making.) Request for information 5: DATABASE STRUCTURE VERIFICATION (Duty to Assist) If SSS claims that language preference data is not stored in a structured database field that allows automated reporting, please fulfil your Section 15 duty by providing: a) The Data Dictionary and Logical Data Schema for the SSS online portal, CRM, or primary client user profile databases, confirming how language preference is logged. Request for information 6: FALLBACK: SECTION 17 TRAP If SSS issues a Section 17(1) notice ("information not held") for questions 1-4, please confirm: How does SSS currently monitor compliance with its Public Sector Equality Duty (Section 149, Equality Act 2010) and its Social Security Charter commitments to "treat everyone equally, fairly and without discrimination" (Charter Expectation A.3) if it cannot disaggregate service delivery data by language/ethnicity? This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested. As the specific measure requested is not recorded, this is a formal notice under section 17(1) of FOISA that the information is not held. 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.