Corporate report

Adult Disability Payment: Service Level Agreement

Updated 26 November 2025

Applies to England and Scotland

Key personnel Name Role
Author [Redacted] [Redacted]
Owner Ally MacPhail Deputy Director, Organisational Strategy and Performance
Owner Helga Swidenbank Director for Accessibility, Disability and Disputes
Owner Margarita Morrison DWP Director for Scotland and National Services, Operations
Owner Martin Brown DWP Director Retirement Services
Owner Vikki Knight Director for Fraud, Error and Debt Policy & Strategy

1. Parties

1.1. This Service Level Agreement (hereafter referred to as ‘this Agreement’) is entered into between the Secretary of State for Work and Pensions of Caxton House, Tothill Street, London, SW1H 9NA and the Scottish Ministers of, St Andrew’s House, Regent Road, Edinburgh EH1 3DG acting in some instances through Social Security Scotland.

1.2. References to the Scottish Government (SG), the Scottish Ministers or Social Security Scotland will, as appropriate, be read as also including reference to each of the other entities.

1.3. References to Secretary of State for Work and Pensions shall be read as including reference to the Department for Work and Pensions (DWP), as appropriate, and vice versa.

2. Scope and principles

2.1. This Agreement sets out the provisions of the relationship between Scottish Ministers and DWP in relation to Adult Disability Payment (ADP) and ‘the Services’ DWP will provide to support this. The Services are described in Annexes 1 to 11c.

2.2. Adult Disability Payment has replaced DWP’s Personal Independence Payment and Disability Living Allowance Working Age in Scotland and is administered by Social Security Scotland. Social Security Scotland and DWP have completed the transfer of all Personal Independence Payment claims to Adult Disability Payment. This agreement has been revised to include people moving from England and Wales to Scotland and who will be required to make a new application to Adult Disability Payment.

2.3. Separate arrangements have been agreed in relation to the interaction between Adult Disability Payment and reserved benefits. Where a client is in receipt of Adult Disability Payment in the qualifying period for Christmas Bonus, Scottish Ministers will provide data to DWP to ensure the reserved benefit is assessed accurately.

2.4. DWP will deal with customer enquiries relating to Adult Disability Payment by sign posting customers to Social Security Scotland.

2.5. DWP and Scottish Ministers shall work in partnership to ensure that the Services are delivered in accordance with the terms of this Agreement.

2.6. The partnership will seek continuous improvement in delivery standards including sharing lessons from delivery of the Services insofar as relevant.

2.7.Each Party will act transparently and will work in a practical way in regard to reaching mutual agreement on any issues that may arise.

3. Duration

3.1. This Agreement replaces the Initial Agreement. The Services will be delivered as outlined in Annexes 1 to 11c. This Agreement shall commence on the 6 November 2025. This Agreement is subject to review by each Party on or before the date twelve (12) months after the signing of this Agreement or when deemed appropriate and agreed by each Party.

3.2. This Agreement may be varied, by mutual written agreement of each Party at any time during the Term. Variations to this Agreement will be agreed by each Party and no additional/further work will be undertaken until principles for funding the work are agreed.

3.3. For the avoidance of doubt, any variations agreed between the Parties must be put forward in writing and shall form an amendment to this Agreement.

3.4. In the event of DWP or Scottish Ministers choosing to terminate this Agreement, DWP and Scottish Ministers shall prepare and agree an appropriate exit plan for the termination of the Services which will seek to ensure no impact on the delivery of Adult Disability Payment.

