Restart for JSA claimants

Sounds like all the other useless schemes from years before..... don't do as they say,think for yourself and they turn nasty..

The Catwoman wrote:Sounds like all the other useless schemes from years before..... don't do as they say,think for yourself and they turn nasty..

yes indeed, they rotate the areas on each tender but its always the same corporations that's involved.

the youtube video's of the organisation that oversee all of them reveal quite a few insights if you have a few hours to spare ;-)

sadly my time should be used on my own job applications as opposed to seeing what the next hoop to jump through looks like :-/

Topaz wrote: No, I found statutory guidelines, annex 6 online.

Ok, good find. It confirms what HMRC told me - the DWP can't get earnings data for those claimants not connected to HMRC's RTE tracking (UC only).

The provider asked me to sign Consent to Share on  page 25 of the provider handbook (Ingeus). I gave text for this on my post on 25 July at 2.00pm.

Thanks for giving us the link to the Ingeus handbook pages, much appreciated. Nothing in it helps any claimant find, get and keep a job. There is nothing in any legislation that states any claimant has to sign a pledge written by a third party private company.

The GDPR, EA 2010, health and safety law all appear under "joint pledge" as if Ingeus is exempt from those laws if the claimant fails to uphold their part of the pledge. They breached the EA 2010 when they accepted disabled claimants as suitable to be referred to Restart and then didn't bother to think about a mandated warm handover call breaching the EA 2010. (They make sure to ask if the claimant is mandated during the call.)

Page 23 -

What we ask from you:
• Keep our centres safe; unlawful activities and offensive weapons are not permitted.
• Keep our centres free of violence; harassment and discrimination of staff or other clients is not permitted.

They are responsible for keeping their centres safe. They are responsible for keeping their centres free of violence, harassment and discrimination. If they are asking the claimant not to engage in unlawful activities, take offensive weapons, not be violent, harass or discriminate against others then they need to be a lot plainer about it.

Page 24 - Mandation. Words in colour have been inserted by me to indicate where Ingeus are being dishonest.

Should you fail to attend voluntary appointments or voluntary activities that have been set for you without good reason (only a DM gets to decide what is and isn't good reason) future appointments may or may not be subject to Mandation. Your Restart Advisor will share this information with your Jobcentre Plus (JCP) Work Coach. If you continue to miss mandated appointments without good reason (which a DM and only a DM gets to decide), JCP (a DM) may apply a sanction. A sanction is a financial reduction or total ceasing of benefit that is imposed on a Universal Credit or income based Jobseekers Allowance claimant who doesn’t comply with their requirements (JSA Act 1995, JSA Regulations 1996, SAPOE Regulations 2013, or UC Regulations 2013) without good reason.

Please keep the above mention of mandation and sanctions in mind when coming to Page 25.

Page 24 - Whistleblowing - they've written "criminal office"   Bit of a Freudian slip there?

Whistleblowing falls under the "pledge" sections and Ingeus is asking the claimant to promise to please report a criminal offence to the email address shown, rather than to the police.

I will turn to Page 25 and its link to Page 20 in the following post.

Quick reminder: The provider has the legal right to mandate a JSA claimant into undertaking job search activity and job preparation activities only and when they mandate it has to be on a JSA MAN.

Page 25 and Page 20 -

1. "Department for Work and Pensions Fair Processing Notice and On-programme support (page 20)."

"We, the Department for Work and Pensions (DWP), need to record and share information about your employment activity. The information shared will be between DWP, employers and our contracted service providers. This information will be used by DWP (and, where relevant, those contracted to provide auditing services to DWP):
• to validate and audit payment claims from employers and service providers, for the running of the Restart Scheme; and
• in relation to job interview performance. To corroborate details of your employment activity, where appropriate, we will need to confirm details with each of your employers."

AND

2. "Please sign to confirm that you consent to Ingeus and our Delivery Partners sending your CV and application forms via email to necessary recipients (including employers) in order to support you into employment."

"Sending your CV and application forms. To support you into employment we may need to send your CV and/or application forms via email to employers or to your own email account. We may also share your contact details with external providers in order that they can directly speak to you about specific services that they are delivering as part of the Restart Scheme. Your Restart Advisor will always discuss these opportunities with you prior to sharing any personal data and gain your consent."

Item 1 is about the DWP needing to share information and item 2 is about Ingeus sending the claimant's CV and application forms to employers with the claimant's consent. If the DWP needs consent for item 1 to occur then it should be the DWP asking the claimant for it, not the provider.

