Public Authorities (Fraud, Error and Recovery) Bill

Lord Palmer of Childs Hill Excerpts

Report stage
Tuesday 21st October 2025 Lords Chamber

These two amendments, which have already been well explained by the noble Baroness, Lady Finn, simply define who may use the powers, particularly ensuring that serious use of them requires explicit ministerial authorisation and that the use of the powers is robustly recorded and reported upon. At the very least, those safeguards should be in place. I am happy to support the amendments wholeheartedly and I very much hope the noble Baroness will seek the approval of the House for them.

[Lord Palmer of Childs Hill (LD)]

My Lords, the amendments, as has been clearly stated by the noble Baroness, Lady Finn, and the noble Lord, Lord Vaux, concern ministerial and parliamentary oversight—it is the oversight that is important—or the powers granted to authorised officers for reclaiming finances under this Act.

As has been stated by other noble Lords, these amendments would require that a Minister of the Crown authorise the use of such powers where the amount involved exceeded £10,000. This would also oblige the Public Sector Fraud Authority to maintain a register of instances in which the powers were exercised, with a relevant Minister required to lay a copy of that register before Parliament.

On these Benches, we have been critical throughout the passage of the Bill of the broad powers—and in some cases inadequately checked powers, as described by the noble Lord, Lord Vaux—granted to recover funds identified as perhaps fraudulent. We therefore support these amendments, as they would introduce additional senior authorisation for cases involving substantial sums and provide a necessary level of parliamentary oversight. If the noble Baroness pushes her amendment to a vote, we will support her.

[Baroness in Waiting/Government Whip (Baroness Anderson of Stoke-on-Trent) (Lab)]

My Lords, while I appreciate the intention behind these amendments, the reality of their drafting would give Ministers the ability to block politically inconvenient investigations. They would prevent counterfraud enforcement at any kind of scale, and they would expose the identities of civil servants investigating serious criminals. On that basis, we cannot accept them.

Although we cannot agree to the amendments, it might surprise the noble Baroness that I believe there is a lot that we agree on. We agree that the measures in the Bill are powerful and must be used with care; we agree that staff must be appropriately trained before they are able to use these powers; and we agree that robust oversight, both internal and external, is essential.

With regard to ministerial oversight, for as long as the powers sit in the Cabinet Office, they will be exercised in the name of the Minister for the Cabinet Office. However, the amendments go beyond accountability; they bring the Minister into specific operational decisions. It is not appropriate to mandate that the Minister for the Cabinet Office be brought into hundreds of operational decisions in the way that the amendments suggest.

First, Ministers must be free to delegate, or the work of government will grind to a halt. Your Lordships’ House would be rightly concerned if Cabinet Office Ministers, who need to make government more effective and efficient, were spending their days taking detailed counterfraud operational decisions.

Secondly, it would be inappropriate for Ministers—of whichever party happens to be in power—to take operational decisions on individual enforcement cases. That would make enforcement political. It would necessarily expose every case to charges of political interference; it would place honest Ministers in an invidious position; and it would give dishonest Ministers the power to block investigations that were politically inconvenient.

However, the noble Baroness is right that Ministers should know what is happening in their name. Ministers are accountable and must therefore choose how these powers should be delegated, not simply hand them over to civil servants and forget about them until a crisis occurs, which I know is a genuine concern. In response to the noble Baroness’s challenge, let me set out what Ministers will do before any of the powers are used.

Ministers will scrutinise the set-up of the PSFA, its plans to use the powers, the oversight arrangements in place, and the skills and experience of authorised officers and authorised investigators. They will also decide what thresholds they wish to set and what constraints they wish to place around the exercise of powers in their name. Ministers will decide what reports they want to receive and their frequency. They will also decide how they wish to appoint authorised officers and authorised investigators, and will take a strong interest in the training, experience and professionalism of those staff. Finally, Ministers will be accountable to your Lordships’ House and the other place to show that they have done that. I am happy to commit to Ministers bringing forward a statement before the powers are first used to demonstrate that these commitments have been fulfilled. Every time there is a change of Ministers, officials will ask for the new Minister’s view on these questions, and not silently continue out of sight, which I know is a genuine concern of the noble Baroness. She is absolutely right to draw attention to how delegation works in government; it is for Ministers who are accountable to decide on the appropriate delegation.

