Response 290524610

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Name
David E Alexander

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Individual
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Organisation
Mydex Data Services Community Interest Company

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Fixing the principles in legislation

Which way do you think principles should be embedded in the legislation?

Please select one item
A. As a 'Claimant Charter'?
Ticked B. Placing principles in legislation?
C. Some other way

We are considering whether or not to adopt the name, "Claimant Charter". Can you think of another name that would suit this proposal better? If so, what other name would you choose?

We are considering whether or not to adopt the name, "Claimant Charter".
Citizen's Charter Person's Charter These are possibly less stigmatising and negative than claimant and are assets based statements, as the new Scottish Social Security System is to be person centred and Scotland can start again and demonstrate that there is support for person centred services and human rights based approaches. Scotland can have a new system with person centred services that shows the world that citizens in Scotland are at the centre.

Do you have any further comments on the 'Claimant Charter'?

other comments - claimant charter
There are principles already written by the Welfare Reform Committee of the Scottish Parliament in their Recommendations in December 2015 Person centred services ; dignity ; compassion etc..... These must be included if the Charter is to have credibility or be trustworthy.

On whom would you place a duty to abide by the principle that claimants should be treated with dignity and respect?

Please select one item
Ticked The Scottish Government
The Scottish Ministers
The Chief Executive of the Social Security Agency
Someone else

Do you have any further comments on placing principles in legislation?

further comments on placing principles in legislation
The principles in legislation is a requirement so that the citizens of Scotland are protected by the law, and the Scottish social security system is a new beginning. GDPR and EU Legislation also require a new approach from Governments, other organisations and citizens. This could enable a Fairer Scotland for data and person centred services. There should be a principle that states the services must be person centred. The Welfare Reform Commitee of the Scottish Parliament recommended a number of Principles and person centred is Para 14 of their Report in December 2015 The Scottish Government writes in the consultation - first of our "principles" is that social security is an investment in Scotland. This is not so much a principle as an aspiration. It is not person centred. It gives no protection to vulnerable people, and is not an assets based, person centred, human rights approach. The first principle of the Scottish Government should be to make the new system a person centred system with services that improve the lives of the citizens, families and communities and economy of Scotland. This is a Fairer Scotland approach that recognised citizen's needs, and these may include a basic income for all citizens. In the Welfare Reform Committee Report and Recommendations of December 2015, there were many human rights and assets based and person centred recommendations. These are the principles that citizens want in a Fairer Scotland that is legislated for and supports them. Executive Summary 7. The design and implementation of a new Scottish social security system is probably one of the biggest political tasks facing Scotland over the next 10 years. The Scottish Government is undertaking a major consultation exercise on this topic, which is to be welcomed. The Welfare Reform Committee believes that wherever possible, this system should be based on a strong political consensus. For this reason we have chosen to examine the issue to contribute to that foundation. 8. The Committee has examined the existing delivery of social security in Scotland over the past three years. It has witnessed the impact of the current regime on claimants - its failings and strengths. It seeks to bring this experience to bear in examining how that regime may be improved. 9. Witnesses suggested that elements of the current system appear to operate under an umbrella philosophy which regards those on social security universally as ‘skivers’.1 The Welfare Reform Committee rejects this narrative and believes that it is neither realistic nor helpful. We have witnessed many claimants fighting to get back into the labour market, or otherwise improve their chances of contributing to society, in situations where the current system can act as a hindrance rather than a help.i 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes. 2 19. It is of course easy to list the principles that are desired in a new Scottish social security system. The Committee appreciates that achieving them all will be a substantial task, particularly as we face a number of big issues and tough choices. http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/94823.aspx

Do you have any further comments or suggestions in relation to our overall approach, to fix our principles in legislation? For example, do you feel that there is no need to fix principles in legislation?

comments or suggestions in relation to our overall approach, to fix our principles in legislation
The principles must be fixed in legislation to empower citizens and to ensure that person centred services are designed and delivered that improve outcomes for all citizens of Scotland. The principles in legislation must ensure that the individual is at the centre, as the next two, five or ten years will see the complexity of running systems in parallel with UK. The legislation must contain principles for the citizens of Scotland - a vision of what a person centred social security system would have within it, i.e. data independence and portability ; interoperability ; person-centred design and services for the citizen experience. - Independent layers. - personal data stores as core tool for integration between different stakeholders to give the citizen control and choice The Scottish Government already recognised personal data stores in its Data Vision for Scotland in 2020. This will empower citizens when delivered - Driving Change: a Data Vision The Data Management Board proposes a Data Vision for Scotland in 2020 where: Data are used to support the delivery of outstanding public services. Citizens feel confident that personal data are being shared responsibly to create better and more responsive services which meet their individual needs. Citizens readily know how to and can access personal information held about them, allowing them to confirm accuracy and to choose if they wish to create their own personal data store. http://www.gov.scot/Topics/Economy/digital/digitalservices/datamanagement/dmbvfs/dmbvfspdf For Scotland to stay consistent with the EU, there are other person centred design considerations - The General Data Protection Regulation (GDPR) provides individuals with increased control over how their personal data is collected and used online, but more can and should be done to ensure that individuals are able to take back control of their online identities, the European Data Protection Supervisor (EDPS) said yesterday, as he published his Opinion on Personal Information Management Systems (PIMS). Giovanni Buttarelli, EDPS, said: “Our online lives currently operate in a providercentric system, where privacy policies tend to serve the interests of the provider or of a third party, rather than the individual. Using the data they collect, advertising networks, social network providers and other corporate actors are able to build increasingly complete individual profiles. This makes it difficult for individuals to exercise their rights or manage their personal data online. A more human-centric approach is needed which empowers individuals to control how their personal data is collected and shared.” http://www.wired-gov.net/wg/news.nsf/articles/Towards+a+new+reality+Taking+back+control+of+our+online+identities+21102016111500?open This is highlighted by the Minister - Stornoway Gazette reports the Minister - “Part of the difficulty with this exercise is the scale and the complexity of it because we only have 15% of the total UK welfare spend,” Ms Freeman explained, highlighting: “Whatever we have in Scotland has to work with the 85% that the UK Government will be responsible for.” Read more at: http://www.stornowaygazette.co.uk/news/local-headlines/benefits-transfer-creating-new-plan-1-4251800 The only way the two systems can work is if they are person centred, and there is trusted, person centred data attribute exchange to enable UK and Scottish services to work together. For the new services to work, they must be person centred as the individual citizen is the most important legal entity in the whole system. Scotland's citizens must see this new system as centred on them. The Welfare Reform Committee recommended this in Para 14 http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/94823.aspx Legislation must carry the support of citizens ; families ; communities ; GPs ; civic society ; trade unions ; third sector organisations and Parliament.

Outcomes and the User Experience

Are the outcomes the right high level outcomes to develop and measure social security in Scotland?

Please select one item
Yes
Ticked No
Please explain why.
The outcomes as written above do not take into account all the Welfare Reform Committee Recommendations of December 2015. They do not take into account the principles and the values as described in that Report. The needs of the individuals who claim social security from DWP can be delivered in new ways by a new system using a person centred Scottish approach. There could be much stronger commitments to Outcomes to making the whole system person centred from A to Z. The short and medium term aims must include the improvements in the experience, dignity, compassion and person centred outcomes for individual citizens. Otherwise the new Scottish system is not committing to improvements and will be at risk of repeating the current UK system which is organisation centred and creates multiples disadvantages and issues for people. Scotland can take a different path, and introduce genuine person centred services. This new systems will take into account the needs of the citizens of Scotland, their families or communities as they create ways to make social security genuinely and truly person centred. Principles and Values of a Person Centred System were outlined by the Welfare Reform Committee in December 2015 Report http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/94823.aspx 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes. The European Union GDPR has also recently stated how countries should empower citizens, and create person centred services with increased control for the individual of their online identies. Citizens need their own privacy friendly identity. The General Data Protection Regulation (GDPR) provides individuals with increased control over how their personal data is collected and used online, but more can and should be done to ensure that individuals are able to take back control of their online identities, the European Data Protection Supervisor (EDPS) said yesterday, as he published his Opinion on Personal Information Management Systems (PIMS). Giovanni Buttarelli, EDPS, said: “Our online lives currently operate in a providercentric system, where privacy policies tend to serve the interests of the provider or of a third party, rather than the individual. Using the data they collect, advertising networks, social network providers and other corporate actors are able to build increasingly complete individual profiles. This makes it difficult for individuals to exercise their rights or manage their personal data online. A more human-centric approach is needed which empowers individuals to control how their personal data is collected and shared.” http://www.wired-gov.net/wg/news.nsf/articles/Towards+a+new+reality+Taking+back+control+of+our+online+identities+21102016111500?open