3.5. Each Party will provide twelve (12) months’ notice of termination in writing.

4. Derivation

4.1. This Agreement forms an annex to the ‘Memorandum of Understanding (MoU) between Scottish Ministers (SM) and Secretary of State for Work and Pensions (SSWP) on joint working arrangements covering the implementation of devolved provisions in the Scotland Act 2016 relating to Social Security and Employment Support Services in Scotland’, and is to be read in conjunction with the following documents, and any subsequent arrangements which are agreed and support this Agreement, insofar as they are not replaced or terminated in the future:

Document Version/Date
Concordat between the Department for Work and Pensions and the Scottish Government March 2020
Memorandum of Understanding and Supplementary Agreements on Devolution between the United Kingdom Government, the Scottish Ministers, the Welsh Ministers and the Northern Ireland Executive Committee (MoU on Devolution) October 2013
Memorandum of Understanding (MoU) between Scottish Ministers (SM) and Secretary of State for Work and Pensions (SSWP) on joint working arrangements covering the implementation of devolved provisions in the Scotland Act 2016 relating to Social Security and Employment Support Services in Scotland (SM/SSWP Single MoU) and the following Annexes: Disability Living Allowance Agency Agreement —- Personal Independence Payment Agency Agreement —- [Redacted] —- [Redacted] January 2023
Initial Service Level Agreement (Inc variations of that agreement agreed from time to time) between Department for Work and Pensions and the Scottish Ministers in respect of Adult Disability Payment – V1.0 (the ‘Initial Agreement’) March 2022
[Redacted] [Redacted]
Memorandum of Understanding Between The Secretary of State for Work and Pensions and The Scottish Ministers acting through the Scottish Government and on behalf of Social Security Scotland in relation to benefit accounting and reconciliation services provided to the Scottish Ministers March 2020
The Agreement between the Scottish Government and the United Kingdom Government on the Scottish Government’s fiscal framework August 2023
Scottish Devolution: Financial Arrangements for Formal Agreements April 2025
Scottish Devolution: A Framework for Audit and Accountability March 2019
DWP and SG Joint Communications Framework December 2023
[Redacted] [Redacted]

5. Revision to this agreement

5.1. DWP agrees to inform Scottish Ministers as soon as reasonably practicable in advance of any potential changes that may impact on or require changes to the Services.

5.2. Each Party would need to agree whether a revision to this Agreement is required, subject to paragraph 3.2 and 3.3 above.

5.3. Any mutually agreed minor changes or amendments to this Agreement will be dealt with through normal means of communications, by the single point of contacts (SPoCs).

SPoCs for each Party are as follows:

SG SPoC DWP SPoC
[Redacted] [Redacted]

5.4. Where more significant change is required, the SPoCs will apply the appropriate Business as Usual (BAU) change control processes. Where the change is agreed it will be incorporated into this Agreement as an amendment following any review as detailed in 3.2 and 3.3 above.

6. Disputes

6.1. In the first instance DWP and Scottish Ministers will notify each other of any issues, concerns or complaints regarding any matter covered by this agreement.

SPoCs for each Party are as follows:

SG DWP
[Redacted] [Redacted]

6.2. The process for dispute resolution is outlined in Section 6 (Escalation) of the ’SM/SSWP Single MoU’, as referenced in Section 4 (Derivation) of this Agreement.

7. Roles and responsibilities

7.1. Scottish Ministers will, as set out in this Agreement:

7.1.1. Be responsible for payment to DWP for the Services in accordance with Paragraph 15 (Financial Arrangements).

7.1.2. Inform DWP as soon as reasonably practicable if they become aware of any deficiency in the quality of the Service delivered under this Agreement and seek to agree steps to resolve such issues.

7.1.3. Work in partnership with DWP in respect of any potential changes to the delivery of Adult Disability Payment as these may impact on the Services.

7.1.4. Be responsible for the effective identification and management of risks arising from the delivery of the Services.

7.2. For the avoidance of doubt, each Party acknowledges that Scottish Ministers shall at all times retain responsibility for Adult Disability Payment and its delivery.

7.3. DWP will, as set out in this Agreement:

7.3.1. Deliver the Services in accordance with the terms of this Agreement.

7.3.2. Work in partnership with Scottish Ministers in respect of any potential impacts and changes that may affect or require changes to the Services.

7.3.3. Inform Scottish Ministers as soon as reasonably practicable if they become aware of any deficiency in the quality of the Services delivered under this Agreement and take steps to resolve such issues.