I turn to the seniority of civil servants provided for in proposed new subsection (1B) in Amendment 28. By requiring senior civil servant sign-off for every use of the powers in Part 1, the noble Baroness seeks to set the bar for internal authorisation too high. Currently, the PSFA’s enforcement unit is relatively small—I love using the word “relatively”; it is not large—so the number of information notices envisaged in a year, for example, could all be reviewed by a senior civil servant. However, we are making this legislation to last decades, and its operation cannot be contingent on keeping our capacity to pursue public sector fraudsters small. At any scale, requiring excessive civil servant grading in legislation is a strict operational limitation and unnecessarily expensive.

That is why those who use these powers successfully elsewhere in government, such as HMRC, do not have these requirements in either their legislation or their practice. It is not the grade that matters; it is skills, experience and professionalism. Authorised investigators and authorised officers in the PSFA will all be members of the Government Counter Fraud Profession. They will undergo bespoke training, on top of the previous knowledge, skills and experience they bring to the role. Current members of the PSFA’s enforcement unit bring a wealth of experience with them. They include former police officers, customs officers and other civil servants who have worked in investigatory roles across a number of departments.

Noble Lords have been clear in this debate that they are particularly concerned about the use of PACE powers. Let me remind your Lordships’ House that it is the courts that will authorise any application that the PSFA makes under PACE. No civil servant—of any grade—nor any Minister can authorise a search warrant or a production order under PACE. Only the courts can authorise such actions, each and every time we seek to use them.

That means that the PSFA must be able to demonstrate, to the court’s satisfaction, that there are reasonable grounds to believe that an offence of fraud has been committed against a public authority and, as set out in PACE, reasonable grounds to believe that the material sought is likely to be of substantial value to the investigation—I repeat: it must be of substantial value. This means that the subject of an application has the protection of a court’s scrutiny before authorised investigators can execute a warrant or production order.

Moreover, the powers in the Bill are subject to review by an independent person, as specified under Clause 65. I have committed to ensure that the independent person will be passed all the concerns raised by parliamentarians, including those we have heard today. The PSFA will be subject to inspections by His Majesty’s Inspectorate of Constabulary and Fire & Rescue Services. Inspection reports will be made publicly available and will be laid before Parliament.

Finally, I turn to the question of maintaining a register that has to be laid before Parliament. We will of course keep meticulous records of how and when powers are used; that would be a bare minimum for good investigatory practice. Those records will be made available to the independent reviewer, who will report on the use of the powers to Parliament, ensuring democratic oversight. However, laying this register before Parliament carries significant risks; it may compromise ongoing cases and expose the identities of investigators to dangerous individuals, jeopardising their safety and the integrity of the justice system. We must remember that we are talking about people who undertake criminal activity—online in some cases—so publishing the names of the investigating officers could make them vulnerable.

On the points raised by the noble Baroness, Lady Finn, and the appalling Horizon scandal, I want to take this opportunity to reassure and remind noble Lords that the scandal was based on private prosecutions that the PSFA will not undertake.

I understand the noble Baroness’s concerns and have set out how Ministers will act in an effort to assuage them, but the amendment cannot stand. It would allow dishonest Ministers to block politically inconvenient investigations, it would make counter-fraud enforcement at any scale impossible, and it would expose the names of officials to the fraudsters they are investigating. I urge the noble Baroness to withdraw her amendment.

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[The Minister of State, Department for Work and Pensions (Baroness Sherlock) (Lab)]

My Lords, in moving government Amendment 41, I will speak also to government Amendments 42, 43, 64, 80, 90 and 111.

Under current devolution arrangements, DWP administers certain devolved benefits on behalf of the Scottish Government through agency agreements. These amendments will ensure that the expanded information gathering powers introduced in this Bill will be available to Scottish Ministers, should they require them in the future. This follows confirmation from the Scottish Government that they would like the updates to these powers to apply to them too.

These amendments will ensure necessary changes are made to the DWP debt recovery powers in the Bill. As drafted in Clause 91, the UK Government are seeking powers to apply new recovery methods to debts of certain devolved benefits delivered under agency agreements. However, the Scottish Government have confirmed that they do not wish these new recovery methods to be applied to devolved benefits administered by DWP through agency arrangements.

Taking the amendments in turn, government Amendment 41 simplifies Clause 73, reflecting how it was originally introduced, with new Section 109BZA now containing the expanded power to issue information notices to any information holder as part of a DWP criminal fraud investigation and ensuring that Scottish Ministers will have access to these equivalent expanded powers in the event that Scottish Ministers deliver any benefits covered by the 1992 Act.

