Social Security Scotland’s use of Artificial Intelligence (AI) technology: FOI release

Information request and response under the Freedom of Information (Scotland) Act 2002

FOI Reference: FOI/202500484275
Date received: 10 September 2025
Date responded: 8 October 2025


Information requested

Social Security Scotland’s use of Artificial Intelligence (AI) technology:

Request for Information 1: A list of tools, platforms or systems currently deployed or being piloted/trialled.

Request for Information 2: The purpose and function of each of the above.

Request for Information 3: The departments or services where these are operational.

Request for Information 4: Details of any contracts, tenders or partnerships with external providers for AI solutions.

Request for Information 5: Total expenditure on AI related technologies over the past three financial years, broken down by year.

Request for Information 6: Copies of, or information relating to, any internal policies, frameworks or guidance documents relating to the use of AI.

Request for Information 7: Any ethical review processes or risk assessments conducted prior to deployment.

Request for Information 8: Details of any group responsible for the oversight of AI use within your organisation.

Request for Information 9: Any assessments, reports or internal communications regarding the impact of AI on staffing levels, job roles or workforce planning (including recruitment, redundancy).

Request for Information 10: Information on any roles that have been automated, restructured or made redundant due to AI implementation.

Request for Information 11: Details of any training, redeployment or upskilling initiatives offered to staff in response to the adoption of AI.

Request for Information 12: Any consultations with trade unions or staff representatives regarding AI-related changes.

Request for Information 13: Evaluations, audits or performance reviews of AI systems, as referenced in section 1.

Request for Information 14: Evidence of how AI systems have affected service delivery, decision-making or operational efficiency.

Request for Information 15: Types of data used to train or operate AI systems, including whether this data is synthetic or not.

Request for Information 16: Measures in place to ensure compliance with data protection legislation, including the DPA 2018 and UK GDPR.

Request for Information 17: Procedures for handling bias, transparency and accountability in AI decision-making.

Response

Request for information 1 and 2:

All of the information you have requested is available from the Scottish AI register - https://scottishairegister.com/.

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.

Please note Social Security Scotland staff also have access to Co-Pilot as part of our wider Microsoft package provision from Scottish Government shared services.

Request for information 3:

We have two AI tools which are currently operational in the following areas:

Brandwatch - used by our external communications team.

Document Understanding – is used within Client Services Delivery specifically for Adult Disability Payment and Child Disability Payment.

Request for information 4:

Details of any contracts, tenders or partnerships with external providers for AI solutions. Please find below the information you have requested for Brandwatch:

Contract Commencement Date – 01 April 2025 Contract Expiry Date – 31 March 2026

The published contract notice can be found here - View Notice - Public Contracts Scotland

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.

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have some information you have requested. This is because the Document Understanding Tool was developed by colleagues in our Chief Digital Office.

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.

Request for information 5:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have some information you have requested. This is because the Document Understanding Tool was developed by colleagues in our Chief Digital Office.

This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.

Some of the information you have requested is available from the prior Freedom of Information responses below. 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.

Social Security Scotland - Information relating to Social Security Scotland's Social Media Management Tool: FOI release

Social Security Scotland - Information relating to Social Media: FOI release

Request for information 6:

The information you have requested is available online from the below site:

https://www.scottishai.com/scotlands-ai-strategy

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.

We have also attached a copy of our Artificial Intelligence Adoption Framework.

Request for information 7:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have some information you have requested. Our use of AI does not use personal data or impact upon job roles and, as such, no ethical reviews or risk assessments have been carried out.

This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.

You may find these prior Freedom of Information responses helpful:

Social Security Scotland - AI Document Understanding or Client Advisor Knowledge Assist systems used by Social Security Scotland: FOI release

Social Security Scotland - AI Document Understanding and Client Advisor Knowledge Assist systems: FOI release

Social Security Scotland - AI Document Understanding system: FOI release

Request for information 8:

The AI Working Group are responsible for the use of AI technology within Social Security Scotland. Further existing governance groups have oversight of AI use within Social Security Scotland. These include Equalities, Data Governance and Architecture Governance. In circumstances where decisions are required at a strategic level, these will be considered by the Executive Team.

Please see attached the Terms of Reference for our AI working group. 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, i.e. 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 9 and 10:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have the information you have requested. This is because no evaluation has been conducted to date, as the use of AI thus far has had no impact on staffing levels, job roles or workforce planning within Social Security Scotland and no roles have been made redundant due to AI implementation within the Agency.

At present, zero roles within our organisation have been automated, restructured, or made redundant as a direct result of AI implementation. We also do not currently collect or maintain data on this topic.

The Scottish Government has an existing Restructuring and Reassignment policy in place where job roles are changing due to a reduction in the volume of work that is delivered by certain staff and teams; the ceasing of work either as a result of re-prioritisation or completion; or a change to the nature of work or its delivery. According to the restructuring and reassignment policy, the Scottish Government also has a no compulsory redundancies policy commitment that is reviewed annually as part of pay negotiations.

This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.

Request for information 11:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have the information you have requested. This is because no training or upskilling on AI is currently delivered by Social Security Scotland. We are planning to develop learning materials for our staff to use AI capabilities in future.

This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.

You may be interested to know that the Scottish Government is committed to building internal capability and expertise to ensure the sustainable and responsible adoption of AI technologies.

AI-related training and upskilling initiatives are led by the AI Policy Unit, with specialist support from The Data Lab, and are aligned with the Scottish Government’s AI Strategy, which promotes inclusive, ethical, and trustworthy use of AI. Staff training has also been delivered internally, including through the Scottish Digital Academy.

These initiatives focus on equipping staff with the knowledge and skills to use AI safely and ethically, rather than on redeployment. The content is based on guidance developed for civil servants’ use of AI.

For further details, please see: Guidance on the use of ChatGPT or AI large language models: FOI

Request for information 12:

Consultation and discussions with the recognised civil service trade unions regarding AI related changes are ongoing. A series of upcoming meetings have been scheduled with the trade unions regarding public sector reform, where any discussions on AI-related changes would take place. Union representatives regularly attend the Social Security Scotland AI Working Group, which governs new requests to use AI.

Please see attached terms of reference for our AI working group. 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, 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.

Request for information 13:

The information you have requested is available from prior FOI response Social Security Scotland - AI Document Understanding and Client Advisor Knowledge Assist systems: FOI release.

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.

Request for information 14:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have the information you have requested. This is because no analysis has been carried out.

This is a formal notice under section 17(1) of FOISA that Social Security Scotland does not have the information you have requested.

Request for information 15:

Brandwatch is operated on data from social media posts.

The Document Understanding tool was trained on synthetic PDF application forms to train it how to retrieve information from our applications.

Request for information 16:

The information you have requested is available from the below:

https://www.mygov.scot/social-security-data

https://www.socialsecurity.gov.scot/privacy-notice

https://www.socialsecurity.gov.scot/reporting/publications/information-relating-to-safeguarding-privacy- and-gdpr-policies-foi-release

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.

Request for information 17:

While our aim is to provide information whenever possible, in this instance Social Security Scotland does not have the information you have requested. This is because the AI systems we use have not been trained on personal data and are not used for decision making. Therefore, there has been no requirement to develop procedures for handling bias, transparency and accountability in AI decision- making.

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 202500484275 Additional Documents

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