7.3.4. Be responsible for the effective identification and management of risks arising from the delivery of the Services.

8. Servive Delivery Standards

8.1. The Services will be delivered in accordance with the Service Delivery Standards set out below.

8.1.1. Where a customer moves address to Scotland from England or Wales on or after 6 November 2025, DWP will end their claim, taking into account the 13 week run-on period, and signpost them to Social Security Scotland to make a new application for Adult Disability Payment.

8.1.2. Where Scottish Ministers receive a new application which is identified as a Special Rules Terminally Ill (SRTI) case on or after 6 November 2025, and the client previously lived in England/Wales and claimed Personal Independence Payment, both Parties will exchange information via email.

SPoCs for each Party are as follows:

SPOC SPOC
[Redacted] [Redacted]

8.1.3. Where a client has been awarded Adult Disability Payment and moves to England or Wales, on or after 6 November 2025, Scottish Ministers and DWP will follow the process to provide each other with the relevant information, as detailed in Annex 1.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inboxes
[Redacted] [Redacted]

8.1.4. Where a Linking Award has been identified, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annex 2 to 2(b).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.5. When a Scottish resident in receipt of Adult Disability Payment moves to England/Wales, and has an existing AVE/Motability agreement, Scottish Ministers will provide DWP with all relevant information.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.6. Where Industrial Injuries Disablement Benefit and Constant Attendance Allowance (IIDB CAA) cases are identified, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annex 3 and 3(a).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.7. Where Scottish Ministers identify an issue with a Global Unique Identifier (GUID), Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annex 4.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.8. Where a client resident in Scotland and is under state pension age incorrectly sends an Attendance Allowance claim to DWP, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annex 5.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.9. Where DWP require Scottish Ministers to confirm an Attendance Allowance interest/award, Scottish Ministers and DWP will follow the process to provide each other with relevant information as detailed in Annex 6.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.10. Where a Personal Independence Payment customer is residing abroad and Genuine Sufficient Link (GSL) to Scotland is a consideration, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annex 7.

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.11. Where Social Security Scotland identifies Armed Forces Independence Payment (AFIP) cases, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annexes 8 and 8(a).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.12. Where Electronic Exchange of Social Security Information (EESSI) cases are identified, Scottish Ministers and DWP will follow the process to provide each other with relevant information, as detailed in Annexes 9 to 9(b).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.13. Scottish Ministers and DWP will confirm with the other Party the control measures associated with Keeping Customer Interactions Safe (KCIS)/Unacceptable Actions (UA) cases, as detailed in Annexes 10 and 10(a).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.14. Where a new appointee or a change to appointee is identified, Scottish Ministers and DWP will follow the processes to provide each other with relevant information, as detailed in Annexes 11 to 11(c).

SPoCs for each Party are as follows:

Social Security Scotland Inbox DWP Inbox
[Redacted] [Redacted]

8.1.15. Details of the specific data being shared can be found in the associated Data Sharing Agreement.

8.1.16\ The turnaround time for responding to dedicated email enquiries relating to the processes, as detailed in Annexes 1 to 7, will be as soon as reasonably practicable and within 5 working days. For any enquiries, which are complex and are off system the turnaround time will be 10 working days.

8.1.17. The turnaround time for responding to dedicated email enquiries relating to SRTI cases will be 1 working day. For any enquiries, which are complex and are off system the turnaround time will be 10 working days.

8.1.18. The turnaround time for responding to dedicated email enquiries relating to Armed Forces Independence Payment cases will be 2 working days, as detailed in Annexes 8 and 8(a). For any enquiries, which are complex and are off system the turnaround time will be 10 working days.

8.1.19. The turnaround time for responding to dedicated email enquiries relating to EESSI, will be as soon as reasonably practicable and within 15 working days as detailed in Annexes 9 to 9(b).

8.1.20. The turnaround time for responding to dedicated email enquiries relating to Keeping Customer Interactions Safe (KCIS)/ Unacceptable Actions (UA) Control Measures will be 2 working days, as detailed in Annexes 10 and 10(a).