Are there any other outcomes that you think we should also include (and if so, why)?

ny other outcomes that you think we should also include
There should be outcomes that measures user satisfaction ; convenience ; user participation and experience ; digital uptake ; security ; trust and confidence in the new system The new system can be designed by those with experience to improve on the existing one. These people can come from civic society, be their families, individuals or people who work with the current system and have knowledge of how to start a new approach.. There should be a primary outcome that the new System is person centred. Citizens need to know that the new system meets their needs and is a person centred service. Individuals can use identity, consent management services, and personal data stores and services to store once, and share many times. Trusted, person centred, data attribute exchange can then take place. This can happen with a different design that includes person centred, trusted attribute exchange 1) the Verified Attribute Provider e.g. DWP ; NHS 2) the individual at the centre ; 3) and the Relying Party e.g. new Scottish Social Security Agency. In this way, it will be much easier to bring new citizens to use the service, and to enable data exchange and flows for existing citizens taking up the new service. Person centred services can underpin the whole, new Scottish System. The individual can have a consistent service.

How can the Scottish social security system ensure all social security communications are designed with dignity and respect at their core?

Scottish social security system ensure all social security communications are designed with dignity and respect at their core
By making the new system a person centred service. It is not enough to just talk about dignity and respect as these are not sufficient. By placing user needs at the centre of the new system, and by working with people who have experience of the existing system there is a much stronger chance the the new system will be a person centred service. Scotland could succeed with a person centred system that meets the needs of citizens if it shifts away from current models and works in a different way. The Christie Commission offered this new way and principles and values. Equality by Design - citizens can say how they want the new system to work and how it will be person centred, and can do this before the new System is built By designing the whole system from A to Z as a person centred service By empowering citizens with their own identity ; consent management ; personal data stores so that they can be active participants in the whole system By creating a trust framework that places individuals at the centre

With whom should the Scottish Government consult, in order to ensure that the use of language for social security in Scotland is accessible and appropriate?

With whom should the Scottish Government consult, in order to ensure that the use of language for social security in Scotland is accessible and appropriate?
Plain English Campaign Users who represent all of society and communities Translation organisations and language groups

Are there any particular words or phrases that should not be used when delivering social security in Scotland?

Please select one item
Ticked Yes
No
If yes, please state which words or phrases should not be used.
avoid any words or phrases that stigmatise

What else could be done to enhance the user experience:

When people first get in touch?
All services should be person centred services User experience and the citizen journeys might offer a choice of methods - digital first ; post ; phone ; face to face Ensure that all the digital services are all person centred services and designed to empower citizens. - Scotland needs a vision of what a person centred social security system would have within it, i.e. data independence and portability, interoperability, person-centred design and services for the citizen experience. - citizens can use their own, privacy friendly identity credential and use verified data attributes from organisations to enable transactions and data exchange to take place - components such as these working with the front end service can enable a genuine person centred service and collaboration between the individual who may interact with social security, employability, and other service providers. - Independent layers and cosent management to give individuals control and choice. - Personal Data Stores as core tool for integration between different stakeholders. The way customer/personal data is currently organised and managed – by separate organisations each in its own silo – works against providing truly ‘joined up’ services. It is often difficult, expensive and time consuming to combine multiple sets of information to provide services in this ‘joined-up’, unified way. This problem can be solved via a person-centric approach. Each individual holds their own data in a personal data store where they can provide organisations with permissioned access to this data as and when it is needed. But a personal data store in isolation is not enough. To work effectively it needs a surrounding personal data ecosystem which enables enables the data to be managed and shared by the individual. This includes three interoperable layers contributing different functions: ▪ an independent identity layer where individuals can access services online using an identity credential that can be supplied with the required amount of information (from the data management layer below) to qualify the individual to access that service ▪ an independent communications layer enabling secure transmission of data – an open internet with the addition of secure encryption that’s not reliant on proprietary systems ▪ a data management layer that enables individuals to collect and curate their own data and to share this data under their own control. This includes a consent management layer giving individuals simple, easy, ‘one-stop-shop’ tools to manage all their consents in one place (and not one by one for each different organisation or transaction). This data sharing and consent management layer is what is needed to interact with the different models for data storage, access and the underlying commercial models that go with them. Create the services with people, carers, families and support groups so that the new system is convenient, trustworthy and secure.
When they are in the process of applying for a benefit?
Citizens can create and use their own portable, independent, self sovereign, life long identity and have choice and control. This creates trust and transparency. It enables store once, share many. Citizens can create a personal data store ( PDS ) Citizens can make a Connection from the new System to their PDS Citizens can be invited to apply online, and to use verified data attributes. The services are all person centred, and the individual can be supported to complete citizen journeys through the new system. This support could be face to face or online. The system is based on human rights, dignity and respect.
When a decision is made (for example, about whether they receive a benefit)?
2 way communications can be made between the new System and the individual's personal data store to ensure safe, secure correspondence. All the front end journeys can be designed by the new SSSS with citizens, and the data layer can be independent and involve The individual can volunteer information to the System about changes in circumstances. Organisations can send information to individuals via digital letter boxes using secure communications.
When they are in receipt of a benefit?
Again, a personal data store can act as a digital letter box and can be the place where communications are sent so that the individual holds the data. The overriding outcome is Equality by Design. The individual can share the verified data attributes with relying parties as evidence of a claim ; evidence of an entitlement ; evidence of address ; evidence for health and care needs etc..... In this way the individual and their family and support network are in control, and the service empowers the person at the centre.

How should the Scottish social security system communicate with service users (For example, text messaging or social media)?

Scottish social security system communicate with service users
Secure, encrypted, digital, two way Connections from the system to the citizen's personal data store and services. Text messaging and other forms of communication where they are secure can be used if the user chooses this method.

What are your views on how the Scottish Government can ensure that a Scottish social security system is designed with users using a co-production and co-design approach?

co-production and co-design approach
Person centred services is the first principle. The individual has personal control over personal data Data independence Build citizen journeys ; demonstrations ; user needs first See the Welfare Reform Committee Recommendations for ensuring how principles are met. 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes.

We are considering whether or not to adopt the name, "User Panels". Can you think of another name that would better suit the groups of existing social security claimants which we will set up? If so, what other name would you choose?

We are considering whether or not to adopt the name, "User Panels".
Citizen Advisers for new Person Centred System

Delivering social security in Scotland

Should the social security agency administer all social security benefits in Scotland?

Please select one item
Yes
Ticked No
Please explain your answer.
The SSA could administer some benefits, and local organisations could deliver others. If the system is person centred, then people can have control and choice. There could be local and central points. The benefits could be replaced by a citizen's minimum income or other arrangement that would mean the agency did not administer everything.

Should the social security agency in Scotland be responsible for providing benefits in cash only or offer a choice of goods and cash?

Please select one item
Ticked Yes
No
Please explain your answer.
Cash only for the national provider. Local providers may offer goods.

How best can we harness digital services for social security in Scotland?

How best can we harness digital services for social security in Scotland?
The Welfare Reform Committee laid down the principles of the service. Scotland needs to show clear leadership, and design a person centred service to meet the needs of citizens. Scotland does not have a successful record in this e.g. Farmers payments system. There will need to be genuine collaboration with citizens, suppliers and organisations in a complex program of work. http://www.parliament.scot/parliamentarybusiness/CurrentCommittees/94823.aspx 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes. 2 Digital services must be designed to be person centred services.

Should social security in Scotland make some provision for face to face contact?

Please select one item
Ticked Yes
No
Please explain your answer.
There will be occasions if the system is not person centred where the individual cannot be supported, and will need to have face to face meetings.

Who should deliver social security assessments for disability related benefits?

Who should deliver social security assessments for disability related benefits?
GPs and other health professionals would appear a possible choice. The evidence of entitlement should be provided as a verified attribute from the relevant organisation to the individual's personal data store. It can then be shared with the relevant Relying Party.

Should we, as much as possible, aim to deliver social security through already available public sector services and organisations?