Government Amendments 42 and 43, made to Clause 74, update the Social Security Fraud Act 2001, aligning it with the new powers and ensuring that the requirement to issue a code of practice and the ability to make payments for information also apply properly to Scottish Ministers.

Government Amendment 90 to Clause 91 reflects the position of the Scottish Government on the DWP debt recovery powers. It ensures that the Scottish Government retain control over how debts relating to their devolved benefits are recovered. Once these agency agreements come to an end, it will be for the Scottish Government to determine their own approach to debt recovery, including establishing new powers if necessary.

Finally, government Amendment 111 to Clause 101 confirms that Clauses 73 and 74 are treated as pre-commencement enactments for the purposes of the Scotland Act 1998, enabling Scottish Ministers to use these updated powers for fraud investigations in relation to devolved benefits. It confirms that the provisions in Clauses 96 and 97 relating to cost recovery and data protection apply to Scottish Ministers’ existing debt recovery powers. Amendments 80 and 64 update the clause references in Clause 85 and Schedule 3 as a consequence of these changes.

Having outlined the case for these amendments, I hope noble Lords will accept them so that we can fulfil our agreements with the Scottish Government. I beg to move.

[Lord Palmer of Childs Hill (LD)]

My Lords, on these Benches, we welcome the agreement reached with the devolved Administrations—may this be a lesson to people around the world on how to deal with them, at least in this case.

The amendments in this group relate to how the powers in the Bill refer to Scotland specifically. Amendment 41, together with related amendments to Clause 74, and the replacement of Clause 101 and others, reverses—I stress that—the changes made in the House of Commons. I gather that this follows confirmation from Scottish Ministers that they wish the changes to the Secretary of State’s functions regarding information notices to apply to them as well. This seems to me a positive movement of Administrations working together—long may it continue.

[Viscount Younger of Leckie (Con)]

My Lords, as it is my first appearance at the opposition Dispatch Box on Report, I echo remarks made by my noble friend Lady Finn on the first day of Report, because I also appreciate the constructive approach that the Government have taken following Committee.

It is perhaps appropriate that, as a Scot, my first brief contribution relates to matters north of the border. It is our understanding that this amendment has been brought forward by the Government in order to apply to Scotland those provisions of the Bill which we have already debated in earlier clauses, in particular those concerning the new powers to issue information notices under the Social Security Administration Act 1992, and to clarify that the new methods of recovery introduced under the Bill will not apply to devolved benefits.

In that sense, these amendments are essentially technical in nature, as the Minister said, ensuring consistency across the United Kingdom and confirming that the devolved benefits system in Scotland remains outside the scope of the new recovery powers. We appreciate and support the clarification. However, while the amendments themselves are straightforward, they raise some wider questions about the relationship between the UK and the devolved Administrations in this area.

It is somewhat surprising that these changes have had to come forward as government amendments at this relatively late stage of the Bill, when one might have expected such matters to have been settled at the drafting stage through earlier consultation and agreement with Scottish Ministers. The Government have placed great store over the past year in stating that they seek to improve communications and trust between the UK Government and the devolved nations, so can the Minister give us an update on how they view progress on these changes and what has changed in the past year?

While we do not oppose these amendments—indeed, we welcome the fact that the necessary legislative consent has now been secured—they prompt reflection on the importance of ensuring that such engagement happens promptly and systematically in future. The relationship between the UK and the devolved Governments works best when issues of competence and application are identified and agreed well in advance, rather than being corrected through amendments on Report.

That said, I would be grateful if the Minister could take this opportunity to update the House on the Government’s current assessment of the risk of fraud in relation to devolved benefits and on what engagement has taken place with the devolved Administrations to address that risk. Can she tell us what steps she is aware of in those authorities to tackle fraud within their systems and how information sharing and co-ordination between the UK Government and the devolved Governments is being managed to ensure that fraud risks are tackled effectively across all jurisdictions?

We are content to support these amendments that bring Scotland into line with the rest of the UK where appropriate while respecting the devolution settlement and maintaining clarity over responsibilities in the fight against fraud.

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[Lord Sikka (Lab)]

My Lords, I will say a few words about Amendment 60. I thank the noble Baroness, Lady Bennett of Manor Castle, for her support.