8.1.21. The turnaround time for responding to dedicated email enquiries relating to appointees will be as soon as reasonably practicable and within 5 working days, as detailed in Annexes 11 to 11(c).

8.1.22. The turnaround time for responding to dedicated email enquires relating to known system issues are:

Priority Timescale Scenarios
High Within 24hrs Preventing payment to a client, SRTI, Scottish Ministers or Parliamentary enquiry
Medium Within 72 hrs Case queries which don’t prevent payment but have a negative impact on client journey
Low Within 5 days General Process issues

8.1.23. The agent-to-agent email service will be available from 8.00 am to 5.00 pm Monday to Friday excluding public and privilege holidays.

8.1.24. Scottish Ministers will provide updates to, and retrieve data from, a number of DWP data services which will enable Scottish Ministers to assess eligibility for Adult Disability Payment. Further details are set out in the associated Data Sharing Agreement.

8.2. Escalation will be between SPoCs at team management level, between Social Security Scotland and DWP operational teams in appropriate cases including, but not limited to:

8.2.1. Where Service Delivery Standards have not been met.

8.2.2. Where there are cases when the normal Service Delivery Standards would have an unacceptable impact on the client.

8.2.3. Details of the specific data being shared can be found in the associated Data Sharing Agreements.

SPoCs for each Party are as follows:

SG Escalation SPoC DWP Escalation SPoC
[Redacted] [Redacted]

9. Fraud

9.1. Processes to allow DWP Counter Fraud & Compliance Directorate and Social Security Scotland Agency Fraud & Error Resolution Unit to collaborate and co-operate in sharing relevant and proportionate data to assist in the prevention, detection and prosecution of benefit fraud have been developed and are routinely reviewed by DWP and Social Security Scotland.

9.2. Each party should refer to their operational guidance for current processes and each process is contained within the associated Data Sharing Agreement. Method of Data transfer through email to the inboxes detailed below:

DWP transfer to Social Security Scotland – [Redacted]

Social Security Scotland transfer to DWP – [Redacted]

10. Management review

10.1. Each Party will act transparently and work in a practical way in the spirit of co-operation, trust, respect and confidentiality in regards to any issues that may arise. In general, the working arrangements covered by this Agreement should be reviewed at least every twelve (12) months during the period this Agreement is in place. This may involve meetings between each Party at a working level.

11. Evaluation

11.1. Each Party agrees that no personal data will be shared for the purposes of evaluation.

11.2. Scottish Ministers will be wholly responsible for the evaluation of Adult Disability Payment. Each Party will work together to ensure the agreed service standards are delivered.

12. Complaints

12.1. Each Party will follow their defined Business as Usual (BAU) Customer/Client complaints procedures.

13. Service Design and Delivery

13.1. It is understood by each Party that the design of the Services will evolve. Each Party agrees to inform the other as soon as reasonably practicable of any changes with its own legislation relating to Personal Independence Payment or Adult Disability Payment that may impact or require changes to the delivery of Adult Disability Payment or the Services.

13.2. Scottish Ministers will deliver Adult Disability Payment while seeking continuous improvement in delivery as part of BAU processes. Each Party will work to ensure cost-effective delivery; subject to the overarching financial arrangements as described in the ‘Scottish Devolution: Financial Arrangements for Formal Agreements’ as referenced in Section 4 (Derivation) of this Agreement.

14. Communications

14.1. Communications in relation to Adult Disability Payment will be as in the agreed document ‘DWP and SG Joint Communications Framework’ as referenced in Section 4 (Derivation) of this Agreement.

15. Financial arrangements

15.1. DWP will recharge Scottish Ministers agreed costs associated with the delivery of the Services. The agreed financial arrangements and the costs are contained in the ‘Scottish Devolution: Financial Arrangements for Formal Agreements’ as referenced in Section 4 (Derivation) of this Agreement.

16. Audit arrangements

16.1. DWP and Scottish Ministers will abide by the principles of audit and accountability as set out in the document ‘Scottish Devolution: A Framework for Audit and Accountability’ as referenced in Section 4 (Derivation) of this Agreement.

