Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025

Introduction

1. The draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 (“the draft Order”) was laid before Parliament on 21 May 2025 by the Cabinet Office (“the Department”), together with an Explanatory Document and an Impact Assessment. The draft Order was laid under section 14 of the Legislative and Regulatory Reform Act 2006 (“the 2006 Act”). The draft Order extends and applies to England and Wales.

2. The purpose of the draft Order is to amend the Local Audit and Accountability Act 2014 and the Public Audit (Wales) Act 2004 to enable the matching and sharing of adult social care data across local authorities in England and Wales. This will enable the National Fraud Initiative (“NFI”), a team within the Cabinet Office’s Public Sector Fraud Authority, to use this data in its data matching activities to identify and prevent fraud and error in the adult social care system.

3. The Department’s Explanatory Document notes that adult social care data matching was previously undertaken by the NFI on behalf of local authorities, but ceased as a result of a 2016 amendment. The Cities and Local Government Devolution Act 2016 amended the NHS Act 2006 such that local authority social care data became aligned with “patient data”. This meant that the results of data matching using patient data could only be shared with “relevant NHS bodies”. The Department states that this consequence of the 2016 amendment was “wholly unintended”, and that the purpose of the draft Order is to address this “legislative anomaly”.¹

4. The Government has recommended that the draft Order be subject to the affirmative resolution procedure.² The House of Lords Delegated Powers and Regulatory Reform Committee concluded in its report of 13 June 2025 that the affirmative resolution procedure is appropriate for this draft Order.³

1 Description of the draft Order

5. The Local Audit and Accountability Act 2014 defines “data matching” as the comparison of sets of data to determine how far they match including the identification of patterns and trends.⁴ The National Fraud Initiative, known as the NFI, is a data matching exercise that has operated since 1996. The NFI assists public bodies and private sector organisations to prevent and detect fraud and error, and also help auditors to assess the arrangements that audited bodies have put in place to deal with fraud. In the NFI, participating bodies receive a report of matches which identify inconsistencies in the data held which may be indicative of fraud and which they should follow-up, and investigate where appropriate.⁵

6. Adult social care data matching was previously undertaken by the NFI on behalf of local authorities.⁶ However, the sharing of matched adult social care data to local authorities became prohibited as a result of paragraph 7 of Schedule 4 to the Cities and Local Government Devolution Act 2016. This Act inserted section 251(12A) into the NHS Act 2006 (control of patient information), amending the definition of “medical purposes” to include social care services. Data that is held for “medical purposes”, and from which the individual can be identified, meets the definition of “patient data” under the Local Audit and Accountability Act 2014, and is subject to restrictions on disclosure.⁷

7. According to the Department, this 2016 amendment had the “unintended consequence” that local authorities’ adult social care data became defined as “patient data” and, once matched, could therefore only be shared with “relevant NHS bodies”. This effectively prevented the results of matched adult social care data from being shared with local authorities, despite them being responsible for the delivery of adult social care as one of their core statutory functions.⁸ The Cabinet Office became aware of the effect of this amendment in 2020, and the NFI subsequently ceased adult social care data matching.⁹ In its report of 13 June 2025, the House of Lords Delegated Powers and Regulatory Reform Committee expressed regret that this consequence of the 2016 legislative amendment was not foreseen by the Government at the time, and the amount of time that has passed since the Cabinet Office became aware of the issue and subsequently laid this draft legislation to rectify it.¹⁰

8. The Welsh equivalent to the Local Audit and Accountability Act 2014 is the Public Audit (Wales) Act 2004. The Public Audit (Wales) Act 2004 also defines “patient data” by reference to section 251 of the NHS Act 2006, and thus was also affected by the unintended consequence of the 2016 amendment to the NHS Act 2006.¹¹