Item 1 and item 2 are both to be signed for in the same signature box on Page 25. If item 1 doesn't require the claimant's consent then it does not need to be referred to under "consent to share" and should be over with "protecting your privacy" on the left hand side of page 25. If it does need the claimant's consent then there should be 2 separate signature boxes as item 1 and item 2 are different. If item 1 is tied to item 2 then the provider needs to explain why they are tied together.  

Due to the document not stating what the claimant is signing for in relation to item 1, it would be foolish of any claimant to sign that part of the document.

Thank you for all the info posted, I’ve been from pillar to post with my local JCP, lots of non payment of my benefits, trying to push me onto UC, and now the restart course. As my username implies, I’m deaf so a 3 way call is beyond their limited brain powers! However, it looks like it’ll be going forward in the next few weeks.

Welcome to the forum #Deafbloke...
Just as I thought it's another ' Cookie cutter' approach to all Claimant's, so much for 'tailored support' from the Retread scheme .

It will be interesting to see what the Provider & JCP , do within the Equalities Act 2010 'reasonable adjustment' with regards to your hearing issue?

Pintel wrote:Welcome to the forum #Deafbloke...
Just as I thought it's another ' Cookie cutter' approach to all Claimant's, so much for 'tailored support' from the Retread scheme  .

It will be interesting to see what the Provider & JCP , do within the Equalities Act 2010 'reasonable adjustment' with regards to your hearing issue?

So far, not a lot! I’m sure they use the EA2010 as toilet paper! I’ve had so much trouble with them in the last few months! After some hassles with a new roach, I wrote letters of complaint around treatment I’d been getting in their office, sanctioned for not taking phone appointments, when they know I’m deaf, I also was in the office for another appointment, they said I didn’t attend as I didn’t come forward when called. Although I’m not under sanctions at the moment, my benefits are routinely paid a week late. Silly games really, but all happened after I wrote letters of complaint regarding lack of reasonable adjustments, the only thing that’s got me is a fast track to restart! Still, it’s finally on my record that I’m deaf. They still insist on phoning though!

Welcome DB.

I’m sure they use the  EA2010 as toilet paper!

Yes, they actively ignore what their own employer has written on this page:

https://www.gov.uk/guidance/get-help-with-benefits-and-pensions-if-you-have-accessibility-needs#:~:text=DWP%20will%20contact%20you%20to,appointment%20at%20a%20quieter%20time

Although I’m not under sanctions at the moment, my benefits are routinely paid a week late.

What is their explanation for this? Do you see the delay as pressure to get you to switch to UC?  

it's finally on my record that I’m deaf

It shouldn't be such a fight to get access issues recognised.

it looks like it’ll be going forward in the next few weeks

Have they said that it will be via a 3 way warm handover call? If so, in what location?

Absolut wrote:Welcome DB.

I’m sure they use the  EA2010 as toilet paper!

Yes, they actively ignore what their own employer has written on this page:

https://www.gov.uk/guidance/get-help-with-benefits-and-pensions-if-you-have-accessibility-needs#:~:text=DWP%20will%20contact%20you%20to,appointment%20at%20a%20quieter%20time

Although I’m not under sanctions at the moment, my benefits are routinely paid a week late.

What is their explanation for this? Do you see the delay as pressure to get you to switch to UC?  

it's finally on my record that I’m deaf

It shouldn't be such a fight to get access issues recognised.

it looks like it’ll be going forward in the next few weeks

Have they said that it will be via a 3 way warm handover call? If so, in what location?

It’s definitely pressurising me to switch, I’ve told them I’ve no intention of moving voluntarily, although I THINK I may be slightly better off, unless it’s a managed migration, I’m not doing it.
I’ve also been foisted the new CC that others on legacy benefits have been, there’s no mention of my disability on it, or the limitations it could place me with, so I quite often say I’m only looking for work as a telephonist, it’s the only way they acknowledge that I’m deaf! Small victories, but I like them! I’ve also recently been partnered with an assistance dog, and this will mean the type of work I do will need to change. They’re no too pleased about that, but I can’t take a dog into a busy factory environment.
I’ve had every excuse for late payment they can give, it’s your bank, the payments gone through, but I’ll do it again, I’m so sorry, I know how hard it must be… Strangely, only happened since I wrote complaint letters
Sorry to meander, as to the call, I THINK it’ll be a JCP manager talking/ passing on what’s said, but I’m not sure. Apparently it HAS to go ahead in some form, but I’ve no intention of making it easy for them, or signing anything!