16.2. DWP and Scottish Ministers remain subject to their overall existing accountabilities to, respectively, the UK and Scottish Parliaments, and their associated audit bodies.

16.3. DWP and Scottish Ministers will abide by the principles in ‘The Agreement between the Scottish Government and the United Kingdom Government on the Scottish Government’s fiscal framework’ as referenced in Section 4 (Derivation) of this Agreement: Paragraph 29 which states that ‘All costs incurred by the UK Government where the Scottish Government is expected to meet the cost will be subject to audit.’

16.4. Social Security Scotland, National Audit Office and Audit Scotland; Special Purpose Audit Framework will be used going forward as set out in the ‘Financial Arrangements for Formal Agreements’ document, as referenced in Section 4 (Derivation) of this Agreement.

17. Data processing

17.1. Further details of the data controller, and roles and responsibilities of Scottish Ministers and DWP in relation to the sharing of personal data, are set out in the associated Data Sharing Agreement.

18. Freedom of Information requests, Parliamentary Questions, Ministerial Correspondence and ‘Treat Official’ Correspondence

18.1. Each Party is to follow existing processes and obligations for requests to that Party and having regard to the ‘MoU on Devolution’ as well as the ‘Concordat between the Department for Work and Pensions and the Scottish Government’ as referenced in Section 4 (Derivation) of this Agreement.

18.2. Each Party will assist and cooperate with each other where appropriate to enable each to meet its obligations.

18.3. This Agreement does not supersede any legal obligations under the Freedom of Information Act 2000 (FoIA) and the Freedom of Information (Scotland) Act 2002 (FoI(S)A).

SG FOI(S)A contact DWP FOI Contact
FoI@socialsecurity.gov.scot Freedom-of-informationrequest@dwp.gov.uk

19. Data subject requests

19.1. When either Party receives a right of access request from a data subject requesting copies of data shared by the other Party, they will for any relevant information they hold as an independent data controller and in line with Article 15 of the UK GDPR and ICO’s UK GDPR guidance on the right of access:

  • confirm that they are processing any such personal data
  • provide a copy of the personal data held; and provide other supplementary information as appropriate.

19.2. In addition, if it appears the data subject is requesting information held by the other Party, they will also, at the same time, return the request to the sender with details of the correct address (of the other Party) as soon as reasonably practicable and within regulatory deadlines. The request itself must not be forwarded.

19.3. Details on how to make an access request to DWP can be found in the DWP Information Charter – The DWP Personal Information Charter can be found at this link - DWP Personal Information Charter.

19.4. Details on how to make an access request to Scottish Ministers can be found in the Social Security Scotland Privacy Notice. The Social Security Scotland Privacy Notice can be found at this link Social Security Scotland Privacy Notice

19.5. Details of the specific data being shared can be found in the Associated Data Sharing Agreement.

Address details for each Party are as follows:

Social Security Scotland Data Protection Team
Data Protection Officer
PO Box 10298
Dundee
DD1 9FS
dataprotectionofficer@socialsecurity.gov.scot

DWP Right of Access Request
Right of Access Gateway Team
Post Handling Site A
Wolverhampton
WV98 2EF
[Redacted]

20. Business continuity

20.1. If DWP or Social Security Scotland business continuity plans are invoked which affect the Services, the Party invoking their business continuity plan will advise the other Party of the issue, impact and resulting action as soon as reasonably practicable. Individual continuity plans are in place in DWP and Social Security Scotland and communication points of contact are in place in respective business continuity teams.

