Tag: IDS

The Department for Work and Pensions don’t know what their ethical and safeguarding guidelines are but still claim they have some


I have recently written quite extensively about problems with how the government conduct “research,” I’ve also highlighted the many official rebukes the Conservatives have faced because of their tendency to invent statistics to “verify” their ideologically-driven, value-laden “hypotheses.”

Who could ever forget the Department for Work and Pension’s fake testimonials from fake benefit claimants telling us all how fakely beneficial the fakesters had found having their fake lifeline benefits withdrawn for fake non-compliance, leading to fake improvements of behaviour, presumably after a bout of fake starvation and destitution.

The new Work and Health Programme, aimed at reducing the number of people claiming Employment and Support Allowance (ESA), is currently still at a research and trialing stage. Part of the experimental nudge element of this research entails enlisting GPs to “prescribe” job coaches, and to participate in constructing “a health and work passport to collate employment and health information.”  (See The new Work and Health Programme: the government plan social experiments to “nudge” sick and disabled people into work.)

This raised some serious ethical concerns for me, which I addressed in a Freedom of Information (FoI) request to the Department for Work and Pensions (DWP). The most important part of the request was:

I should like to ask what ethical guidelines are in place regarding the use of behavioural theory on claimants. What guidelines are in place to protect claimants from any potential adverse effects of trials and experiments using methods aimed at changing behaviours of claimants? And what method of gaining claimant consent (to be used as a subject in trials and experiments ) is used by the Department and by job centres?

I did ask a further three brief and reasonable questions, citing a source of information – The Government Communication Service guide to communications and behaviour change quoting from it and explaining the questions.

My request was refused.

The DWP response

I can confirm that we hold information falling within the description specified in your request. However, we estimate that the cost of complying with your request would exceed the appropriate limit for central Government, set by regulations at £600. This represents the estimated cost of one person spending 3½ working days in determining whether the Department holds the information, and locating, retrieving and extracting it.

Under section 12 of the Freedom of Information Act the Department is not therefore obliged to comply with your request and we will not be processing it further.


Firstly, something as fundamentally important as safeguarding and ethical guidelines regarding government behavioural/psychological experimentation should actually be available for public access and scrutiny, not hidden away in a place that allegedly takes so much time, effort and money to locate.

Anyone would think those comments are simply an obstructive tactic, if the DWP can confirm that they have the information, then surely that reduces the cost and time spent retrieving and extracting it to comply with my request. Wouldn’t you think?

Someone who is earning £600 for 3½days work is on a very generous annual salary of around £45K. Unless this person is being paid to be intentionally incompetent and obstructive, their job skills suck, it has to be said. So do the logic and reasoning skills of the person who wrote that response.

I also know from experience that the DWP regularly respond only partially. They had the option of answering some of my request, at least. After all, they claim to have the information, seems a shame not to share some of it.

However, because the ethical considerations of government experiments and trials on people needing welfare support are so very important, I have pursued this request further by taking the option of simplifying it.

I wrote:

Dear DWP CAXTON HOUSE Communications,

You confirm that you have the information that I requested, but then claim that it would exceed the £600 limit to provide that
information which you state is because of the “estimated cost of one person spending 3½ working days in determining whether the Department holds the information, and locating, retrieving and extracting it.”

If you confirm you have the information, then surely that reduces the cost and time spent retrieving and extracting it to comply with my request.

I will however simplify my request. Most people would expect that ethical guidelines, safeguards and the important matter of client consent to participating in Government trials and experiments on people needing welfare support is something that the DWP would have to hand – easy to retrieve and very important information that one would expect to be in the public domain in any case. But I can’t find it.

I refer again to the The Government Communication Service guide to communications and behaviour change –

In particular, I refer to page 5: “Behavioural theory is a powerful
tool for the government communicator, but you don’t need to be an experienced social scientist to apply it successfully to your work.”

I should like to ask:

  • What ethical guidelines are in place regarding the use of behavioural theory on claimants?
  • What guidelines are in place to protect claimants from any potential adverse effects of trials and experiments using methods aimed at changing the behaviours of claimants?
  • And what method of gaining claimant consent (to be used as a subject in trials and experiments ) is used by the Department for Work and Pensions and by job centres?