DeafBloke wrote:It’s definitely pressurising me to switch, I’ve told them I’ve no intention of moving voluntarily, although I THINK I may be slightly better off, unless it’s a managed migration, I’m not doing it.

UC is of no benefit to any claimant who doesn't have a job.

I’ve also been foisted the new CC that others on legacy benefits have been, there’s no mention of my disability on it, or the limitations it could place me with, so I quite often say I’m only looking for work as a telephonist, it’s the only way they acknowledge that I’m deaf! Small victories, but I like them!

They don't like including disabilities on claimant commitments, particularly when that CC is gong to be used by a provider. I see it as a deliberate omission. All my disabilities are on my CC and hubby got his disability on his CC as well, after I sent them a letter before claim.

I’ve also recently been partnered with an assistance dog, and this will mean the type of work I do will need to change. They’re no too pleased about that, but I can’t take a dog into a busy factory environment.

Not too pleased? They really don't know what utter scumbags they are.

I’ve had every excuse for late payment they can give, it’s your bank, the payments gone through, but I’ll do it again, I’m so sorry, I know how hard it must be… Strangely, only happened since I wrote complaint letters

Yeah it's always a coincidence isn't it? Not.

Sorry to meander, as to the call, I THINK it’ll be a JCP manager talking/ passing on what’s said, but I’m not sure. Apparently it HAS to go ahead in some form, but I’ve no intention of making it easy for them, or signing anything!

Why does it have to go ahead? Disabled claimants who have been on JSA for more than 24 months can be mandated to the WHP yet are being "referred" to Restart instead, which has no record to prove that they are any good at getting disabled claimants into work. Seems to me that they have referral targets to hit rather than appropriately referring disabled claimants to the right provision for their needs.

I had a meeting a couple of years ago with a representative of The Shaw Trust with the aim of going on WHP, and said things like are you going to fund training that’ll make a difference? No… pure cat sat on the mat cv writing etc. They said I wasn’t suitable for whp. Hence I think why it’s now restart, and the disability experts at Reed!

quick question, why are people with disabilities being thrown into restart over WHP? i am assuming that was the whp mandate.

i confess to not having looked into whp as i am on restart, seems odd they have 2 schemes running at same time without purpose

mandy tori wrote:quick question, why are people with disabilities being thrown into restart over WHP? i am assuming that was the whp mandate.

i confess to not having looked into whp as i am on restart, seems odd they have 2 schemes running at same time without purpose

Restart is, oddly enough, better than the WHP. WHP providers are authorised employment officers and can mandate claimants into applying for specific vacancies. Restart providers are not EOs. At any time the DWP could authorise the Restart providers to be EOs.

Why 2 different provisions? The Restart provider contract includes them working out of satellite offices in ground floor locations within a disabled claimant's travel distance, and the WHP contract doesn't. However, the DWP isn't obligated to allow a claimant to choose which SAPOE scheme to go on.

Absolut wrote:The Restart provider contract includes them working out of satellite offices in ground floor locations within a disabled claimant's travel distance, and ''the WHP contract doesn't. ''

If there ever was any need for confirmatiomn of what total dellusional moroans we are all being forced to deal with, then in bold is clear as it gets.

They are a total joke. How their allowed to get away with recieving obscene amounts of tax payers money funding these circuses year in year out i will never know. And I wonder, how many tax payers are aware their effectively being ripped off in the process while these 'go nowhere, get nowwhere schemes,' being delivered as something actually worthwhile are the compl;ete opposit for a very large percentage of people. Lets see your success rates provider jokers with all the 50 + age groups with health conditions youve miracoulsy got back into any decent paid work. Hopefully, I will assume right, my definition of any decent paying job will be a mile away from what you would claim is.imo.

As a follow up to the DWP mandating warm handover calls it is worth noting this section in the provider document Chapter 2 "referral process":

2.14. For Potential Participants where English is not their first language and/or have communication needs (e.g. hearing impaired) it is the Jobcentre Plus work coach’s responsibility to ensure appropriate communication methods (e.g. translators) are available up to and including the Warm Handover.

It does not get any clearer than this. If the communication method is not appropriate it is the responsibility of the work coach to arrange one that is, not for the work coach to mandate the inappropriate method instead.

You [the provider] should organise local processes to support these arrangements. Should this be by phone conversation, then you will need to ensure that you are available for calls to arrange the Warm Handover.

The word "should" indicates that it might not be by phone conversation.

