Credit Reference Agencies
Various initiatives involving the processing of DWP customers’ data with credit reference agency (CRA) data have been identified and it is possible that more may arise in the future. The potential benefits of these initiatives have varied and have been both operational and for research.
This guidance is to sign-post staff who are exploring any new initiative. It is a potentially complex and sensitive area. Business owners will need help with the handling and legalities. You are strongly advised to engage with those specialist branches identified here at the earliest opportunity. It would be wise not to commit to deliverables and deadlines until you are satisfied you have all the bases covered.
Over recent years Fraud, Error and Strategy Division has engaged with CRAs in developing data matching and other processes to combat fraud. They will be able to provide advice based on their experience of best practice for working with CRAs.
Data Sharing and Access Management (DSAM) have overall responsibility for initiatives involving exchanges of data into and out of the Department. You will need to involve them as soon as you have an initiative you wish to take forward. They have helpful guidance and a Data Sharing Protocol pro-forma which will help guide you through the steps you should follow. These are available on their intranet site along with contact details. The DSAM material will steer you to check the strategic desirability, operational feasibility and lawfulness of your initiative.
Lawfulness can be achieved in different ways according the nature of the proposal. Just because one data exchange with CRAs was lawful does not necessarily mean that they all will be, even if they appear similar. It will be necessary to involve lawyers (and specifically Sol Commercial if the initiative involves the CRAs acting for DWP under contract). In the first instance for legal and data protection policy advice, you should contact Legal Group who will advise.
Information, Devolution and Governance will also advise on handling in relation to the Information Commissioner who takes a keen interest in these initiatives.
There is a Framework Agreement with all 3 Credit Reference Agencies i.e. Experian, Equifax and Callcredit. Anyone in DWP who wants to use CRAs must involve Business and Financial Services Category team in Commercial Directorate. The Framework Agreement ensures competition between the 3 CRA’s is maintained to achieve value for money and prevent any individual CRA being given an unfair advantage. Commercial Directorate will need to carry out a mini (streamlined) tendering process for each requirement as it arises, hence the need to involve them at an early stage.