169. Between 1995 and 2004, accurate information about changes to State Pension age was publicly available in leaflets, through DWP’s pensions education campaigns, through DWP’s agencies and on its website. What DWP did reflects expectations set out in the Civil Service Code, the DWP Policy Statement, the Pension Service’s Customer Charter and the Benefits Agency Customer Charter.
170. However, DWP’s decision making following the 2003/2004 research failed to give due weight to relevant considerations, including what research showed about the need for ‘appropriately targeted’ information, what was known about the need for individually tailored information, or how likely it was doing the same thing would achieve different results. Despite having identified more it could do, DWP failed to provide the public with as full information as possible. DWP failed to make a reasonable decision about next steps in August 2005. It did not ‘get it right’. And its failure to use feedback to improve service delivery meant it did not ‘seek continuous improvement’. That was maladministration.
171. DWP then failed to act promptly on its 2006 proposal to write directly to affected women, or to give due weight to how much time had already been lost since the 1995 Pensions Act. It did not ‘get it right’ because it did not meet the requirements of the Civil Service Code, and it did not take all relevant considerations into account. And it failed again to use feedback to improve service delivery and ‘seek continuous improvement’. That was also maladministration.
172. The maladministration led to a delay in DWP writing directly to women about changes in State Pension age. If the maladministration had not happened, DWP would have begun writing to affected women by December 2006 at the latest, 28 months earlier than it did (in April 2009). We say this bearing in mind that it took DWP 16 months to issue letters from when it decided to send them using CIS in December 2007, and it is possible using a different database could have enabled letters to be issued sooner than December 2006.
173. It follows that affected women should have had at least 28 months’ more individual notice of the changes. For women who were not aware of the changes, the opportunity that additional notice would have given them to adjust their retirement plans was lost. The next stage of our investigation will consider the impact that injustice had.