Yours sincerely,

Susan Jones

Link to the request

Here is the FoI request and response in full: Use of behavioural theory to change behaviours of people claiming benefits.

Under Section 16 of the FoI Act the DWP should assist me in helping to narrow my request so that it may fall beneath the cost limit. I have narrowed my request and submitted a shorter, simplified version, focussing on the ethical issues only. It is reasonable to expect the DWP, whose remit includes face to face work with some of our most vulnerable citizens, to have ethical and safeguarding guidelines and consent forms to hand without having to pay someone hundreds of pounds for days of work to “find and retrieve” information that ought to be in the public domain anyway. 

In the event of that request being refused, I will be pursuing this further via the Internal Review Mechanism, and if need be, I shall be contacting the Information Commissioner’s Office.


I wonder if the response was influenced by this


My second amended request has been refused. I have therefore asked for an Internal Review. I said:

Dear DWP CAXTON HOUSE Communications,

I refer to your first response: “Under section 16 of the Act we
should assist you in helping you narrow your request so that it may fall beneath the cost limit. It may help to reduce the number of questions by refocusing it to only a few elements of the presently broad request. We will consider a fresh any revised request however we cannot guarantee that any revised request will fall within the cost limit.”

I subsequently submitted a narrowed and focussed request in
response, with just 3 basic questions from the initial FOI request. You responded by refering to my original request, and completely ignored my amended and narrowed down, shorter request.

I am therefore making a formal complaint that you did not address the reduced, simplified and narrowed down request. I am asking for an internal review.

I wrote:

“I should like to ask what ethical guidelines are in place
regarding the use of behavioural theory on claimants.

What guidelines are in place to protect claimants from any
potential adverse effects of trials and experiments using methods aimed at changing the behaviours of claimants?

And what method of gaining claimant consent (to be used as a
subject in trials and experiments ) is used by the Department for Work and Pensions and by job centres?”

You have stated that you do have this information. As I have
considerably narrowed down the request to 3 very basic questions, the costs involved in retrieving and providing it ought to be quite minimal. It’s also a very reasonable request. The DWP works with some of our most vulnerable citizens. It is especially important that in light of the current experimental nature of behavioural theories, and the current trialing of the new government health and work programme, that there are ethical guidelines and safeguards in place to protect vulnerable clients, and also, that there is a mechanism for gaining informed consent from clients who are subjects of trials and experiments.

These are issues that researchers within the medical sciences and social sciences have to consider every day. Using behavioural modification (“behavioural change theory”) methods on citizens without their consent and without engaging their deliberative processes has enormous ethical implications.

The British Psychological Society , for example, has strict code of
conduct and human research ethics –

And I refer to the Helsinki Declaration regarding medical research http://www.ncbi.nlm.nih.gov/pmc/articles…

The Geneva Declaration – https://en.wikipedia.org/wiki/Declaratio…

And the the Nuremberg code includes such principles as informed consent and absence of coercion; properly formulated scientific experimentation; and beneficence towards experiment participants – https://en.wikipedia.org/wiki/Nuremberg_…

These are just a few examples of codes of ethics regarding human research.

There are a wide range of legal and Human Rights implications
connected with experimentation and research trials conducted on social groups and human subjects. My request for clarification that there are ethical guidelines, safeguards and protections for subjects and basic consent mechanisms in place and the details of what they are is therefore a very reasonable one.

Yours sincerely,

Susan Jones

Link to this

I also added that Section 16 of the FoI Act places a duty on public authorities to provide reasonable advice and assistance to applicants. I was not provided with “advice or assistance.” I was not asked if I prefer to narrow my request in an alternative way to reduce costs (this is a breach of the section 16 duty to advise and assist). Nonetheless I did narrow my request, and that was completely ignored, the second response I received was related entirely to the initial request. In fact it was exactly the same response. I also challenged the DWP’s estimate of the costs of meeting my request. The rest of the grounds for my request for an Internal Review may be viewed here.