Please select one item
Ticked Yes
No
Please explain your answer.
Not necessarily as there are so many choices. There should be a hybrid, person centred service to suit the needs of individual. Which organisation does it is not as important as the individual having one, privacy friendly, identity so that they can receive, accumulate, store and share all necessary information and personal data. A person centred, digital design could enable much more flexibility. Then the service could be provided by National Agency Local organisations Third Sector

Should any aspect of social security be delivered by others such as the 3rd sector, not for profit organisations, social enterprises or the private sector?

Please select one item
Ticked Yes
No
If yes, which aspects?
Support for digital services ; support to make claims

Equality and low income

How can the Scottish Government improve its partial EqIA as to produce a full EqIA to support the Bill?

How can the Scottish Government improve its partial EqIA as to produce a full EqIA to support the Bill?
To be equal, the services must be founded on principles and values - these would person centred services ; respect for the individual ; transparency ; design services with people who have experience ; dignity and others. At present, the services are not equal. People feel stigma as "claimants" and citizens do not make always make claims that they are entitled to because of fear and complexity. Equality by design can be a principle to ensure that all people in Scotland receive equal treatment by the system. There is also the question of a Minimum Basic Income or Citizen's Income to ensure that all people receive an income with dignity and respect. This would be a significant step to empower citizens and promote equality.

Independent advice and scrutiny

Do you think that there is a need for an independent body to be set up to scrutinise Scottish social security arrangements?

Please select one item
Ticked Yes
No
Please explain your answer.
If an independent body can be constituted and selected, then its Members can enable a social security system that is rights based ; the body can take account of other issues such as minimum basic income and EU legislation and all the other complexities. It can also act as a trust framework, as citizens of Scotland can believe that the future system is designed for people and with people and by people.

If you agree, does the body need to be established in law or would administrative establishment by the Scottish Government of the day be sufficient?

Please select one item
Ticked Yes
No
Please explain your answer.
To establish it in law provides for independence, transparency and continuity. It would also meet UK and EU legal needs.

If yes, what practical arrangements should be made for the independent body (for example, the law could state how appointments to it are made and the length of time an individual may serve as a member of the body)?

what practical arrangements should be made for the independent body
The arrangements could be borrowed from other similar projects that have taken place, albeit this is a very significant, initial £ 3 billion Project and very complex. Investigations might be made into other countries that have had new powers and how these were conducted successfully, and how the democratic process and legal system supports this.

Should there be a statutory body to oversee Scottish social security decision making standards?

Please select one item
Ticked Yes
No
Please explain your answer.
To ensure a person centred system, dignity, fairness, respect transparency and other values, this should be a statutory body. It may be relevant to review other places and methods e.g. Denmark

If yes, should the be a separate body in its own right?

Please select one item
Ticked Yes
No
Please explain your answer.
A separate body is independent and transparent.

Do you have any other views about the independent scrutiny of social security arrangement in Scotland (e.g. alternative approaches)?

about the independent scrutiny of social security arrangement in Scotland
No

Disability Benefits

Please explain your views (both positive and negative) on disability living allowance.

Please explain your views (both positive and negative) on disability living allowance.
DLA is a benefit that has caused issues.

Please explain your views (both positive and negative) on personal independence payment.

Please explain your views (both positive and negative) on personal independence payment.
PIP has caused issues. It has been outsourced, and this means trust is lost.

Please explain your views (both positive and negative) on attendance allowance.

Please explain your views (both positive and negative) on personal independence payment.
Attendance allowance and all the others are not designed in a person centred, assets based, human rights way and the principles should change.

Please explain your views (both positive and negative) on industrial injuries disablement benefit.

Please explain your views (both positive and negative) on personal independence payment.
as above

Is there any particular change that could be made to these disability benefits that would significantly improve equality?

Please select one item
Ticked Yes
No
Please explain your answer.
The benefit is a person centred service. The person, family and others can gather evidence. Trust is built in to the benefits process. GPs able to assess and approve the benefit claims Person centred services means that the individual is in control, and can work in an assets based way. Support is given to the individual with verified data attributes from trusted sources e.g. GP ; NHS ; Benefits System to enable digital proofs of claim and to complete the service effectively and with dignity for the individual to receive the benefit (s) ; income ; entitlement etc.

How should the new Scottish social security system operate in terms of a person applying for a disability related benefit?

Please explain your answer.
Citizen registers for the system via a personal, privacy friendly identity credential The person can use the identity credential anywhere in the system The person visits a GP and is approved / not approved The system generates a payment The citizen can assert their self sovereign identity with a personal data store, and carry this portable, privacy friendly identity across all of Scotland and across borders if necessary. The process is built around the individual.

How should the new Scottish social security system operate in terms of the eligibility criteria set for the benefit?

Please explain your answer.
Criteria can be provided as verified data attributes from the trusted source e.g. GP ; NHS ; Other organisation to the individual. This is a person centred system. Citizens are at the centred. The DWP can be the source of trusted, verified attributes at the start of the introduction and this can be tested in advance and other organisations can join the Scottish trust framework.

How should the new Scottish social security system operate in terms of the assessment / consideration of the application and the person’s disability and/or health condition?

Please explain your answer.
Again GPs and others can provide trusted evidence to the individual, and the individual can share this with the social security Agency. This is a person centred system.

How should the new Scottish social security system operate in terms the provision of entitlements and awards (at present cash payments and the option of the Motability Scheme)?

Please explain your answer.
Entitlements and awards presently made by DWP could be re-started as digital proofs of claim and digital proofs of entitlement. The DWP can provide trusted verified attributes to the citizen.

How should the new Scottish social security system operate in terms of the review and appeal process where a person isn’t content with the outcome?

Please explain your answer.
A digital right of appeal could come first After that, a face to face process Support organisations can work with the person

We want to make sure that the process is clear and accessible from start to finish, and that people claiming devolved benefits understand how and when their claim will be dealt with. With this in mind, do you think that timescales should be set for applications, assessments and decision-making?

Please select one item
Ticked Yes
No
Please explain your answer.
This gives clarity and dignity and must be worked out with citizens. The system must earn the trust of people.

What evidence and information, if any, should be required to support an application for a Scottish benefit?

what evidence and information, if any, should be required to support an application for a Scottish benefit
Verified attributes work for this process. An individual with a personal data store can provide evidence of for example their citizen account number ; national insurance number ; HMRC Scottish Tax Code number Any evidence in a digital form from a citizen to prove address could come from the citizen if the process is person centred.

Who should be responsible for requesting this information and who should be responsible for providing it?

Please explain why.
The citizen can provide this Trusted sources of evidence can provide verified attributes to the citizen. Local Authority ; Central Government etc... The citizen can provide these to Relying Parties. This is a person centred service, and where appropriate families, communities and support organisations can work with the person to ensure the data and information flows and is exchanged.

Should the individual be asked to give their consent (Note: consent must be freely given, specific and informed) to allow access to their personal information, including medical records, in the interests of simplifying and speeding up the application process and/or reducing the need for appeals due to lack of evidence?

Please select one item
Ticked Yes
No
If no, please explain why.
This consent management service can be designed into the new system if person centred services are used. Personal data stores and personal, privacy friendly identity credentials can support the citizen and organisation to empower the individual to give consent using applications. These personal data services are ISO27001 certified and GDPR compliant.

If the individual has given their permission, should a Scottish social security agency be able to request information on their behalf?

Please select one item
Ticked Yes
No
If no, please explain why.
Via personal data stores, this can be done with the citizen's consent and permission

Do you think that the impact of a person’s impairment or disability is the best way to determine entitlement to the benefits?

Please select one item
Ticked Yes
No

Would applicants be content for their medical or other publicly-held records, for example prescribing and medicines information or information held by HMRC, to be accessed to support automatic entitlement where a legal basis existed to do this?

Would applicants be content for their medical or other publicly-held records, for example prescribing and medicines information or information held by HMRC, to be accessed to support automatic entitlement where a legal basis existed to do this
Applicants will not be content if the law is broken by Scotland's social security system. Scotland is trying to build a person centred system. GDPR is coming into force in May 2018 and Scotland could show a lead in UK and work with citizens to empower them with consent management services. Otherwise this non consensual approach destroys the trust framework that Scotland is trying to create. This has happened with Named Persons and the Supreme Court. Scotland could empower individuals with personal control over personal data and rebuild trust. Citizens are independent, and have choice and control and do not want organisations to break trust. This is what happens with e.g. Named Persons and the government lost trust and social contracts with individuals by not considering the options available.

What would the advantages and disadvantages of a single, whole-of-life benefit be?