My concern is about justice. People on the receiving end of DWP penalties and accusations of fraud will predominantly be old, sick, disabled and the poor. Most would not be able to afford legal advice or qualify for legal aid, which is scarce in any case. DWP actions and penalties could arise because people have made errors in completing very long and complex forms. For example, the pension credit form is 24 pages long and has 243 questions on it. Errors can be made in completing the forms and interpreting the questions on them, and in the DWP’s assessment of the answers given to those questions.

There is a high probability that some people may eventually be unjustly accused of committing fraud and face the removal of money from their bank accounts without their express approval. It will be the might of the state on one hand and a poor person who does not have any legal advice on the other. We know from the Post Office scandal that innocent individuals can be pressurised into admitting fraud that they did not commit and into handing over money that they did not steal or do not owe. There is enormous scope for injustice in the Bill.

The 2023 High Court case of R v Secretary of State for Work and Pensions related to a single mother of two disabled adults who was receiving universal credit and was overpaid by £8,623, entirely due to the fault of the DWP. The DWP sought to recover the money. The High Court’s judgment said that, under certain circumstances, benefit claimants may be able to argue that recovering the debt would be an unlawful breach of their legitimate expectation and the debt need not actually be paid. Would many claimants who are accused of committing fraud or receiving overpayments be aware of these things?

Steve Webb, the former Pensions Minister, said:

“It can be difficult for people to understand whether the demands they are being sent for overpayments are a mistake, as benefits such as tax credits and pension credit are so complex”.


Without legal advice, these people become even more vulnerable.

Last year, a lot of press coverage was given to the plight of a 75 year-old pensioner who was chased by the DWP for pension credit fraud, adding up to £22,000. The Sun newspaper took up the case, and eventually the investigation showed that there was no fraud—it was all due to errors by the DWP. This case, obviously, is not unique; there are many others that do not get the publicity. I cannot help wondering how many people over the years have been pressurised into admitting guilt when they are not guilty. How many more will admit guilt when they are simply pressed into it?

Last year, data secured by Big Brother Watch showed that more than 200,000 people wrongly faced investigation for housing benefit fraud and error after the performance of the Government’s algorithm fell far short of expectations. Earlier this year, 30 charities wrote to the Government, pointing out the dangers of this legislation and previous legislation, and they identified 686,756 new official error overpayments on universal credit.

Eventually, at some point, people who are accused need some advice. Amendment 60 suggests that the Government ought to provide legal advice to people who may well qualify for it. On 9 October this year, the Government announced that all victims of the Post Office Horizon IT scandal who are claiming compensation will be entitled to free legal advice. Why wait until people suffer? Why not offer this advice up front to save anguish to millions of people? That is what a civilised society would do.

I am sure the Minister will not support this and will possibly refer to the cost associated with it, but the cost of injustice is even higher. I hope that the Minister will be able to offer some help with this.

[Lord Palmer of Childs Hill (LD)]

My Lords, I take this opportunity to refer to the title of this Bill, which is not just “Fraud” but “Fraud, Error and Recovery”. What we are really dealing with is unintentional error. If you are at the bottom of the food chain, worrying how to pay for your food and all the other necessities of life, and you receive some money, you do not look too carefully at that in the real world; you are just grateful for all that you can receive. It then transpires that there has been an error, not really a fraud, and that is part of the title of this Bill. What the noble Lords, Lord Vaux and Lord Sikka, and my noble friend Lady Kramer have tried to explain is that these are errors, not frauds. These amendments reflect ongoing concerns that the Bill grants excessive powers that could intrude upon individuals’ financial privacy and be applied punitively to those receiving universal credit who are at the bottom of the food chain.

The amendment in the name of the noble Lord, Lord Vaux, would align the safeguards that apply for the use of eligibility verification powers with those in other parts of the Bill, ensuring continuity in this legislation. My noble friend Lady Kramer’s amendments would remove the requirement for banks to examine the bank accounts of relevant claimants. I do not think we expect a Division on this, but I hope the Government will take account of the nervousness that many of us feel about excessive powers that could affect the people least able to defend themselves.

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[Lord Palmer of Childs Hill (LD)]

My Lords, I thank the noble Lord, Lord Deben, very much for that. The point I would like to make is that there are people who will perpetuate fraud but, if you try to close up every single channel, you will catch people who are innocent. I believe that all laws should allow for people to get away with fraud, perhaps, if it means that you are not accusing people unintentionally. These amendments are appropriate because, as has been said, who knows what Government will come along and what people will be in charge? If there is fraud, it has to be proved pretty conclusively, rather than, because we suspect fraud, us making it impossible for people who would otherwise be found innocent. We found that with the Horizon scandal: it looked all right but AI said that they were all guilty, though they were not guilty. When even speeches made in this House probably come from AI, we have to be increasingly careful about what we do. These amendments protect people; if they are pressed, we on these Benches will support them.