2.6. A minimum of 90% of referrals will have a Warm Handover. Jobcentre Plus work coaches will be present and facilitate these.

Which indicates that 10% (or more) will not have a warm handover.

2.30. Exceptional circumstances may mean that a Warm Handover conversation does not happen, such as:
· COVID-19 restrictions (either local or national)
· office outages
· exceptionally high levels of claims, where resources across an area (or nationally) are targeted at making payments
· exceptionally high levels of sickness within a Jobcentre Plus site
· unable to book a Warm Handover following a number of attempts to do so.

Note, this list is not exhaustive.

2.31. In such an instance you will receive a PRaP referral, but you will not have a record already detailing a Warm Handover call, and you won’t have had the opportunity to receive the appropriate Participant information. Not having a Warm Handover is not a reason to reject a referral. You will be required to utilise the initial engagement activity period to discuss the Restart Scheme with your Potential Participant, identify any support needs and arrange the time, date and location for the initial Face to Face meeting, using the appropriate methods available. Continue actions on initial engagement activity as from paragraph 2.20.

It is the DWP that should have already identified support needs to the provider prior to that provider contacting the claimant, but due to the DWP doing nothing other than "booking a call", no information is sent to the provider about any support needs, such as not being able to take a phone call to begin with. That then takes us back to section 2.14 and the work coach being responsible for that, not the claimant.

I'm yet another IB JSA conscript to Restart, and would appreciate some advice.

At my induction a few weeks ago I declined to sign the 'Consent to Share Participant Information - Data Protection' form. The manager was summoned to 'persuade' me to sign, largely by means of making up the rules. I didn't relent and was told that meant I could not have any of my induction paperwork. At a telephone appointment last week my request for copies of said paperwork was declined on the grounds not signing was a failure to participate. Is it worthwhile my making a Subject Access Request to get my paperwork? If so, to whom do I make the request - Reed or Standguide, who are delivering Restart? Do I make any request by email or letter?

This week I have received an email for what appears to be another induction appointment. At my aforementioned telephone appointment, the advisor confirmed my next appointment which is for a week after the appointment I have now been emailed about. Nowhere in this email does it state it is mandatory for me to attend. Should I attend, or only attend when they issue the correct Mandatory Activity Notice? I have completed an induction and the only reason they do not appear to have registered my start is because I will not sign the data sharing form.

Is it risky my either complaining to JCP or calling Reed/Standguide's bluff and getting them to raise a compliance doubt about my failure to participate? Apart from the initial appointment, I have recorded my meetings with them so have some confidence I can substantiate their making the rules up as they go along.

Finally, even though there are plenty of FOI requests confirming participants do not have to sign provider paperwork, is it worth me submitting my own in case this ends up with a Decision Maker?

Signing a piece of paper is not a job seeking activity. You did not fail to participate because they didn't give you anything to participate in..
Do not sign there paperwork, why should you sign their paperwork when they don't have your best interests.
If it's not a mandatory appointment I wouldn't bother attend.

You attended the induction appointment. "Registering a Start... Examples of acceptable evidence could include but not limited to, induction pack items that have been signed for, site attendance register.."
You could show provider relevant FOI responses that no legislation compels you to sign. If you don't sign, this does not mean that you do not have to participate in the scheme.

Ignatius wrote:I'm yet another IB JSA conscript to Restart, and would appreciate some advice.

Hi and welcome to the forum. Were you mandated to attend the first appointment via a printed letter from the DWP? For now I will take it that you were mandated following your agreeing to attend.

At my induction a few weeks ago I declined to sign the 'Consent to Share Participant Information - Data Protection' form. The manager was summoned to 'persuade' me to sign, largely by means of making up the rules. I didn't relent and was told that meant I could not have any of my induction paperwork. At a telephone appointment last week my request for copies of said paperwork was declined on the grounds not signing was a failure to participate. Is it worthwhile my making a Subject Access Request to get my paperwork? If so, to whom do I make the request - Reed or Standguide, who are delivering Restart? Do I make any request by email or letter?