Please explain your answer.
Convenience would apply. Change of circumstances could be volunteered by the individual with consent using personal data services and might involve e.g. GPs and other Assessors.

Could the current assessment processes for disability benefits be improved?

Please select one item
Ticked Yes
No
Please explain how.
The principles of person centred services, access, dignity, compassion and respect These are all described in Welfare Reform Committee Recommendations

For those people that may require a face-to-face assessment, who do you think should deliver the assessments and how? For example, private organisation, not-for-profit organisation, public sector body or professional from health or social care.

people that may require a face-to-face assessment, who do you think should deliver the assessments and how
GP ; not for profit

What are the advantages and disadvantages of different types of assessments e.g. paper based, face to face, telephone?

What are the advantages and disadvantages of different types of assessments e.g. paper based, face to face, telephone?
All types will be needed and trust in the assessment can be tested in user groups

How could the existing assessment process be improved?

How could the existing assessment process be improved?
There could be a redesign so that the principle is Person centred services. A new citizen journey could be created. The individual has control and choice, so that trust in the process increases.

Could technology support the assessment process to promote accessibility, communication and convenience?

Please select one item
Ticked Yes
No
Please explain why. If yes, please explain what technology would be helpful e.g. Skype, video conferencing.
video and phone personal data stores and person centred services ; consent management services personal control over personal data decision support services Local Clusters delivering person centred services services e.g.Housing ; Care ; new System providers

If the individual’s condition or circumstances are unlikely to change, should they have to be re-assessed?

Please select one item
Yes
Ticked No
Please explain why.
Individual could volunteer changes

Do you think people should be offered the choice of spending some of their benefit for alternative support, such as reduced energy tariffs or adaptations to their homes?

Please select one item
Ticked Yes
No
What alternative support do you think we should be considering?
self directed support person centred services working with Housing ; Third Sector ; Employability

How could the new Scottish social security system support older people with mobility problems not eligible for a mobility allowance?

new Scottish social security system support older people with mobility problems not eligible for a mobility allowance
A person centred service would give an individual a personal data store, and a Connection to a card or phone that could be used by the individual across Scotland to access services This is an example of a holistic, person centred and value adding service At the moment, different organisations issue different cards and it is a very messy, uncoordinated and expensive system in Scotland and UK. It is frustrating for the individual. Currently, a person with a disability may carry 5 to 25 plastic cards There could be 1 card or 1 mobile phone to use with one person centred solution that uses identity, consent and personal data store to make the person's life easier and more convenient.

How could the new Scottish social security system better support people of all ages with mobility problems who are in receipt of a mobility allowance?

How could the new Scottish social security system better support people of all ages with mobility problems who are in receipt of a mobility allowance?
Convenient person centred services to enable mobility and access to work, services, leisure activities etc.....

What kind of additional support should be available for people who need more help with their application and during assessment?

additional support should be available for people who need more help with their application and during assessment
In order to provide better support and assistance, the new Agency can find ways to work with support organisations to offer support with the new person centred services. One aspect will be to require the people with previous experience to work to re-design the new services, and avoid the issues and failures of the old system. Existing members of staff in the current system will also be able to work to design new person centred services. So will families and Carers and the voluntary sector and local authorities and housing. A holistic, person centred service can then be created. Individuals can use personal data stores to store once, and share many. Trusted, person centred, data attribute exchange can then take place.

How could disability benefits work more effectively with other services at national and local level assuming that legislation allows for this e.g. with health and social care, professionals supporting families with a disabled child.

disability benefits work more effectively with other services at national and local level
Scotland needs to move to Person centred services - design and delivery with the individual at the centre, and an active role, so they are involved and the whole system is working to make the new benefits easier and simpler. Scotland needs to work smarter, and trust citizens to create convenient solutions and citizen journeys as their contribution has never been asked. Citizens do not know what public services do with their information, and there is a fear and distrust as evidenced in recent surveys and events. All citizens live with a host of service providers around them - Housing ; Health and Care ; Employability ; Culture ; Local Government ; Support & Advice ; DWP ; Employer ; HMRC ; Wellbeing ; Family. The individual is at the centre, and connects to these. The individual can only achieve outcomes if they trust organisations, and for that to happen the individual must be in control and have a choice. This creates a halo of trust. Individuals can use personal data stores to store once, and share many. Trusted, person centred, data attribute exchange can then take place. This can happen with the Verified Attribute Provider e.g. DWP ; the individual at the centre ; and the Relying Party e.g. new Scottish Social Security Agency An article about this and Local Clusters of organisations https://www.commonspace.scot/articles/9497/alex-stobart-why-person-centred-politics-should-matter-scottish-parliament
How do you think this might be achieved?
Individuals are placed at the centre Scotland designs genuine person centred services, and follows the pronciples in the Welfare Reform Committee Recommendations 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes. 2
What are the risks?
Risks are in managing the chance to a new system and a better Scotland People, families, communities and organisations can manage the change to person centred services.

If DLA and PIP help meet the additional costs of disability, what is the role of IIDB and its supplementary allowances (Constant Attendance Allowance, Reduced Earnings Allowance etc) in the benefits system?

Please explain your answers.
no answer made

What is right with the IIDB scheme?

What is right with the IIDB scheme?
no answer made

What is wrong with the IIDB scheme?

What is wrong with the IIDB scheme?
no answer made

Should different approaches be taken for people with life limiting conditions compared to people with less severe conditions?

What would be the advantages or disadvantages of such an approach?
no answer made

Are there situations where a one off lump sum payment would be more appropriate than a regular weekly IIDB benefit payment?

What are they, and why? What would be the advantages and disadvantages of such an approach?
no answer made

Should the Scottish Government seek to work with the UK Government to reform the IIDB scheme?

If yes, what should be the priorities be? What barriers might there be to this approach?
no answer made

Do you agree with the Scottish Governments approach to Severe Disablement Allowance?

Please explain why.
no answer made

Carer's Allowance

Do you agree with the Scottish Governments approach to developing a Scottish carers benefit?

Please select one item
Ticked Yes
No
Please explain why.
Agree with the proposals. The delivery of the system must be built on the major principles, and the most important is person centred services. A person can demonstrate that they are entitled to an Allowance, and do this digitally and with respect and dignity. This can run through the whole new system.

Do you agree with our proposed short to medium term priorities for developing a Scottish carer's benefit?

Please select one item
Yes
Ticked No
Please explain why.
Carers is a national benefit, so Scotland can provide one national service. This would be simpler, more effective and give the same human rights to all Carers. If each local authority does their own information and advice, this will be 32 times as expensive and confusing. When a Carer moves from Falkirk to Forres they are in the same country.

How can we improve the user experience for the carer (e.g. the application and assessment process for carer's benefit)?

How can we improve the user experience for the carer
Digital, person centred services that are the same across Scotland. Designed for self sovereign identity - portability - independence - human rights

Should the Scottish Government offer the choice of exchanging some (or all) of a cash benefit for alternative support (e.g. reduced energy tariffs)?

Please select one item
Ticked Yes
No

How can we achieve a better alignment between a future Scottish carer benefit and other devolved services?

How can we achieve a better alignment between a future Scottish carer benefit and other devolved services?
By making all the services person centred services and creating self sovereign identity for the individual citizen in Scotland. In this way the services are person centred and meet this individual's needs. The way they are now reflects DWP and 70 years of incremental additions, changes, amendments and therefore they are too complex and organisation centred.

Do you agree with our proposed long term plans for developing a Scottish Carer’s Benefit?

Please explain why
Agree with the proposals and if we simplify the system, there will be many millions of pounds more to give to Carers and not to spend on adversarial disputes and law cases.

Do you have any other comments about the Scottish Governments proposals for a Scottish Carer’s Benefit?

any other comments about the Scottish Governments proposals for a Scottish carers benefit
All future Benefits must be person centred. This is the fundamental principle of the Welfare Reform Committee ; is Christie Commission recommendation and will improve the lives of 5.3 million citizens of Scotland

Winter Fuel and Cold Weather Payments

Do you have any comments about the Scottish Governments proposals for Winter Fuel and Cold Weather Payments?

other commments
They should be person centred services, and part of a holistic design.

Could changes be made to the eligibility criteria for Cold Weather Payments?

For example, what temperature and length should Cold Weather Payments be made on in Scotland?
Possibly.

Funeral Payments

Are there other elements that you think should be included or explicitly excluded?