9. The purpose of the draft Order is therefore to reverse the “unintended consequence” of the 2016 amendment, by amending both the Local Audit and Accountability Act 2014 and the Public Audit (Wales) Act 2004 to exempt adult local authority social care data from the restriction on the disclosure of data matching results.¹² In setting out the policy background to the draft Order, the Department asserts that fraud is a significant issue for adult social care in local authorities, and that without the amendments made by this draft Order, “fraud and error loss will persist and is expected to increase in the adult social care sector”.¹³

10. The Department states that the amendment relates to a reserved matter, and that Senedd consent is therefore not strictly necessary to amend the relevant Welsh legislation. However, the Department believes that it would be desirable to receive Senedd consent for the Order, as it will amend primary legislation within the Senedd’s legislative competence.¹⁴ The Welsh Government Cabinet Secretary for Housing and Local Government, Jayne Bryant MS, laid a Statutory Instrument Consent Memorandum relating to the draft Order on 23 May 2025, stating her view that the Order is an appropriate means of delivering the intended outcome.¹⁵

11. For Scotland, the Public Finance and Accountability (Scotland) Act 2000 (PFASA) does not carry the same restrictions on the disclosure of local authority social care data. The PFASA’s definition of “medical purposes’’ at section 26B(5) does not expressly include local authority social care, and therefore local authority adult social care data does not meet the definition of “patient data” under section 26B(4). As a result, Audit Scotland, which leads the operation of the NFI in Scotland, has the legal ability to undertake adult social care data matching. However, at present, it does not do so because of the different legal status across England and Wales (in examples whereby individuals suspected of adult social care fraud may also have residency in England or Wales). The Department has indicated that data matching will resume in Scotland once England and Wales are on the same statutory footing.¹⁶ In Northern Ireland, the Audit and Accountability (Northern Ireland) Order has a provision for patient data to be disclosed to health and social care trusts, who have responsibility for social care.¹⁷

12. NFI issued a direct consultation to explore, and help inform, policy decisions on the usage of an Order to resume the sharing of adult social care data. The consultation was sent to all 207 local authorities across England, Wales and Scotland responsible for adult social care provision, as well as 19 relevant Government departments, public bodies and independent organisations with a remit in the management and security of public data, adult social care provision, local government administration and/or countering public sector fraud. The consultation was also sent to the Information Commissioner’s Office (ICO), in accordance with statutory requirements.¹⁸ The consultation was issued on 19 October 2023 and closed on 30 November 2023.¹⁹ The NFI received 137 responses to the consultation, which equates to an overall response rate of 61% (62% amongst local authorities, and 42% amongst the other organisations consulted). Several other organisations, such as the National Data Guardian for Health and Social Care (NDG), Audit Wales and the Local Government Association, also provided responses to the consultation.²⁰

13. According to the Department’s Explanatory Document, as an average across all the responses received, and across all questions posed to consultees, 90% of the responses were supportive of the legislative proposal. 1% of responses disagreed with the legislative proposal, with the remainder either giving a “neutral” or “other” response. The results of the consultation included the following findings:

• 90% of 129 authorities strongly agreed or agreed that they would benefit from receiving adult social data matching;
• 91% of 129 authorities strongly agreed or agreed that adult social care data matching would help them in understanding their overall fraud risks;
• 88% of all 137 respondents strongly agreed or agreed that the proposal was proportionate;
• 82% of all 137 respondents said that there was no other non-legislative alternative which would target this fraud better; and
• 80% of all 137 respondents strongly agreed or agreed that the proposal will maintain patient data protections, with 15% neither agreeing or disagreeing.²¹

2 Assessment of the draft Order

Role of the Business and Trade Committee

14. Under Standing Order No. 141, the Business and Trade Committee is charged with examining and reporting on draft Legislative Reform Orders laid before the House under the 2006 Act.²² The Committee’s function is to consider, in addition to such other matters as it deems appropriate, whether provision in a draft Legislative Reform Order meets a number of criteria. These tests are set out in Standing Order No. 141(3) as follows:

(3) In its consideration of draft orders under Part 1 of the Act the committee shall include in each case, in addition to such other matters as it deems appropriate, whether provision in the draft order—

(a) appears to make an inappropriate use of delegated legislation;