21. Technical capabilities

21.1. Each Party will, as soon as reasonably practicable, inform the other Party of any proposed changes to its IT environment that would impact on the delivery of Adult Disability Payment. Each Party will thereafter co-operate with the other to minimise the impact that such changes may have on delivery of Adult Disability Payment. [Redacted]

22. Signatories

Signed:

Print Name: Ally MacPhail

Date: 06/10/2025

A duly authorised officer for and on behalf of the Scottish Ministers

Signed:

Print Name: Helga Swidenbank

Date:

A duly authorised officer for and on behalf of the Secretary of State for the Department for Work and Pensions

Signed:

Print Name: Margarita Morrison

Date:

A duly authorised officer for and on behalf of the Secretary of State for the Department for Work and Pensions

Signed:

Print Name: Martin Brown

Date:

A duly authorised officer for and on behalf of the Secretary of State for the Department for Work and Pensions

Signed:

Print Name: Vikki Knight

Date:

A duly authorised officer for and on behalf of the Secretary of State for the Department for Work and Pensions

Annex 1 - Adult Disability Payment Client moves out of Scotland [Redacted]

Annex 2 - Adult Disability Payment Linking Award Process [Redacted]

Annex 2(a) - Adult Disability Payment Linking Award Process [Redacted]

Annex 2(b) - DWP Request for New PIP Claim Linking Information [Redacted]

Annex 3 - Industrial Injuries Disablement Benefit Constant Attendance Allowance [Redacted]

Annex 3(a) - Industrial Injuries Disablement Benefit Constant Attendance Allowance [Redacted]

Annex 4 - GUID No Match Process [Redacted]

Annex 5 - Adult Disability Payment Claim in the Alternative [Redacted]

Annex 6 - Confirmation SG have noted Attendance Allowance interest/award [Redacted]

Annex 7 - PIP Claimant Living Abroad requests transfer to Adult Disability Payment [Redacted]

Annex 8 - Armed Forces Independence Payment [Redacted]

Annex 8(a) - Armed Forces Independence Payment [Redacted]

Annex 9 - EESSI - Send Non Competency Notice [Redacted]

Annex 9(a) - EESSI - Request for Information [Redacted]

Annex 9(b) - EESSI - Receive Non Competency Notice [Redacted]

Annex 10 - KCIS/UA [Redacted]

Annex 10(a) - KICS/UA [Redacted]

Annex 11 - Process for a new Appointee [Redacted]

Annex 11(a) - Process for a new Appointee [Redacted]

Annex 11(b) - Notification of a change of Appointee [Redacted]

Annex 11(c) - Notification of a change of Appointee [Redacted]

Annex 12 - Glossary of Terms

The Glossary defines various words, abbreviations and phrases which have specific meanings in the context of this Agreement. Unless otherwise provided or the context otherwise requires, the following expressions have the meanings set out below.

Abbreviation Meaning
AA Attendance Allowance
ADP Adult Disability Payment
BAU Business as Usual
Commencement Date of Adult Disability Payment The date in 2022 on which delivery of Adult Disability Payment Services commenced
DWP Department for Work and Pensions
EESSI Electronic Exchange of Social Security Information
FoI(A) Freedom of Information Act 2000
FoI(S)A Freedom of Information (Scotland) Act 2002
GSL Genuine Sufficient Link
GUID Global Unique Identifier
KCIS Keeping Customer Interactions Safe
Linking Awards Linking Awards is where entitlement to the new claim is based on previous awards to qualifying benefit
MoU Memorandum of Understanding
PIP Personal Independence Payment
Public and Privilege holidays All public and privilege dates in England and Scotland including regional specific dates in Social Security Scotland Agency
Resident in Scotland Ordinarily resident in Scotland or either in the EEA or Switzerland with a genuine and sufficient link to Scotland
Service Delivery Standards The service delivery standards to be met by DWP for the delivery of the Services as set out at Para 8
Services Has the meaning set out in Para 2
SG Scottish Government
SLA Service Level Agreement
SM Scottish Ministers
SM/SSWP Single MoU Memorandum of Understanding between Scottish Ministers and the Secretary of State for Work and Pensions dated January 2023 as amended
SPoC Single Point of Contact
SREL Special Rules for End of Life
SRTI Special Rules Terminally Ill
SSWP Secretary of State for Work and Pensions
Term Has the meaning set out in Para 3
UA Unacceptable Actions
UK GDPR UK General Data Protection Regulations