Please explain why.
no answer made

How can we improve the process for identifying whether someone is responsible for the funeral and should receive the funeral payment?

How can we improve the process for identifying whether someone is responsible for the funeral and should receive the funeral payment?
If an individual has a personal data store (PDS), then they can be part of a process that allows them to demonstrate they are next of kin This is a person centred process that can be designed

In terms of the Scottish Funeral Payment, are there any qualifying benefits (e.g. Pension Credit) that you would add to or take away from the current qualifying benefit list?

Please explain your answer
no answer made

Is the three month application window for a Funeral Payment sufficient time for claimants to apply?

If no, please explain your answer and suggest an alternative length of time in which a claim could be made.
no answer made

What are your views on the options for speeding up and simplifying the payment?

iews on the options for speeding up the grant
Re-design the process to enable digital services to be delivered with citizens using a holistic approach and using personal data services

The other funds which are deducted from the DWP funeral payment are listed below. What sorts of funds do you think it is appropriate to deduct from a Scottish FP?

Are there any other funds that you think are appropriate to deduct?
no answer made

Are there other funds that you think are appropriate to deduct?

Are there other funds that you think are appropriate to deduct?
no answer made

Which services should promote awareness of the funeral payment to ensure that claimants know about it at the relevant time?

ervices should promote awareness of the funeral payment to ensure that claimants know about it at the relevant time
An automatic process could generate messages to personal data stores from solicitors or others in the trust framework to ensure that people know what is happening. Use of the digital letter box and data exchange and flow can be designed.

Are there any other points that you would like to raise in connection with the new Scottish Funeral Payment?

any other points that you would like to raise in connection with the new funeral payment
This is another opportunity to design a person centred service and deliver the needs of citizens across Scotland It could be incorporated into advice services and solicitors and others so it can be holistic and work across Scotland and elsewhere

Best Start Grant

What are your views on who should receive the Best Start Grant?

What are your views on who should receive the Best Start Grant?
Continue initially with the current process, and redesign the process in a person centred way so that the person is able to claim more easily

Should we continue to use the same system to determine who is responsible for a child for the purposes of the BSG application?

Please select one item
Yes
Ticked No
Please explain why.
This should be reviewed

Do you agree that each of the three BSG payments should only be made once for each child?

Please select one item
Ticked Yes
No

Should we continue to use the same method as the SSMG to determine whether a child is the first child in a household?

Please select one item
Ticked Yes
No

Do you agree that we should retain the requirement to obtain advice from a medical professional before making a maternity payment?

Please select one item
Ticked Yes
No
Please explain your answer.
This could be done in a person centred way using processes and digital to enable medical professionals to provide verified data attributes This could be a demonstration of a person centred social security system

Are there other points during the first five years of a child’s life when families face greater pressure than at the start of nursery (other than birth and the start of school)?

The BSG will pay low income families £250 to support them as their children begin early learning and childcare. We want to provide support when people need it, but the practicalities may be difficult as everyone’s situation is different and plans for nursery and childcare can change right up until the last minute. We would like to understand the pressures that families face, when they face them and how the payment can add most value, without becoming too complicated.
Possibly e.g. event of significant chance

What are your views on defining ‘the start of nursery’ as the point of entitlement to a funded early learning and childcare place, for the purposes of making the second payment?

What are your views on defining ‘the start of nursery’ as the point of entitlement to a funded early learning and childcare place, for the purposes of making the second payment?
No views

Are there any particular issues related to the school payment that you think we should consider?

Are there any particular issues related to the nursery payment that you think we should consider?
No views

Are there any particular issues related to the school payment that you think we should consider?

Are there any particular issues related to the school payment that you think we should consider?
Yes, the parent could benefit from a digital process and claim

Should the school payment be payable to all eligible children who begin primary school for the first time in Scotland, or should an upper age limit be included?

Please select one item
Ticked Payable to all eligible children who begin primary school for the first time in Scotland
An upper age limit be included

What are your views on our proposals in relation to the BSG application process?

views on the proposals in relation to the application process
Redesign the process in a person centred way

What are your views on establishing an integrated application process for the BSG and Healthy Start?

What are your views on establishing an integrated application process for the BSG and Healthy Start?
It would be simpler for the benefits to be integrated, but only in a person centred way of delivering the service

What are the advantages and disadvantages of this approach?

What are the advantages and disadvantages of this approach?
The advantage is convenience

Would the option to receive items rather than a cash payment as part of the BSG have benefits?

Please explain why.
No views

Which services should promote awareness of the BSG to ensure that claimants know about it at the relevant time?

We know that there is a patchy awareness of the SSMG and that take up is low. It is important that people are able to access and receive the support that they are entitled to. We think that we can improve take up of the BSG by ensuring that it is promoted by services commonly used by people who will need support, for example the family nurse partnership and health visitors. We also think that the new baby box which will be available for all new mothers will be a good opportunity to raise awareness of the BSG.
A redesign of the service could identify the awareness relevant times

Discretionary Housing Payment

Could the way that DHPs are currently used be improved?

Please select one item
Ticked Yes
No
Please explain why.
The DHP could be reviewed and become part of a new, person centred social security system in the future.

Could the administration of DHP applications be improved?

Please select one item
Ticked Yes
No
Please explain why.
The individual could administer it directly, if it continues, by volunteering information to inform the system

Does the guidance for local authorities on DHPs need amending?

Please select one item
Ticked Yes
No
Please explain why.
In light of the system redesign to a person centred service, guidance can be amended when this happens.

Job Grant

What should the Scottish Government consider in developing the Job Grant?

What should the Scottish Government consider in developing the Job Grant?
It should work with the participants to enable the young person to create a person centred service and build evidence of work and skills and achievements The young person is more likely to store something, and they can then share it many times e.g.digital CV ; digital proofs of academic achievement In this way citizens, organisations and Scottish Government can design another person centred service to create trust, convenience and start a lifelong journey for the young person

Universal Credit flexibilities

Should the choice of managed payments of rent be extended to private sector landlords in the future?

Please select one item
Ticked Yes
No
Please explain why.
It is a simpler process and may protect individuals and their tenancies.

Should payments of Universal Credit be split between members of a household?

Please select one item
Ticked Yes
No
Please explain why.
To take account of family circumstances and events

If Yes, please indicate if you think the default position should be:

Please select one item
automatic payments to individuals, with the option to choose a joint payment
Ticked automatic household payments, with the option to choose individual payments

If Yes, how do you think payments should be split? For example 50/50 between members of a couple or weighted towards the person who is the main carer if the claim includes dependent children?

If Yes, how do you think payments should be split? For example 50/50 between members of a couple or weighted towards the person who is the main carer if the claim includes dependent children?
There should be control and choice for the members of the household

Do you have any other comments about how the Scottish Government’s powers over Universal Credit administrative flexibilities will be delivered?

other comments about how the Scottish Government’s powers over Universal Credit administrative flexibilities will be delivered
It may be that over time the SG reviews its powers, and considers a move to a new person centred system.

Universal Credit housing element

Do you have any comments about the Scottish Government's powers over the housing element of Universal Credit?

Do you have any comments about the Scottish Government's powers over the housing element of Universal Credit?
The SG may wish to review the whole system, and indeed this would be a good way to consider the introduction of a person centred service and to remove the organisation centred one. A person centred service is holistic, is flexible and can be designed to enable a new social security system in Scotland. It can build trust into the relationships.

Advice, representation and advocacy

What role[s] should publicly funded advice providers to play in the development of a new Scottish social security system?

What role[s] should publicly funded advice providers to play in the development of a new Scottish social security system?
Advice providers can assist in the redesign and build of a new person centred system. The Welfare Reform Committee suggests that advice will not be needed as much in a digified, respectful and compassionate person centred system. A new system is going to be complex to run with the DWP one, and will need to be person centred from the design stage on to delivery. These DWP and Socttish Government interactions are likely to augment the complexities of the benefit system over time if, as expected, the two systems diverge. Managing these interdependencies will require ongoing intergovernmental cooperation.

What steps need to be taken, to understand the likely impact of the transfer of the devolved benefits on publicly funded advice in Scotland?

What steps need to be taken, to understand the likely impact of the transfer of the devolved benefits on publicly funded advice in Scotland?
A Review of the law and impact

How could the transfer of the devolved benefits to Scotland be used to drive improvements in the provision of publicly funded advice?