(b) serves the purpose of removing or reducing a burden, or the overall burdens, resulting directly or indirectly for any person from any legislation (in respect of a draft order under section 1 of the Act);

(c) serves the purpose of securing that regulatory functions are exercised so as to comply with the regulatory principles, as set out in section 2(3) of the Act (in respect of a draft order under section 2 of the Act);

(d) secures a policy objective which could not be satisfactorily secured by non-legislative means;

(e) has an effect which is proportionate to the policy objective;

(f) strikes a fair balance between the public interest and the interests of any person adversely affected by it;

(g) does not remove any necessary protection;

(h) does not prevent any person from continuing to exercise any right or freedom which that person might reasonably expect to continue to exercise;

(i) is not of constitutional significance;

(j) makes the law more accessible or more easily understood (in the case of provisions restating enactments);

(k) has been the subject of, and takes appropriate account of, adequate consultation;

(l) gives rise to an issue under such criteria for consideration of statutory instruments laid down in paragraph (1) of Standing Order No. 151 (Statutory Instruments (Joint Committee)) as are relevant.²³

15. The following section sets out our assessment of the draft Order against these criteria. We wrote to Georgia Gould MP, Parliamentary Secretary for the Cabinet Office, on 16 June 2025 seeking some further information to aid in our review of the draft Order. Minister Gould responded on 25 June 2025, and her response is published alongside this report.²⁴

16. The Committee also has a role, under section 15 of the 2006 Act, in considering whether the parliamentary procedure recommended for the draft Order is appropriate. The Government has recommended that the draft Order be laid under the affirmative resolution procedure, with the Explanatory Document stating that, although the Order is of limited impact and complexity, it does amend an Act of Parliament and an Act of Senedd Cymru. The Government therefore considers it appropriate to subject the Order to a level of scrutiny above that required by the negative resolution procedure. The Government also believes that the super-affirmative procedure is unlikely to be appropriate, as the draft Order is not “wide-ranging or complex”.²⁵

17. Following the laying of the draft Order on 21 May 2025, a 30-day period began during which the Committee could recommend that the super-affirmative procedure should apply to the draft Order.²⁶ The Committee considered this question on 24 June 2025, and concluded that the affirmative procedure is appropriate for this draft Order. As previously noted, the House of Lords Delegated Powers and Regulatory Reform Committee concluded likewise in its report of 13 June 2025.²⁷

Assessment against criteria

A: Appears to make an inappropriate use of delegated legislation

19. In light of the information provided by the Department, and our assessment against the other criteria enumerated in Standing Order No. 141, we are satisfied that the draft Order does not make inappropriate use of delegated legislation.

B: Serves the purpose of removing or reducing a burden, or the overall burdens, resulting directly or indirectly for any person from any legislation (in respect of a draft order under section 1 of the Act)

21. Section 1 of the 2006 Act provides the power to make an order which would serve the purpose of removing or reducing any burden resulting directly or indirectly for any person from legislation. The burden may be a financial cost, an administrative inconvenience, an obstacle to efficiency, productivity or profitability, or a sanction that affects a lawful activity being carried out.

22. The Department asserts that the draft Order will remove and reduce burdens in accordance with section 1(2) of the 2006 Act, namely financial burdens and administrative inconveniences. The Department accepts that the Order will introduce an initial negligible financial burden, but argues that this will be fully offset by the far greater financial savings in fraud prevention and recovery. For example, the biennial (two-yearly) fee (payable by a local authority to participate in the NFI’s data matching exercise) would be uplifted to cover the cost of additional social care data matching, by around £300. However, the Department expects outcomes as a result of resumed data sharing to be similar to previous years in which data sharing was mandated and each local authority made average savings of up to £25,000 in England, £17,000 in Scotland and £7,000 in Wales over a two-year period. The Department believes that resuming data sharing will represent a return on investment of circa 83:1, reducing overall financial burdens.²⁸

