Information request and response under the Freedom of Information (Scotland) Act 2002
FOI Reference: FOI/202500478600
Date received: 1 August 2025
Date responded: 1 September 2025
Information requested
I request the following information regarding the AI Document Understanding system used by Social Security Scotland:
Request for Information 1: Any fairness assessments, algorithmic impact assessments, or equality impact assessments conducted in relation to this system, including any documentation on potential bias by protected characteristics (e.g. disability, ethnicity, gender)
Request for Information 2: Any correspondence or advice sought from external regulatory bodies (e.g. EHRC) on risks of discrimination or bias in this system.
Response
Request for Information 1:
While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have some of the information you have requested. The AI document understanding system is not user facing and it is not trained on personally identifiable information. Therefore, there is no requirement to undertake the assessment methods requested.
This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have some of the information you have requested.
In relation to the Equality Impact Assessment (EQIA) the project team gave due consideration as to whether this was required. A declaration of EQIA not required was completed to confirm this. We have included this as per your request for relevant documentation. The declaration was signed off by email.
An exemption under section 38(1)(b) of FOISA (personal information) applies to a small amount of the information requested because it is personal data of a third party, e.g. names/contact details of individuals, and disclosing it would contravene the data protection principles in Article 5(1) of the General Data Protection Regulation and in section 34(1) of the Data Protection Act 2018. This exemption is not subject to the ‘public interest test’, so we are not required to consider if the public interest in disclosing the information outweighs the public interest in applying the exemption.
Request for Information 2:
While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have the information you have requested. There are no personal attributes considered with the AI document understanding system therefore no external advice was required.
This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.
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. You can view the responses at http://www.gov.scot/foi-responses.
FOI 202500478600