The Tories are not simply “out of touch”, their policies are deliberate and malevolent


It’s a common belief that inhumane Tory policies – which are directed at taking money and support from the most vulnerable citizens – have happened because of a kind of naivety, lack of experience, or a simple egocentricity of the privileged. Or general incompetence.

These certainly may well contribute to the obvious lack of joined-up thinking, apparent when we step back to consider that the most vulnerable citizens in our so-called civilised society are suffering and dying as a direct consequence of recent legislations and “reforms,” but it certainly doesn’t explain why the Tories persistently and historically CHOOSE to continue to ignore any other account of social reality but their own. That implies some intentionality, to me. Selective perception involves a certain degree of free will. And choice. 

So we are now almost through the doorway to the “mad or bad” debate.

Tories also reduce every single human deed to an underlying motivation of greed for financial gain, no matter what the circumstances. They know the price of everything and the value of nothing. Some would argue that this is classic Freudian projection. But that doesn’t account for the fact that the Tories normalise and make a virtue of the financial gain principle, for the wealthy, big business and of course, the Tories themselves. That corrupts government policy and our democracy. 

These motivations are held to be universal, and are translated into a vice when it comes to ordinary, everyday people, or in particular, poor and vulnerable people. That doesn’t hang together coherently at all, nor does it corroborate the view that the Tories are simply out of touch with everyday experience, since there is a deep and fundamental – and very apparent – contradiction here. It is a very significant flaw in their ideological grammar.

Human beings are not static when it comes to ideas and beliefs: we are capable of learning, and in a variety of ways: though experience, through the experience of others, through historical accounts, evidence and so on. The Tories simply choose to overlook the need. They prefer, instead, to stay put, or regress, and simply insist that they know best. Challenge a Tory, and they often believe that simply talking louder, and over the top of you will somehow make what they are saying “right.” They are not called “Conservative” for nothing – they do like to maintain a status quo and resist progressive change.

Tory notions of change apply only to their idea of how a society ought to be, hence the proliferation of legislation these past couple of years. The Conservatives are unravelling the progress we have made as a society, because they prefer the simplicity of basic feudal relationships. I’m not really joking here, unfortunately. The Tories are re-privileging the privileged and reinforcing a traditional hierarchy. 

It’s as if the clocks stopped the moment the Tory-led Coalition took Office, and now we are losing a decade a day.

The truth is that austerity is NOT about deficit-cutting. It’s just the cover for Tory ideology. It is actually about shrinking the State and squeezing the public sector until it becomes marginal, then non-existent, in an entirely market-driven society. The banking crisis-generated deficit has been a gift to the Tories in enabling them to launch the narrative that public expenditure has to be massively cut back, which they would never have been able to get away with without the deficit-reduction excuse in the first place.

Austerity won’t benefit the economy: it will damage it further, since the cuts will reduce the income of those that spend proportionally the most money and add to the economy – the poorest. Taking more money out of an already struggling economy and impacting local economies will simply exacerbate the problem. In the longer term, the Tories will destroy our prosperity as a nation, because they are disaster capitalists. Worse, they don’t care if citizens die as a consequence. 

“We can safely abandon the doctrine of the eighties, namely that the rich were not working because they had too little money, the poor because they had too much” – John Kenneth Galbraith

Nope, that hasn’t happened, the Tories are still taking money from the poor and handing it to the wealthy. Why? Is it because the Tories are phenomenologically impoverished and incapable of learning, ever? No, I don’t think so.

I think it’s much worse than that. I think that the Tories DO understand the consequences of their ideologically-driven policies, but they don’t care. Money for the wealthy has to come from somewhere, after all. The whole “out of touch/lack of experience” proposition overlooks the fact that the Tories refuse to listen, quite deliberately, they exercise authoritarian tactics to shut people up – such as excluding those people from debate who oppose their views – witnessed during the passage of the Health and Social Care Bill, for example. Then there is the “monitoring” of the media for alternative political “biases.”

That is a quite deliberate narrowing down of experience, not naivety, based on a lack of understanding. That’s deliberate, calculated and certainly bears all of the hallmarks of authoritarianism. That’s the wilful imposition of a pre-moulded, dystopic Tory version of reality onto a largely unwilling population.

