Sharing details of a client's benefit award with a third-party representative: FOI release

FOI Reference: FOI/202500491205
Date received: 29 October 2025
Date responded: 24 November 2025

Information requested

Copies of any policy documents, internal guidance, staff instructions, or training materials used by Social Security Scotland that set out the rules or procedures regarding:

Request for information 1:

The circumstances in which Social Security Scotland staff may or may not share details of a client’s benefit award (including the rate, decision outcome, award duration, and reasons for the decision) with a third-party representative.

Request for information 2:

How such disclosure is handled when there is a valid form of authority signed by the client, and where the thirdparty representative section of the application form (for example, the Pension Age Disability Payment form) has been completed and accepted by Social Security Scotland.

Specifically, I am seeking to understand:

• Why information about whether a client has been awarded the higher or lower rate of Pension Age Disability Payment, and the reasons for that decision, cannot be shared with an authorised thirdparty representative when the client has explicitly given consent for all communications.
• Whether there are any internal data protection or operational policies that restrict such
• Communication by phone, email, or other means, despite a signed authority being in place.

Please include any guidance, staff memos, call-handling instructions, or legal interpretations relied upon to justify withholding award outcome information from authorised representatives.

Response

Request for information 1 and 2:

Some of the information you have requested is available from the Social Security Scotland and mygov.scot websites at:

Social Security Scotland - Client Representative guidelines – Part 7 – Third party representatives

Decision about your Adult Disability Payment application - mygov.scot

Decision about your Pension Age Disability Payment application - mygov.scot

Pension Age Disability Payment

Under section 25(1) of FOISA, we do not have to give you information which is already reasonably accessible to you. If, however, you do not have internet access to obtain this information from the website(s) listed, then please contact me again and I will send you a paper copy.

For more details on ‘Information that can and cannot be shared with a third-party representative’ see attached document.

About FOI

Social Security Scotland is committed to publishing all information released in response to Freedom of Information requests. The Scottish Government also publishes responses to requests.