How could the transfer of the devolved benefits to Scotland be used to drive improvements in the provision of publicly funded advice?
If the new benefits are person centred, and the whole system is person centred then the need for advice will reduce.

Do you think that Independent Advocacy services should be available to help people successfully claim appropriate benefits?

Please select one item
Ticked Yes
No
Please explain why.
To enable people to receive all social security

What next steps would you recommend that would help the Scottish Government better understand the likely impact of the transfer of the devolved benefits on independent advocacy services?

What next steps would you recommend that would help the Scottish Government better understand the likely impact of the transfer of the devolved benefits on independent advocacy services?
Commission an independent Review Commission Person Centred Services Design and Delivery Model to demonstrate how the simpler person centred service can reduce needs for advocacy, and free time for face to face meetings

Complaints, reviews and appeals

Do you agree that we should base our CHP on the Scottish Public Services Ombudsman’s ‘Statement of Complaints Handling Principles’?

Please select one item
Ticked Yes
No
Do you agree that we should base our CHP on the Scottish Public Services Ombudsman’s ‘Statement of Complaints Handling Principles’
This could be a base but it should be flexed to take into account the new holistic, person centred services that represent a new service delivery

How should a Scottish internal review process work?

How should a Scottish internal review process work?
n/a

What would be a reasonable timescale for the review to be carried out?

What would be a reasonable timescale for the review to be carried out?
n/a

Should a tribunal be used as the forum for dispute resolution for the Scottish social security system?

Please select one item
Ticked Yes
No

If no, are there any alternative methods of dispute resolution that you think would be preferable to a tribunal?

If no, are there any alternative methods of dispute resolution that you think would be preferable to a tribunal?
Mediation first

How can we ensure that our values underpin the appeals process for a Scottish Social Security agency?

How can we ensure that our values underpin the appeals process for a Scottish Social Security agency?
If the Scottish Government introduces the principles that the Parliament recommended in 2105 - person centred services, dignity, compassion, human rights, assets based etc then these should be added

Are there any other values that you feel should be reflected in the design of the appeals process?

Are there any other values that you feel should be reflected in the design of the appeals process?
A person centred process would make for fewer appeals

What do you consider would be reasonable timescales to hear an appeal in relation a decision on a devolved benefit?

What do you consider would be reasonable timescales to hear an appeal in relation a decision on a devolved benefit
n/a

In order to ensure a transparent appeals process, what steps could be taken to ensure that those appealing fully understand and are kept informed at each stage of the appeals process?

In order to ensure a transparent appeals process, what steps could be taken to ensure that those appealing fully understand and are kept informed at each stage of the appeals process?
A personal data store enables information to be sent and received in real time This builds trust and confidence

How could the existing appeals process be improved?

How could the existing appeals process be improved?
n/a

Residency and cross-border issues

Should Scottish benefits should only be payable to individuals who are resident in Scotland?

Please select one item
Ticked Yes
No
Please explain why
Habitual residence and appropriate EU and UK law

What are your views on the ‘habitual’ residence test currently used in the UK by DWP?

views on the habitual residence test currently used in the UK by DWP
no answer made

Are there other issues that the Scottish Government should take into account when it comes to residency rules?

other issues that the Scottish Government take into account when it comes to Residency rules
For an individual to be resident, the individual can create a personal data store ( PDS ) and make a Connection from their Central or Local Government organisation to their PDS In this way the habitual residence can be complemented by evidence of ongoing transactions and interactions with Scottish organisations It is a human rights based, person centred approach

What other factors should Scottish Government consider in seeking to coordinate its social security system with other social security systems in the UK?

What other factors should Scottish Government consider in seeking to coordinate its social security system with other social security systems in the UK?
Work with DWP on trusted, person centred data attribute exchange so that DWP and Scotland empower citizens via personal data stores

How can the Scottish Government ensure that no-one either falls through the cracks or is able to make a 'double-claim'?

How can the Scottish Government ensure that no-one either falls through the cracks or is able to make a 'double-claim'
Work with citizens and use personal data stores and Connections to ensure no double counting

Managing overpayments and debt

Could the existing arrangements for recovering social security overpayments be improved in the new Scottish social security system?

Please select one item
Ticked Yes
No
If yes, please explain your answer.
The new system could be designed in a way to minimise the risk of overpayments. There could be two way, secure, digital connections between the individual and the system so that the individual could offer / volunteer information. A trusted, person centred system would reduce the risk of overpayments.

What are your views on the role that financial advice can play in the recovery of overpayments?

views on the role that financial advice can play in the recovery of overpayments
Financial advice can enable individuals to manage their position. This should be looked at in the context of a new system being person centred and fairer to individuals.

Fraud

Should the existing Scottish Government approach to fraud be adopted for use in our social security system?

Please select one item
Ticked Yes
No

If yes, should our existing counter-fraud strategy be adapted in any way?

Please select one item
Yes
Ticked No

How could the new Scottish social security system ‘design out’ errors and reduce the potential for fraud at the application stage?

How could the new Scottish social security system ‘design out’ errors and reduce the potential for fraud at the application stage?
The application process can use person centred services, self sovereign identities, verified attributes and personal data stores to design in privacy, security and equality. The DWP and the new Social Security Agency can establish processes to reduce fraud and ensure an accurate and complete transfer of the numbers of individuals. In the same way, a Scottish approach to person centred digital services can design out errors. The UK approach to data is not working as this extract shows - These contradictions were foreshadowed in the consultation on "Better use of data in government" that preceded the Bill. It missed the opportunity to resolve the complex issues that surround making better use of data. Contrary to the good practice championed by the Government Digital Service (GDS), the two-year consultation didn't explore, test and validate any technical options, missing a golden opportunity to inform the policymaking process. As a result, the "data sharing" proposals read as if they have been lifted from the days when the Whitehall typing pool made multiple copies of information to distribute in foolscap manila envelopes. They risk perpetuating the security challenges and inefficiency of copying data out of a system, shipping it around, and then attempting to ingest, merge and match it into other silo systems. It's an approach from the age of the filing cabinet, neither citizen-enabling nor a modern and secure "digital" solution in the face of growing fraud and escalating cyber threats. The recent National Audit Office report "Protecting information across government" highlighted weaknesses in the protection and management of information in government. Diluting already inadequate controls on protecting personal data will only further undermine trust at the very time government seeks to promote increasingly digital services.

Should the Scottish social security system adopt DWP’s existing code of practice for investigators?

Please select one item
Ticked Yes
No
Please explain your answer.
no answer made

What are your views on the existing range of powers granted to investigators?

What are your views on the existing range of powers granted to investigators?
no answer made

What are your views on conducting interviews under caution?

What are your views on conducting interviews under caution?
no answer made

What improvements could be made around conducting interviews under caution?

What improvements could be made around conducting interviews under caution?
no answer made

Should the Scottish Government retain the same list of offences which people can be found guilty of in terms of social security fraud?

Please select one item
Ticked Yes
No
Please explain your answer.
no answer made

Should the Scottish Government impose the same level of penalties for social security fraud as are currently imposed?

Please select one item
Ticked Yes
No
Please explain your answer.
no answer made

Safeguarding your information

Should the existing Scottish Government approach to Identity Management and Privacy Principles be adopted for use in our social security system?

