Policies for handling vulnerable income support claimants

​​​Request ​815508446

Under the Freedom of Information (Jersey) Law 2011, I request information relating to the handling of vulnerable or disabled claimants within Income Support. 

Specifically: 

1. Any policies, procedures, or guidance relating to the identification and handling of vulnerable claimants, including those with long-term incapacity or disability. 

2. Any requirements, adjustments, or additional safeguards applied when dealing with vulnerable or disabled individuals. 

3. Any internal guidance on communication, decision-making, or support measures for such claimants. 

4. Any training materials or internal documents provided to staff regarding the treatment of vulnerable or disabled claimants.

Response

1.

The identification of vulnerable/disabled customers is something a customer or 3rd party agency may declare to us and then appropriate support mechanisms can be put in place. In addition, the Employment Social Security & Housing Safeguarding process, including guidance on identifying safeguarding alerts, is set out in the attached document.

Safeguarding Process and Guidance - redacted.pdf​

2&3.

Vulnerable or disabled individuals can be supported by an agent, family or friend during appointments. Accessible rooms are available which have been reviewed as accessible by our Diversity, Equity and Inclusion team. The online webpages for accessing Income Support contains Easy Read facilities and can be accessed here: Applying for Income Support.. A dedicated translation service is available to assist non-English speaking customers.

General safeguarding policies and multi-agency guidance applicable to all vulnerable individuals are published by the Safeguarding Partnership Jersey and can be accessed at:

Resources | Safeguarding Partnership Jersey​

4.

The following training and development sessions are available to staff within the Employment Social Security and Housing department.​

​From the list above, the following courses are provided to us by another department or external agencies therefore, this information is not held for the purposes of Article 3 of the Freedom of Information (Jersey) Law 2011.

• Trauma Informed Practice

• Dementia Awareness

• SPELL Training

• Foundation Safeguarding Training for Adults & Children

We pay a fee to an external training provider and therefore the following training material are exempt under Article 33(b) (Commercial Interests) of the Freedom of Information (Jersey) Law 2011.

• Diversity Equity & Inclusion

• Hidden Disability Training

• Accessibility Fundamentals

• Mental Health Awareness

• Autism Awareness

• Disability Awareness and Inclusion

• Unconscious Bais for Employees

• Unconscious Bais for Managers

• Domestic Abuse Training

Articles Applied:

Article 3- meaning of information held

Meaning of “information held by a public authority”

For the purposes of this Law, information is held by a public authority if –

(a) it is held by the authority, otherwise than on behalf of another person; or

(b) it is held by another person on behalf of the authority.

Article 33

Article 33 Commercial interests

Information is qualified exempt information if –

(a) it constitutes a trade secret; or

(b) its disclosure would, or would be likely to, prejudice the commercial interests of a person (including the scheduled public authority holding the information).

Public Interest test

Article 33 (b) is a prejudice-based exemption. That means that in order to engage this exemption there must be a likelihood that disclosure would cause prejudice to the interest that the exemption protects. In addition, this is a qualified exemption, and consideration must be given to the public interest in maintaining the exemption.

The Scheduled Public Authority (SPA) considers that the relevant training materials are commercially sensitive and owned by third party providers. Disclosure of these materials into the public domain would remove the providers’ ability to control further use or distribution of their content. This would be likely to prejudice the commercial interests of those third-party training providers, including by undermining their ability to protect their training content and operate effectively in a competitive market. We therefore consider that the likelihood threshold of ‘would be likely to prejudice’ is met and that Article 33(b) is engaged.

Public interest in disclosure

We recognise that there is a degree of public interest in transparency regarding the training provided to employees, particularly where that training relates to the treatment of vulnerable or disabled individuals. Disclosure may assist public understanding of how staff are supported and trained in this area. This public interest has been met in part by listing the training provided, availability and whether it is delivered internally or externally.

Public interest in maintaining exemption

We consider there is a public interest in not disclosing the training material of our third-party training providers. The training materials are developed for commercial use and disclosure would remove the providers’ ability to control how their content is used or distributed. There is also a strong public interest in ensuring that public authorities are able to engage external providers, without creating a risk that licensed or commercially sensitive materials will be disclosed into the public domain. Failure to protect such interests could affect our relationships with such third party providers and a willingness to work with the public sector, which in turn would reduce access to expert training and would not be in the wider public interest.

The SPA considers that while there is a public interest in transparency, this is outweighed by the public interest in maintaining the exemption under Article 33(b) in order to avoid likely prejudice to the commercial interests of third-party providers. The information is therefore withheld.