23. The Department’s Explanatory Document argues that the draft Order will remove burdens referred to in section 1 of the 2006 Act for the following reasons:

• it will support reducing financial burdens on local authorities by helping recover money lost through fraud and error so that it can be spent elsewhere;
• mandation of all local authorities means that all local authorities involved in the provision of adult social care would have scope to benefit, both financially and through administrative convenience;
• the data processing would be likely to reduce obstacles to local authority efficiency through generating counter-fraud savings that would otherwise be lost to fraud, and the Order will also help support the productivity of local authority fraud investigation teams; and
• the change would reintroduce a service previously provided that local authorities found beneficial above the burden of self-sharing data (with no local authorities having undertaken alternative voluntary data matching via the NFI to detect fraud in adult social care) and the paying of a small fee to cover processing costs.²⁹

C: Serves the purpose of securing that regulatory functions are exercised so as to comply with the regulatory principles, as set out in section 2(3) of the Act (in respect of a draft order under section 2 of the Act)

25. The draft Order under consideration is not being made under this section of the Act, so this criterion is not relevant.

D: Secures a policy objective which could not be satisfactorily secured by non-legislative means

27. The Department states that there are no non-legislative alternatives, such as a Memorandum of Understanding, that would achieve the intended outcome of the provision. The policy objective is to rectify an unintended consequence of an amendment to the NHS Act 2006 by a previous Act of Parliament and therefore could not be accomplished through a voluntary code of practice or improved guidance. The Department further notes that local authorities are unlikely to obtain the same scale of outcomes under permissive data sharing under the Local Audit and Accountability Act 2014 and through the NFI, due to a significantly smaller pool of data. The Department indicates that it would expect overall total outcomes from data matching undertaken on a discretionary basis by local authorities to be uncertain and potentially minor compared to those achieved through legislation.³⁰

E: Has an effect which is proportionate to the policy objective

29. The Department states that the changes proposed in the draft Order are proportionate as the effect of the provision is limited, only amending the Local Audit and Accountability Act 2014 and the Public Audit (Wales) Act 2004 to enable disclosure of matched local authority social care data to local authorities, but not removing adult social care data from the definition of “patient data”.

F: Strikes a fair balance between the public interest and the interests of any person adversely affected by it

31. The Department states that the provision would strike a fair balance as data matches from local authorities will assist fraud prevention, reduce the risk of harm to businesses and individuals, and ensure public funds are used effectively. Only those individuals who appear in a match which may indicate fraud would have their record shared for the purposes of further investigation, in line with data protection requirements. The Department also notes that the proposal would restore a previous system that proved effective and did not adversely affect individuals.³¹

G: Does not remove any necessary protection

33. The Department acknowledges that the proposed change could potentially have some impact on individuals’ existing data protections (such as patient confidentiality of data) by allowing adult social care data to be collected and processed by the NFI and the resultant data matches shared with local authorities. As set out in the Explanatory Document, the data protection risk in this instance, like any other aspect of data sharing, would be the risk of data loss as a result of error or criminal attack.³²

34. However, the Department asserts that the NFI’s data matching practices are “extremely robust” and are in compliance with data protection legislation. It also states that the Order would not remove any protections provided for in wider data protection legislation (such as the Data Protection Act 2018). The Explanatory Document confirms that the draft Order would uphold the NHS Act 2006 classification of social care data as “patient data”, and ensure that it is only disclosed by the NFI to certain relevant bodies as specified in legislation.³³

35. We queried the Department on how it foresees the draft Order’s provisions impacting on individuals’ existing data protections. Minister Gould responded that the draft Order “will not remove any protections under data protection legislation” and further stated that:

The data protection impact the Explanatory Document is referring to is that, as a result of the draft Order, adult social care data already lawfully processed by local authorities can be subject to processing by the National Fraud Initiative (NFI) for the purposes of data matching, and the resultant data matches shared back with local authorities. More specifically and in the context of data matching, the draft Order will allow for local authority adult social care data, which falls within the definition of patient data under the Local Audit and Accountability Act 2014 (LAAA 2014) and the Public Audit Wales Act 2004 (PAWA 2004), to be shared by or on behalf of the relevant Minister/Auditor General for Wales with local authorities.

