Information request and response under the Freedom of Information (Scotland) Act 2002
FOI Reference: FOI/202500483072
Date received: 1 September 2025
Date responded: 29 September 2025
Information requested
Information regarding the current 'Future Operating Model' restructuring which affects the Chief Digital Office, Business Change Management, and Programme.
Request for information 1: Any documents, policies, or internal guidance setting out the process being followed for this restructure.
Request for information 2: The total number of staff affected by the restructure, broken down by grade and team if available.
Request for information 3: Any equality impact assessments, health and safety assessments, or other formal assessments carried out in relation to the restructure.
Request for information 4: Any reports, internal communications, decision logs, or minutes of meetings in with the restructure was discussed or approved, dated between March 2025 and the date of this request.
Response
Request for information 1:
Social Security Scotland are following the restructuring and reassignment policy through the future operating model restructures. This policy and accompanying procedures set out the range of measures and approaches that will be put in place to support restructuring exercises and explains how they will be applied in practice.
Annex 1 provides a copy of the restructuring and reassignment policy.
This is complemented by the restructuring and reassignment procedure within Social Security Scotland that explains how we apply the policy. The guidance explains the different stages of the process and the steps to follow when managers are looking at their team resource, thinking of conducting a restructure, and considering reassigning staff.
Annex 2 provides a copy of the restructuring and reassignment procedure within Social Security Scotland.
Clear processes outline how people will be matched into posts in the new structure, these processes follow the restructuring and reassignment policy.
Annex 3 provides a copy of the matching process document.
All people activity is being underpinned by the strategic people principles.
Annex 4 provides a copy of the strategic people principles.
Request for information 2:
The table below provides a headcount of the permanent staff by team who will be affected by the restructuring.
Directorate / Division |
Total Headcount |
Chief Digital Office - Applications and Platforms |
29 |
Chief Digital Office - Architecture and Design |
46 |
Chief Digital Office - Data Office |
38 |
Chief Digital Office - Digital Risk and Security |
31 |
Chief Digital Office - Engineering and Cloud Services |
102 |
Chief Digital Office - Product |
70 |
Chief Digital Office - Service Management and Service Development |
82 |
Chief Digital Office - Strategy, Business and Engagement |
17 |
Organisational Strategy and Performance - Business Change Management |
96 |
Social Security Scotland Directorate - Programme |
358 |
TOTAL |
869 |
The table below provides a headcount of the permanent staff by grade who will be affected by the restructuring.
Grade |
Total Headcount |
A3 and A4 |
7 |
B1 |
60 |
B2 |
183.5 |
B3 |
346.5 |
C1 |
199 |
C2 |
53.5 |
C3 |
15.5 |
SCS - Deputy Director 1 |
4 |
TOTAL |
869 |
Request for information 3:
This report provides a summary of the Equality Impact Assessment conducted on organisational restructure and staff movement, which considered the potential effects and impact of organisational restructure and staff movement upon groups of colleagues with protected characteristics.
Annex 5 provides a copy of the equality impact assessment summary report which was completed for the organisational restructure and staff movement.
Request for information 4:
While our aim is to provide information whenever possible, in this instance the costs of locating, retrieving and providing the information requested would exceed the upper cost limit of £600. To ascertain the information requested would require individual mailbox searches of everyone associated with the project.
Under section 12 of FOISA public authorities are not required to comply with a request for information if the authority estimates that the cost of complying would exceed the upper cost limit, which is currently set at £600 by Regulations made under section 12.
You may, however, wish to consider reducing the scope of your request in order that the costs can be brought below £600. You may also find it helpful to look at the Scottish Information Commissioner's 'Tips for requesting information under FOI and the EIRs' on his website at:
How do I ask for information? | Scottish Information Commissioner (foi.scot)
An exemption under section 38(1)(b) of FOISA (personal information) applies to some of the information requested because it is personal data of a third party, ie 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.
An exemption under section 30(b)(i) of FOISA (free and frank provision of advice) applies to some the information requested. This exemption applies because disclosure would, or would be likely to, inhibit substantially the free and frank provision of advice. This exemption recognises the need for officials to have a private space within which to provide free and frank advice to other officials before the Scottish Government reaches a settled public view. Disclosing the content of free and frank advice on The Future Operating Model will substantially inhibit the provision of such advice in the future, particularly because these discussions are still ongoing and decisions have not been taken.
This exemption is subject to the ‘public interest test’. Therefore, taking account of all the circumstances of this case, we have considered if the public interest in disclosing the information outweighs the public interest in applying the exemption. We have found that, on balance, the public interest lies in favour of upholding the exemption. We recognise that there is a public interest in disclosing information as part of open, transparent and accountable government, and to inform public debate.
However, there is a greater public interest in allowing a private space within which officials can provide full and frank advice to other officials, as part of the process of exploring and refining the Government’s position on the Future Operating Model, until the Government as a whole can adopt a decision that is sound and likely to be effective. This private thinking space is essential to enable all options to be properly considered, based on the best available advice, so that good policy decisions can be taken.
Premature disclosure is likely to undermine the full and frank discussion of issues between Ministers and officials, which in turn will undermine the quality of the decision making process, which would not be in the public interest.
The following working group meeting notes have been identified where the restructuring work was discussed or approved.
Annex 6 provide copies of meeting notes where the Future Operating Model was discussed.
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 202500483072