[Viscount Younger of Leckie (Con)]

My Lords, I speak in support of these amendments tabled by the noble Lord, Lord Vaux of Harrowden, and I am pleased to have added my name to them, because both amendments make valuable and necessary clarifications to the operation and oversight of the eligibility verification mechanism—EVM—and they do so in a way that strengthens, rather than weakens, the Government’s objectives under this Bill.

Amendment 52 makes a particularly important clarification. As the Government have repeatedly described their approach to the EVM as a test and learn process, it is vital that we make clear in the Bill that the mere existence of an eligibility indicator does not in itself constitute reasonable grounds for suspicion. That may sound like a technical point, but it has real-world implications. When a system is still developing, when its data sources are still being refined and when human understanding of how it operates is still evolving, there is a very real risk of false positives and unintended consequences.

The Government have said that there is some clarification within the process of an investigation that would help to clarify that persons subject to an EVM are not guilty, and that there are not, therefore, necessarily reasonable grounds for suspicion. However, putting this clarification in the Bill would be a really valuable step in making this absolutely clear, in black and white, to everyone involved. This amendment removes ambiguity and ensures that this point is not in question.

We have already discussed throughout this Bill the importance of safeguards and clarity when new investigative systems are created, particularly where multiple third parties are involved in data sharing and enforcement, which is paramount. This amendment provides exactly that and sets out this lack of reasonable suspicion in the Bill so that we avoid the potentially harmful ambiguity.

Moreover, this amendment ensures that, before any intrusive action is taken—in other words, before any benefit is amended, suspended or investigated—a person of appropriate seniority and experience must review the information and confirm that there are genuine reasonable grounds for suspicion. This aspect of the amendment places human oversight where it belongs: between the algorithm and the citizen. This matters all the more because, as many noble Lords will have seen, the Government themselves are moving rapidly to expand the use of AI in fraud detection and enforcement. Only a couple of weeks ago, civil servants across Whitehall received an internal update about the significant expansion of AI use within the Public Sector Fraud Authority in an article titled:

“Behind the Scenes: Building the AI Tool that is Revolutionising Fraud Prevention”.


I listened very carefully to the passionate speech from the noble Lord, Lord Deben, added to by the noble Lord, Lord Palmer. We believe that this makes these safeguards an urgent necessity. As we rightly modernise our defences against fraud, we must also modernise our protections against error, bias and overreach. Ensuring human involvement in that process in the way it has been set out in this Bill is fundamentally important, and this amendment provides that assurance.

Amendment 67 complements the first one by broadening the remit of the independent review of the EVM powers. The noble Lord, Lord Vaux, eloquently laid out his reasoning here. It makes sure that the reviewer looks at not just operational effectiveness but proportionality, costs, unintended consequences and how these powers affect vulnerable people and those interacting with the banking system. These are precisely the areas where well-intentioned powers can have unintended harm if they are not closely monitored.

We on these Benches raised these concerns in Committee and do so again on Report. There is the potential for disproportionate costs on financial institutions, the potential chilling effect on access to basic banking services for those already on the margins and, above all, the potential for harm to vulnerable people who find themselves caught up in complex enforcement processes. It is right that the independent reviewer should have these matters placed explicitly within their remit. I am therefore glad that the noble Lord, Lord Vaux, has framed his amendment to achieve exactly that. We need to recover public money which has been overpaid—we are in no doubt on that point—but doing so in a way that causes more harm than good benefits no one. The reviewer must have regard to this, not as a suggested area of review but as a statutory duty.

These are measured, practical amendments that I believe carry broad support across the House. They are not about blocking the Bill or frustrating its purpose: they are about ensuring that the new systems it creates are used wisely, fairly and proportionately. We therefore hope that the Government will listen and take these proposals seriously, recognise their constructive intent and accept them as a genuine improvement to the Bill. If the noble Lord, Lord Vaux, decides to test the opinion of the House, we on these Benches will be supporting him.

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[Lord Deben (Con)]

I would just like to ask the Minister three direct questions. First, why are people in England and Wales so much nastier that they need this force, whereas the Scots do not? That is not, it seems to me, a very sensible distinction. It should be either all of us or none of us.