[…] the draft Order will not result in any necessary protections being removed, but rather that the particular dataset of local authority adult social care data can be subject to the NFI’s data matching process in accordance with the [Local Audit and Accountability Act] 2014 and devolved legislation and in accordance with data protection legislation.³⁴

H: Does not prevent any person from continuing to exercise any right or freedom which that person might reasonably expect to continue to exercise

37. The Department states that the proposal would not prevent anyone from continuing to exercise any such right or freedom. Individual rights in relation to their social care data would remain protected and the change would be implemented in line with data protection requirements. The Explanatory Document asserts that matched information would only be disclosed to local authorities with the aim of preventing and detecting fraud. It further states that individuals would be able to be informed of the use of their data through a revised NFI privacy notice, and revised local authority privacy notices, ahead of any data sharing and processing commencing.³⁵

38. The section of the Explanatory Document summarising the consultation input from the ICO states that the ICO published a public consultation on draft transparency guidance in November 2023, focussing on the additional steps that organisations will need to take to ensure that they are sufficiently transparent about the processing they carry out. The consultation concluded in January 2024, with the final version now published. According to the Department, the NFI will take account of this updated guidance when revising its privacy notice.³⁶

39. We queried the Department on whether the revised privacy notices have been prepared, and how they have taken account of the updated guidance issued by the ICO. In response to our letter, Minister Gould provided us with the draft text of the updated privacy notice for the NFI, and also explained that organisations participating in the NFI are also required to publish a privacy notice that sets out how their data will be processed:

It is the responsibility of participating organisations to ensure that privacy notices are regularly reviewed, updated where necessary and validated by their respective Data Protection Officer prior to submitting data to the NFI. […]

All active participants for the current NFI 2024/25 data matching exercise have self-verified that they have informed individuals regarding the processing of their data. Subject to the approval of the draft Order, the NFI will ask participants again at the time of requesting adult social care data to check that all necessary updates have been made to notices to ensure ongoing compliance.³⁷

I: Is not of constitutional significance

41. The Department states that the draft Order would not “deliver significant constitutional reform”, and that it would instead “amend a legislative oversight”.³⁸

J: Makes the law more accessible or more easily understood (in the case of provisions restating enactments)

43. The Department states that the draft Order is not intended to restate any existing enactment, and therefore is not required to demonstrate that the provision would make the law more accessible or easily understood.³⁹

K: Has been the subject of, and takes appropriate account of, adequate consultation

45. As set out in Chapter 1 of this Report, the NFI undertook a direct consultation with local authorities and other bodies between 19 October and 30 November 2023.

46. While we were satisfied that the consultation appeared to indicate that the vast majority of local authorities are in favour of the proposed amendment, we did wish to establish whether the Department was satisfied that a consultation period of less than two months was sufficient for this provision. We also asked the Department whether it was satisfied with the response rate to the consultation (62% amongst local authorities, and 42% amongst the other organisations consulted), particularly in light of the additional cost and administrative requirements that will arise for local authorities. Minister Gould responded that she was “satisfied that the length of the consultation period was sufficient due to the significant response rate to the consultation”.⁴⁰

L: Gives rise to an issue under such criteria for consideration of statutory instruments laid down in paragraph (1) of Standing Order No. 151 (Statutory Instruments (Joint Committee)) as are relevant

Conclusion

Formal minutes

Tuesday 1 July 2025

Members present:

Liam Byrne, in the Chair

John Cooper

Sarah Edwards

Charlie Maynard

Mr Joshua Reynolds

Rosie Wrighting

Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025

Draft Report (Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025), proposed by the Chair, brought up and read.

Ordered, That the draft Report be read a second time, paragraph by paragraph.

Paragraphs 1 to 50, read and agreed to.

Resolved, That the Report be the Ninth Report of the Committee to the House.