The propaganda regarding unemployed, ill and disabled people is not based on naivety either: it is deliberate, and calculated, a horrible and wicked attempt to justify their small state ideology and punitive approach to stripping welfare provision from the poorest, and from vulnerable citizens to redistribute funds from the public purse to the already wealthy.

David Cameron, Iain Duncan Smith and Chris Grayling have all contributed a selection of propagandic pieces of work to the press – largely the Sun, Express and the Daily Mail. The language they use – words like “scrounger” “fraud” and “workshy” and the implied “burden on the state,” together with their knowledge that so-called benefit fraud was a mere 0.7% (and that includes DWP’s own errors, too) indicates clearly that the policies aimed at removing welfare provision, and the propaganda campaign that has led to an increase in hate crimes directed at sick and disabled people, are absolutely intentional.

10,600 chronically ill and disabled people died last year between January and November, many within six weeks of their ESA claim closing. It’s very telling that the Department for Work and Pensions do not monitor or account for just how many of those were passed as “fit for work” by Atos, or awaiting Appeal.

Furthermore, this Government introduced targets which were written into the Atos contract when they renewed it in 2010: 7 out of 8 sick and disabled people to lose their benefits.

Bearing in mind that those targets exist BEFORE those ill and disabled people are assessed (and the Government have also redesigned the work capability assessment to make sure that there is a heavy bias towards withdrawing people’s support) then we can reasonably infer that the Government see those deaths – that have happened as a result of absolute poverty and extreme distress, some of our most vulnerable citizens have had their means of meeting their basic survival needs removed – as an intended outcome.

That the Government have not acted upon the high number of deaths associated with their welfare “reforms” is truly outrageous, and also indicates quite plainly, to me, that this “outcome” is not simply a by-product of their legislation, or incompetence, or lack of experience: it is calculated and intentional. All policies are intentional. 

This is much, much worse than a little “Tory egocentricity,” incompetence, phenomenological ineptitude, or naivety: this is the deliberate, calculated and wholesale destruction of every State mechanism of support for the most vulnerable citizens as well as for the “ordinary” person. If people cannot meet their basic needs – food, warmth, shelter and so on, they die. That is fact, it’s common sense, something that everyone knows.

Yet this Government are taking away people’s only means of support. Social security, the safety net paid for by the tax paying public to ensure no-one dies of starvation or exposure. This Government have stolen our collective funds for social security, and blamed those they have stolen it from for their deed.

They blame the poor for poverty. They blame the unemployed for unemployment. But we know that the Government are to blame. Have you ever noticed that, historically, whenever poverty grows and inequalities become wider and deeper, look to the helm and lo and behold, we have a Tory-led Government steering the way. We need to put this Government out of our misery.

Every single “reform” has been about taking money away from the poorest and some of the most vulnerable people. The fact that the Legal Aid Bill has been timed for implementation next year, when the horrific consequences of the welfare cuts, the bedroom tax and the new council tax will become very apparent, as well as the Health and Social Care reforms, indicates quite plainly that these policies have been planned and coordinated for a long time.

The Legal Aid Bill means that challenging the Government regarding the reforms will be very difficult. Indeed, the Coalition have been steadily removing the essential democratic processes that safeguard our human rights and enable us to challenge effectively.

This is certainly an authoritarian Government.

We should hang their heads in shame.

It’s truly despicable. How utterly horrifying that they are getting away with it. There is an increasingly discernible taint of eugenics embedded in Tory ideology. This, and the propaganda, smoke and mirrors, media scapegoating diversions and theft from the poorest to handout to the wealthiest –  these actions are intentional, calculated and are being increasingly inflicted and administered, whilst the general population waits passively in the wings, shrugging off the blow by hammer blow accounts: more bad news of further Tory cuts, more devastating consequences. More preventable deaths.

Too many people are finding temporary distractions, watching the idiot box, hoping quietly that those things they can see from the corner of their eye are not real. 

Oh, but they are.


Hanlon’s razor is an eponymous adage that allows the elimination of unlikely explanations for a phenomenon. It reads: “never attribute to malice that which is adequately explained by stupidity.”

However, I always considered intentional malice and stupidity to be strongly correlated characteristics.