Please select one item
Ticked Yes
No
Please explain your answer.
Trust is the fundamental principle - if the individual understands and trusts the new system, they are more likely to use it. Individuals need support as well to understand the system. The SG approach needs to be extended from the 2012 Principles in order to comply with GDPR and to empower individuals with personal control over personal data. Also the Scottish Government has a new Data Vision for 2020. One of the Authors of the original Scottish Group ( Chaired by Paul Gray of SG in c. 2012 ) that wrote the Principles commented recently on how the Government is still getting this trustworthy journey wrong - " These contradictions were foreshadowed in the consultation on "Better use of data in government" that preceded the Bill. It missed the opportunity to resolve the complex issues that surround making better use of data. Contrary to the good practice championed by the Government Digital Service (GDS), the two-year consultation didn't explore, test and validate any technical options, missing a golden opportunity to inform the policymaking process. As a result, the "data sharing" proposals read as if they have been lifted from the days when the Whitehall typing pool made multiple copies of information to distribute in foolscap manila envelopes. They risk perpetuating the security challenges and inefficiency of copying data out of a system, shipping it around, and then attempting to ingest, merge and match it into other silo systems. It's an approach from the age of the filing cabinet, neither citizen-enabling nor a modern and secure "digital" solution in the face of growing fraud and escalating cyber threats. The recent National Audit Office report "Protecting information across government" highlighted weaknesses in the protection and management of information in government. Diluting already inadequate controls on protecting personal data will only further undermine trust at the very time government seeks to promote increasingly digital services. " It is critical that the Scottish Government follows a Scottish approach and there is personal control over personal data, and a person centred services approach that citizens trust. The new System and Agency could be a beacon and model for trusted, person centred, verified attribute exchange. This would require courage, collaboration, honesty, leadership, humility, and to follow the principles that GDPR will introduce. Personal data stores are GDPR compliant. Privacy by design would enable a Scottish approach. Work at the Melbourne School of Government suggests ways in which governments can create the conditions for rebuilding trust. Government needs to lead open and transparent debate with all its communities about policy challenges and options. Expertise comes in many forms – technical, political, professional, lived and user expertise. All need to be included in policy debates, particularly in an era of budget constraint. The Scottish Government published in 2014 Driving Change: a Data Vision The Data Management Board proposes a Data Vision for Scotland in 2020 where: Data are used to support the delivery of outstanding public services. Citizens feel confident that personal data are being shared responsibly to create better and more responsive services which meet their individual needs. Citizens readily know how to and can access personal information held about them, allowing them to confirm accuracy and to choose if they wish to create their own personal data store. http://www.gov.scot/Topics/Economy/digital/digitalservices/datamanagement/dmbvfs/dmbvfspdf

If yes, should our existing Identity Management and Privacy Principles be adapted in any way?

Please select one item
Ticked Yes
No
Please explain how.
The Principles must be extended Personal control over personal data - as a principle, this would enable Privacy by Design and would deliver person centred services. A design that combines person centred services with a trust framework and legislation. - a vision of what a person centred social security system would have within it, i.e. data independence and portability, interoperability, person-centred design for the citizen experience ; privacy friendly identity. - Independent layers and consent management. - Personal data stores as core tool for integration between different stakeholders. The EU has also recently written about principles, and Scotland will need to legislate for these in the new system to ensure it is person centred and meets EU requirements. The General Data Protection Regulation (GDPR) provides individuals with increased control over how their personal data is collected and used online, but more can and should be done to ensure that individuals are able to take back control of their online identities, the European Data Protection Supervisor (EDPS) said yesterday, as he published his Opinion on Personal Information Management Systems (PIMS). Giovanni Buttarelli, EDPS, said: “Our online lives currently operate in a providercentric system, where privacy policies tend to serve the interests of the provider or of a third party, rather than the individual. Using the data they collect, advertising networks, social network providers and other corporate actors are able to build increasingly complete individual profiles. This makes it difficult for individuals to exercise their rights or manage their personal data online. A more human-centric approach is needed which empowers individuals to control how their personal data is collected and shared.” http://www.wired-gov.net/wg/news.nsf/articles/Towards+a+new+reality+Taking+back+control+of+our+online+identities+21102016111500?open All the other principles have been suggested by the Welfare Reform Committee in 2015. They are human values and principles, as well as technical. These principles should be incorporated into the new System and Agency. 6th Report, 2015 (Session 4): The Future Delivery of Social Security in Scotland 10. We believe that a new Scottish social security system requires a huge culture shift. Time and time again we have heard complaints from benefit recipients about how they have been treated by the system. “Most of the way, the way they treated you was as a piece of dirt”, as one claimant on the Work Programme put it to us. Clear leadership from the UK Government’s Department for Work and Pensions (DWP) and the Scottish Government will be required to achieve this. 11. The Committee has a number of scheme-specific recommendations to make but we believe that, even if the system remained substantially the same, significant improvements could be achieved by a culture shift to a more positive attitude towards claimants. 12. We believe that a brand-new philosophy and set of principles is necessary in order to underpin the new Scottish social security system and make it more successful. Most importantly, a new Scottish social security system should be based upon preserving the dignity of, and showing respect for, claimants. We believe that this principle should run through the entire social security system and be enshrined in the primary legislation. 13. The current system is regarded by many claimants as punitive, particularly in regard to the sanctions regime. The Committee accepts that there will be situations where conditionality will be required, but it is essential that the system is non- punitive in nature and that sanctions are only used genuinely as a last resort. 14. The other major principle which we advise the Scottish Government to adopt is to make the new system person- centred. The current social security system often appears to be designed for bureaucratic convenience. The fact that a whole advocacy industry has grown up to support claimants through the process is an indication of how the system is not currently person-centred. Ultimately we would like to see a system where the need for advocacy and support disappears for the vast majority of claimants. 15. If the demand for advocacy support is to reduce, the new system must be much more accessible than at present, include clear and simple communication in plain English and overall be much more transparent and easily understood. 16. Creating a fully person-centred system has a number of other implications. It implies that the system as a whole is much more joined up and coherent than at present. This will not be easy to achieve. It also implies that the principle of ‘passporting’, which allows claimants to automatically qualify for other benefits and support, is used wherever possible. This will minimise the input required from benefit claimants, some of whom are seriously ill, but also make the overall system as efficient as possible. 17. It is important that the basic human rights of individuals are not infringed by their interaction with the social security system and that the right to participate in society, particularly of those with significant disabilities, is recognised. 18. There are a number of other qualities that one would desire from any new system. It should be fair and consistent. It should be helpful and supportive overall, and it should be speedy and responsive. Some of the main reasons given for using food banks by users are delays in benefit decisions, low income and the impact of benefit changes. 2 19. It is of course easy to list the principles that are desired in a new Scottish social security system. The Committee appreciates that achieving them all will be a substantial task, particularly as we face a number of big issues and tough choices. As well as this, there is the new Data Vision for 2020 http://www.gov.scot/Topics/Economy/digital/digitalservices/datamanagement/dmbvfs/dmbvfspdf

Who do you consider should be consulted in regard to the Privacy Impact Assessment and what form should this take?

Who do you consider should be consulted in regard to the Privacy Impact Assessment and what form should this take
The Privacy Impact Assessment can be a relatively easy or very difficult exercise. If the Scottish Government takes a collaborative route and works with citizens in the new social security system, and genuinely empowers citizens and treats them with dignity and respect and enables genuine person centred services, the PIA will be relatively easy. Citizens can design the new system with personal data stores and genuine privacy by design, and the Scottish Government can enable person control over personal data. As the EU European Data Protection Supervisor (EDPS) Giovanni Buttarelli, said in October 2016 " A more human-centric approach is needed which empowers individuals to control how their personal data is collected and shared.” If the Scottish Government takes an organisation centred approach, it will be very difficult to meet the EU requirements and law, and this has been seen already with the Named Persons process where the trust factor is again at risk. Consultees should include all stakeholders including citizens, EU, European Data Protection Supervisor (EDPS) , UK Government and DWP, local authorities, GPs, third sector, NHS, Third Sector, citizens and all other organisations impacted The UK Information Commissioner All lawyers

What are your views on privacy issues that may affect the new agency?

What are your views on privacy issues that may affect the new Agency?
Trust is an essential part of interacting online, for both individuals, organisations they are interacting with and other parties. The new agency will not be trusted unless it adopts the highest privay standards. At Mydex CIC, we made a number of decisions about our legal and technical structure to build trust into the foundations of what we do. Mydex CIC is built with Privacy by Design, Equality by Design and supports individuals with a trust framework and zero knowledge platform to address trust and privacy issues. Mydex designed its person centred personal data stores and services with and for Members so they can benefit from privacy by design. Data independence and data portability are ways for Scottish Government to demonstrate to citizens that the new Agency service is trustworthy. Social security services are not currently trusted by the citizens of Scotland. The 2015 Edelman Trust Barometer points to an “evaporation of trust” in institutions and leaders worldwide. The annual survey finds a decline in trust overall, with more countries classified as distrusting than trusting. Globally, trust in business, media and NGOs is at its lowest level since the 2008 financial crisis.The public has lost trust in government mainly because they do not believe that it “contributes to the greater good”. More than 50% do not believe that the government helps them to live a fulfilling and healthy life. To be different, and to demonstrate a Scottish approach, the new Agency will need to offer a zero knowledge service - for example, by using personal data stores individuals can be assured that their personal data is secure and they have personal control over personal data. Consent management services can also operate in this way, and the service will then be GDPR compliant. People in receipt of social security may be in vulnerable and challenging and complex situations. A human centred way to help them is to build trust and confidence, and the Scottish Government could design a new social security system if it shifted to a model that citizens could trust. Such a model, and more enlightened, person centred approach applies equally to employability, health & care integration, advice services and many other services. Again, Scotland could lead the way if the decision makers in Parliament and Government take a person centred service approach.