Ordered, That the Chair make the Report to the House.

Adjournment

Adjourned till Tuesday 15 July at 2.00pm

List of Reports from the Committee during the current Parliament

All publications from the Committee are available on the publications page of the Committee’s website.

Session 2024–25

Number	Title	Reference
8th	Export led growth: Trade with the Asia-Pacific region	HC 1048
7th	Industrial Strategy	HC 727
6th	How to strengthen UK-EU relations: Policy Priorities for the Summit	HC 908
5th	How to strengthen UK-EU relations	HC 814
4th	Post Office Horizon scandal redress: Unfinished business: Government response	HC 778
3rd	Make Work Pay: Employment Rights Bill	HC 370
2nd	Priorities of the Business and Trade Committee	HC 423
1st	Post Office and Horizon scandal redress: Unfinished business	HC 341
2nd Special	Post Office Horizon scandal redress: Unfinished business: Government response	HC 969
1st Special	Make Work Pay: Employment Rights Bill: Government response	HC 932

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Footnotes

1 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, paras 2.4–2.6

2 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 8.2

3 House of Lords Delegated Powers and Regulatory Reform Committee, 26th Report of Session 2024–25, Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025; Armed Forces Commissioner Bill: Government Response, HL Paper 138, para 9

4 Schedule 9 to the Local Audit and Accountability Act 2014

5 Cabinet Office and Public Sector Fraud Authority, Code of Data Matching Practice for the National Fraud Initiative, 12 September 2018, paras 1.2.2–1.2.3

6 As set out in paragraph 4.5 of the Explanatory Document, the term “adult social care data” refers to data on adult social care services and spending, including care home support payments and personal budgets payments. In England, Scotland and Wales, it is collected by local authorities responsible for adult social care. Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 4.5

7 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 4.6

8 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, paras 4.7–4.8

9 Additional information provided by the Cabinet Office, 9 June 2025

10 House of Lords Delegated Powers and Regulatory Reform Committee, 26th Report of Session 2024–25, Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025; Armed Forces Commissioner Bill: Government Response, HL Paper 138, para 4

11 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 4.9

12 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 4.10

13 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 3.1

14 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 10.2

15 Senedd Cymru/Welsh Parliament, SICM(6)6 - The Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 23 May 2025, para 18

16 Additional information provided by the Cabinet Office, 9 June 2025

17 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, footnote 1

18 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 6.2

19 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 5.3. Clarification on closing date provided by Letter from the Parliamentary Secretary for the Cabinet Office to the Chair regarding the draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 25 June 2025

20 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, Annex C

21 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 7.3

22 House of Commons Standing Orders (Public Business), 23 May 2024, Standing Order No. 141(1)

23 House of Commons Standing Orders (Public Business), 23 May 2024, Standing Order No. 141(3)

24 Letter from the Parliamentary Secretary for the Cabinet Office to the Chair regarding the draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 25 June 2025

25 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 8.2

26 Under section 15(4) of the Legislative and Regulatory Reform Act 2006

27 House of Lords Delegated Powers and Regulatory Reform Committee, 26th Report of Session 2024–25, Draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025; Armed Forces Commissioner Bill: Government Response, HL Paper 138, para 9

28 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.2

29 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.3

30 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, paras 9.5–9.7

31 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.11

32 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.12

33 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, paras 9.12–9.14

34 Letter from the Parliamentary Secretary for the Cabinet Office to the Chair regarding the draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 25 June 2025

35 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.15

36 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, Annex C, para 83

37 Letter from the Parliamentary Secretary for the Cabinet Office to the Chair regarding the draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 25 June 2025

38 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.16

39 Cabinet Office and Public Sector Fraud Authority, Legislative Reform (Disclosure of Adult Social Care Data) Order 2025 - Explanatory document, 21 May 2025, para 9.17

40 Letter from the Parliamentary Secretary for the Cabinet Office to the Chair regarding the draft Legislative Reform (Disclosure of Adult Social Care Data) Order 2025, 25 June 2025