Secondly—because I think it should be none of us —can the Minister explain why it is suitable for DWP officers to do something against individuals who are thought to be fraudulent, while officers of a similar kind do not have the power to do it if it is organised crime? Can she explain why that is?

My third question is extremely simple. Everybody who has ever had a ministerial job that involves this kind of thing knows, as the noble Lord, Lord Harper, said so clearly, that you absolutely need to be trained to do this. Can the Minister say who is trained, how much training they have and whether there is a budget for that training? If her answer is not satisfactory on any of those, I suggest she accepts the amendment which gets rid of this entirely.

Let us get to a sensible world in which the police have powers—for which, in most places, people trust them—and civil people do not have powers. We should remember the comment from the noble and right reverend Lord that was very simple: you know when a policeman is there, but how do you really know that this is a DWP individual? You have to look at some piece of paper, perhaps, but you do not know that. I think this is a very dangerous proposal.

[Lord Palmer of Childs Hill (LD)]

My Lords, I support this amendment because any exercise of physical powers must surely rest with the police. Are we going to train a new breed of DWP officers who have to be tough and able to act as police? It is quite nonsensical.

The one thing that worries me about this amendment is that it is quite easy on violent filing cabinets. You can attack a filing cabinet, apparently, because that is all right. I think this division between property and individuals is a very strange line to draw. Do you hide in a filing cabinet because you think that would be safer? No, you must not hide in a filing cabinet because, under this legislation, even under the amendment, you can attack a filing cabinet because it might hit back. I think the whole thing, when you read it carefully, is quite nonsensical. We have to get back to the crux of the amendment from the noble Lord, Lord Vaux, which is that if there is going to be physical restraint, it has to be from the police and from no one else.

[Viscount Younger of Leckie (Con)]

My Lords, I am very glad to have added my name to this series of amendments tabled by the noble Lord, Lord Vaux of Harrowden. They go to the heart of one of the most serious concerns that we have raised repeatedly with the Government, both inside this Chamber and beyond. I am very pleased that my noble friend Lord Harper spoke from his personal experiences where the state has found itself having to use force, and I will revert to that in a moment.

We are deeply concerned by the powers being granted to DWP investigators under this Bill, particularly the authorisation to use reasonable force against both property and people when exercising powers of entry, search or seizure under the Police and Criminal Evidence Act 1984—I believe that my noble friend Lord Harper referenced 2017, but I will need to check my facts on that. These are, in both name and substance, police powers. The idea that civil servants—officials who are not police officers—should be able, in law, to use physical force against members of the public is one that should give this House real pause. It raises profound questions about the limits of state power and the safeguards that ought to accompany it.

The Government have said that they cannot carve out these powers from PACE because it is separate Home Office legislation, but that simply does not stand up to scrutiny. We will hear later from the Minister, but they have already carved out the power of arrest for both the DWP and the Cabinet Office and they have explicitly carved out the use of reasonable force from the Cabinet Office’s own PACE powers under this Bill. It is, therefore, perfectly possible to do so; the Bill itself provides the precedent.

Given that, we struggle to understand why the Government are unwilling to make a simple, sensible and proportionate distinction that reasonable force may be used only against property and not against people. As it stands, the provision creates an unnecessary and troubling loophole, and one that we doubt will withstand the realities of operational use. On that basis, I had formed my own questions and, funnily enough, they chime with many of the points raised by my noble friend Lord Harper and the noble and right reverend Lord, Lord Sentamu, and, indeed, the noble Lord, Lord Deben, and the noble Baroness, Lady Fox, so there is support around the House.

Let us kick off. First, assuming that the DWP visits a property with a view to seizing property only and people there threaten violence or are violent but the police are not there, what are DWP officials expected to do there and then? Secondly, what training would DWP officials be given to deal with any potential violence? How far would this training go? This point was raised by the noble Lord, Lord Deben. Is it clear what is expected of them? What are the limits? What might be given to these officials for defence against physical force? Thirdly, what equipment would DWP officials be provided with to assist with restraining individuals if this arose in a scenario where only assets were being seized? Fourthly, and perhaps the biggest question of all, what happens if matters get out of hand, the police are not there, or they have been called but they are not there yet, and an individual is injured? The individual could be a DWP official or an individual within whose house the property is being seized. The police can be referred to the Independent Police Complaints Commission, but what redress or investigations are in place for DWP officials, given this scenario? I am referring to legal protections.