The following was submitted as a joint response by Malcolm Gardner from Team Netsol Ltd and entitledto Director Phil Agulnik to the Scottish Parliament's Social Security Committee take-up inquiry in November 2019.
Both Phil and Malcolm will also be giving evidence to the committee tomorrow - 9am, Thursday 23 January - which can be viewed live on the Scottish Parliament TV website.
There are many factors behind low take-up of benefits, as detailed in other submissions to the enquiry. However, a persistent theme is that the hassle of applying for benefits put some people off, particularly as it often involves filling out multiple forms.
For people who are unable or unwilling to use the internet then the existence of multiple paper forms, and complicated rules, is a difficult issue to resolve without investing significant amounts in benefits advice (instead of, for instance, increasing benefit levels). But for an increasing proportion of the population the issue is principally about how they access benefits via the internet. Even people who are happy with, and in some cases prefer, digital channels, still face a system where many do not know their entitlements or are put off by the difficulty of application process.
The approach adopted by some LAs is in combining forms (see for instance the submission from Highland Council about their single application form). But because different benefits are administered by different agencies there will always be limits in terms of how far this approach can go.
The limits are:
- inconsistencies in the requirements and the intentions of different benefit schemes, and
- rigid interpretation of data protection rules, agency and organisational reluctance to share data (in the case of private sector companies to share anything that could undermine their market share), and
- a failure to ensure that there is a golden thread running from data collection through assessment to outcomes.
This combination of limits means that most analytical assessments used to identify potential impacts on current claimants can only superficially indicate potential take-up.
Most welfare Impact assessments have not really been more than data matching exercises that are reactive to known events. To create successful take-up four processes are required:
1) Simplified application form that utilises known data (from a range of data sources) and elements of AI and machine learning to identify citizen’s needs.
2) Real time analysis of conditions that can not only react to changing situations but also predict both actual and likely changes to circumstance. This form of analytics goes beyond data matching and data filtering by making deductions through techniques such as statistical inference and hypotheses utilising machine learning algorithms that automatically apply complex mathematical calculations to big data.
3) More ambitious is data interoperability  which would allow policy makers and administrators to target, not only those citizens who we know are need of support but critically those that are hidden from us.
4) A communications platform that utilises direct communication with the citizen, focusing on information, and prompted (email, SMS, push) notifications to helping applicants and claimants to ensure that changes to their circumstances are maintained–thus avoiding overpayments./p>
Data interoperability can be supported by a range of appropriate data sources, such as, data owned by the Scottish Government, Local Councils and through Open Banking, HMRC tax data, DWP data. GDPR permissions should be incorporated into the data collection and the single application form to safeguard personal data.
One of the biggest blockers to take-up is data protectionism, whereby data owners create pseudo data protection rules that places blockers on the appropriate sharing of data. A recent report by HMRC 'Customer Experiences of Tax Credit Overpayments' highlights that customers are unclear about what details they have to report and to who. There is an expectation that information reported to one agency will be shared with another. While this may not be treated as carte blanche sharing, it is expected that data should be shared where it is in the best interest to do so.
It is clear, that the citizen would be more inclined to take up benefits if they were assured that the application is simple and appropriate data is reused and shared where it prevents a detrimental impact on another benefit or support.
As a Benefits Manager for a large urban town, I was often asked by elected members to run take-up campaigns. The key issue for any of my campaigns was communication and simplifying the application process. Any campaign will achieve improvement in take-up. The inherent difficulties are, for a short period of time, alleviated by the additional resources allowing that assistance is given in completing claim forms. And where communication is targeted to selected groups or cohorts, and resources are made available to ensure quicker assessments.
But for take-up to be successful then it must be a living and continuous process. We believe that new technology and modern direct media allows for the process of take-up and claiming to be streamlined and automated. We would not do this alone. Both Team Netsol and entitledto would see that to architect a quick and efficient welfare system does not need to merge benefits but to manage data flows, machine learning and communication so that support can act as a hive resource interacting directly with the citizen.
As providers of entitlement calculators and claim forms we want to play our part in reducing the difficulty of finding out what you are entitled to and then applying for it and ensuring that your claim is properly and efficiently assessed, awarded and maintained.
We partner with other providers for the range of skills and services needed for modern technological solutions. Whether that is AI and Machine learning from the likes of XpertRule Ltd or telephony and push services suppliers or data sources such as Ascendant Solutions Limited or Experian. Equally, we believe that the technology is the tool to deliver policy and strategy and not in itself the driver of better services. Therefore, we always see our primary partner is regional and local government.
Team Netsol Ltd ran the electronic Scottish census in 2011, the most successful online census in Europe. It also has 20 years’ experience in collecting data and managing sophisticated multi-benefit electronic applications forms.
entitledto is one of the most trusted providers of an award-winning multi-benefit calculator, used by local authorities, social housing providers and welfare advice agencies.
Both Malcolm and Phil have long experience in social policy. Malcolm started his career in ICT but spent the last 25 years running revenues and benefits departments, counter-fraud teams and the Welfare Reform Club. He has now returned to his technological roots as business analyst for Team Netsol. Phil is a foremost expert in benefit policy and its application, and this knowledge has ensured that entitledto has remained the best calculator of its kind.
Between the two companies we cover 75% of Scottish Households.
 Data interoperability addresses the ability of systems and services that create, exchange and consume data to have clear, shared expectations for the contents, context and meaning of that data.