Do you perceive any risks to the individual? What solutions might be considered to mitigate against these?

What solutions might be considered to mitigate against these?
The risks to the individual are principally caused by Government in the current model. The individual does not know what happens to their personal data, with whom it is shared, and for what purpose the personal data is then used. The individual and the family and charity and others who support them may feel alienated by the current system, and by the future Agency as there is such complexity in the system. Scotland can change this by adopting different values and principles, and creating a simpler citizen journey. On the risks to the individual and personal data, the Scottish Government may not comply with GDPR unless it implements zero knowledge, person centred solutions such as personal data stores and services ; privacy friendly identity services ; and consent management services. At present, the individual is unlikely to understand the consequences of data sharing by the Government and Agencies. This is a time of profound flux with GDPR, Brexit and other changes ; it is therefore very important that the Scottish Government works to enable a system with privacy by design. A commentator writes about the risks posed by Government - These contradictions were foreshadowed in the consultation on "Better use of data in government" that preceded the Bill. It missed the opportunity to resolve the complex issues that surround making better use of data. Contrary to the good practice championed by the Government Digital Service (GDS), the two-year consultation didn't explore, test and validate any technical options, missing a golden opportunity to inform the policymaking process. As a result, the "data sharing" proposals read as if they have been lifted from the days when the Whitehall typing pool made multiple copies of information to distribute in foolscap manila envelopes. They risk perpetuating the security challenges and inefficiency of copying data out of a system, shipping it around, and then attempting to ingest, merge and match it into other silo systems. It's an approach from the age of the filing cabinet, neither citizen-enabling nor a modern and secure "digital" solution in the face of growing fraud and escalating cyber threats. The recent National Audit Office report "Protecting information across government" highlighted weaknesses in the protection and management of information in government. Diluting already inadequate controls on protecting personal data will only further undermine trust at the very time government seeks to promote increasingly digital services.

Would you support strictly controlled sharing of information between public sector bodies and the agency, where legislation allowed, to make the application process easier for claimants? For example, this information could be used to prepopulate application forms or to support applications, reducing the burden on applicants.

Please select one item
Yes
Ticked No
Please explain your answer.
No, this is not a sustainable solution. It creates mistrust in Government. There are many better ways to achieve better outcomes. An organisation centred system is not trusted by citizens as it is opaque and not transparent. It is better to earn trust and to work with people in the system design from the start. The question restricts the options, and is not person centred. It is an organisation centred suggestion, and these solutions do not work and are not sustainable and the law has been used to challenge them. The Scottish Government can better invest in Christie Principle, and earn privacy and design person centred services up front, and therefore potentially earn increasing trust. There is a spectrum of sharing, and a lot of grey at present. This requires clarification. The Scottish Government or the NHS or Local Authorities may presently share personally identifiable information with each other and/or other organisations e.g. Universities ; Research Institutes and the individual may not be aware or have given explicit consent. GDPR will require all organisations, including the public sector to build a culture of data confidence and trust in organisations. Data cannot be given by the public sector to Government and then to research or other uses without anyone being informed. Citizens may prefer to have a data usage report every 6 months or a year to know what the public sector has done with their data. At present, the individual is unlikely to understand the consequences of data sharing by the Government and Agencies. This is a time of profound flux with GDPR, Brexit and other changes ; it is therefore very important that the Scottish Government works to enable privacy by design. The Scottish Government has an opportunity to design a person centred service for the citizens of Scotland. It says this in its own Data Vision for 2020. " Citizens readily know how to and can access personal information held about them, allowing them to confirm accuracy and to choose if they wish to create their own personal data store. " There are other aims for the Vision as well. http://www.gov.scot/Topics/Economy/digital/digitalservices/datamanagement/dmbvfs/dmbvfspdf If an individual has a personal data store, and organisations provide verified data attributes to citizens, then the individual can offer those to the Relying Parties to enable processes and citizen journeys. This has explicit consent and is transparent. This is a person centred service. The CIC legal form allows Mydex to be sustainable and requires it be run for community benefit designed to work for individuals. Its Trust Framework ensures that the individual is at the heart of the process, controlling and managing their identity and personal data. This Trust Framework is underpinned by the Mydex Platform and an ISO27001 certification for information security management across Mydex.

Would you support strictly controlled sharing of information between a Scottish social security agency and other public sector organisations (for example local authorities) to support service improvements and deliver value for money?

Please select one item
Yes
Ticked No
Please explain your answer.
The question starts from the wrong premise as it does not state that the individual will give explicit consent. As such government is not creating a trust framework, as there is no mutual reciprocity, fairness or transparency for individuals in such a model. The individual may also wish to revoke the sharing. The ICO says in Code of Practice - People want their personal data to work for them. They expect organisations to share their personal data where it’s necessary to provide them with the services they want. They expect society to use its information resources to stop crime and fraud and to keep citizens safe and secure. However, people also want to know how their information is being used, who has access to it, and what that means for them. People also expect an appropriate level of choice and control, especially over their sensitive data. Information sharing requires the explicit consent of the individual citizen. Otherwise the system is not trustworthy, and it is open to abuse by the organisations such as local authorities, NHS, Charities, GPs and others who will lose trust and confidence of the public if they do not have a fair system with equality for participants. Therefore this is not a completely viable, cost effective, legal or person centred suggestion in the way it is written and structured. It requires much more thought and time, as the way it is written does not offer choice and control. It is not a human rights approach. It is not person centred. It does not support people with a disability, and it does not place the individual at the centre, where support could be provided by family, carers, communities and the third sector to achieve outcomes with the individual. This organisation centred thinking prevents a new Scottish approach for the people of Scotland to receive a person centred approach. It sees Scotland and the new Agency copying a failing UK approach, and it is not delivering outcomes that support and empower citizens. The suggestion is at risk of causing breaks in a possible trust framework, and the citizen is excluded and not participating in their services. The person is likely to lose resilience, and have no motivation to participate in such an organisation centred system. If Scotland copies the existing system, it will not be a successful outcome. Scotland needs a new, person centred, Scottish Social Security System.

What are your views on having the option to complete social security application forms online? Can you foresee any disadvantages?

What are your views on having the option to complete social security application forms online? Can you foresee any disadvantages?
This is the default position to be online. Digital first. Equality by design - this concept means a Government invests in capacity and support to enable all citizens to participate in the digital ecosystem. In Scotland there will need to be significant investment in a person centred system. The gain is when citizens working online with person centred social security services can also then move to employability, local authority and others as they have a privacy friendly identity, and consent management services. Then there is personal control over personal data, and there are more hooks and incentives to persuade people to use online services. By working to achieve this, the Scottish Government could deliver better outcomes.

What are your views on the new agency providing a secure email account or other electronic access to check and correct information for the purposes of assessing applications (noting that any such provision would need to be audited and regulated so that the security and accuracy of the information would not be compromised)?

What are your views on the new agency providing a secure email account or other electronic access to check and correct information for the purposes of assessing applications
Email accounts have been compromised - Yahoo and 500 million accounts. The design requires a person centred approach and a security dialogue. The individual can establish a digital connection from the agency to their personal data store and information can flow in 2 ways. Individuals then have their own digital letter box. https://dev.mydex.org/connection-api/simulated-connections.html This empowers the citizen and invests in their participation and inclusion. Email may well be seen as too high a risk. The new Agency will potentially be a high risk place to store data, and collaborative work can happen here to explore alternatives.

Uprating

What are your views on the best way to ensure that devolved benefits keep pace with the cost of living?

What are your views on the best way to ensure that devolved benefits keep pace with the cost of living
n/a

Are there any devolved benefits in particular where uprating based on a measure of inflation would not be effective? If so, please explain which benefits and why.

devolved benefits in particular where uprating based on a measure of inflation would not be effective? If so, please explain which benefits and why
n/a

Partial Equality Impact Assessment (EQIA)

How can the Scottish Government improve its partial EqIA so as to produce a full EqIA to support the bill?

How can the Scottish Government improve its partial EqIA so as to produce a full EqIA to support the bill?
Invite citizens to describe what Equality would mean to them in the Principles and Design of a new system e.g. Human Rights Assets based Person centred services Dignity Choice Being in Control Self Directed