Not unless it has your data on it, which I doubt, other than possibly the cover page. Instead of a SAR you could request a copy of their generic induction paperwork through a Freedom of Information request to the DWP. https://www.whatdotheyknow.com/  

Standguide is in receipt of public funds and that means they are subject to the FOI Act, which they are refusing to comply with by handing over a generic copy of their induction pack. Frank Zola may have already obtained the Standguide induction pack via his numerous UC Restart requests, so it's worth looking first. An FOI will take some time to be answered though, up to a month. Once it's been submitted you could send the link to the FOI to the provider to show them that, in the end, you will get a copy

For a SAR you ask the data controller to release copies to you of the data they hold about you. In this case it would be Standguide, not Reed. If you want to get a SAR going I would advise contacting the Standguide head office team by telephone if you can (www.standguide.co.uk) and asking them directly what their SAR guidance is as the local office has refused to let you see that guidance (which is in the induction pack) despite being ON Restart since [insert initial meeting date].  

This week I have received an email for what appears to be another induction appointment. At my aforementioned telephone appointment, the advisor confirmed my next appointment which is for a week after the appointment I have now been emailed about. Nowhere in this email does it state it is mandatory for me to attend. Should I attend, or only attend when they issue the correct Mandatory Activity Notice? I have completed an induction and the only reason they do not appear to have registered my start is because I will not sign the data sharing form.

The start date and the induction are not actually connected. Day 1 under the SAPOE Regulations is the day from which a DM can sanction for FTA or FTP in Restart but only if the attendance or activity was on a notice. The day you attended the mandated initial meeting is the date they have to enter onto PRaP as Day 1 no matter what you signed or didn't sign for on Day 1. That start date can't be changed to any other date once it's on a notice given to you by the DWP and you attended.

What comes over to me in regard to meetings is that providers think that simply because they can mandate meetings and some activities, that means they can mandate anything they want and that's simply not true. As to your next meeting, which hasn't been mandated, there is good reason to keep a MAN out of the situation for now. Personally I would treat all Restart meetings as I would a WSR where the work coach books it, but doesn't give me a notice. In effect, Restart is a doubling up of the WSR. By keeping it "voluntary", meetings can be re-scheduled without the worry of a potential sanction arising from a cancellation, which should include an immediate request for another date. The purpose of the meeting should not be forgotten - they are being paid to allegedly help you find, get and keep a job. If that isn't happening, then what are they being paid to do exactly?

Is it risky my either complaining to JCP or calling Reed/Standguide's bluff and getting them to raise a compliance doubt about my failure to participate? Apart from the initial appointment, I have recorded my meetings with them so have some confidence I can substantiate their making the rules up as they go along.

I don't know what was on that consent form but allowing them to send your CV can be asked verbally as the need arises. Future earnings data is due to them being unable to track it via HMRC if there's no UC claim on getting a job. They stand to lose their 70% bonus, which is why they are so upset. Consent to know future earnings data on Day 1? Absolutely not. It's too big a lever to give up so easily. It's the stick all JSA claimants can use to get the provider to actually earn their money and help the claimant to find, get and keep a job.

Finally, even though there are plenty of FOI requests confirming participants do not have to sign provider paperwork, is it worth me submitting my own in case this ends up with a Decision Maker?

Not particularly. The word "consent" implies the right to say no. The providers get uppity about it, but will get nowhere.

Topaz wrote: If you don't sign, this does not mean that you do not have to participate in the scheme.

Excellent point. The contract is between the DWP and the provider, not the claimant and the provider.

Thanks all for the advice. If only we could all have met in better circumstances than queries about Restart.

My phone won't let me quote from previous posts so apologies if the formatting is messy.

In response to Absolut's first question following my icy handover at the JCP I was given a JSA598 with details of my first provider appointment.

Looking at Mr Frank Zola's blog & his impressive FOI work on WhatDoTheyKnow, while he has lots of Reed in Partnership & their various sub contractors induction packs dated last year, there doesn't appear to be the 2022 version I declined to sign. Looks like I need to crack on with a FOI request of my own. I will, of course, contact Standguide re their SARs procedure.

After today, I fear the plot of my Restart saga has thickened. Yesterday I contacted Standguide to query why I had been sent another induction appointment. The receptionist was as baffled as I was. After checking the system she confirmed I had already completed my induction and must have been sent someone else's appointment in error (even though it was addressed to me) and reminded me my next advisor appointment was next week. Shortly afterwards I received a text stating it wasn't a mix up and that I needed to attend to "sign the paperwork not signed previously". Today I saw yet another advisor who was initially baffled as to why I was there. I explained I had completed all the assessments, had an Action Plan etc produced 3 weeks ago but I had not been allowed to retain copies due to declining to sign the Consent to Share Data form. My mentioning the data sharing form led to a shift in his tone . When he checked the system all of the assessments and the Action Plan had mysteriously disappeared and I had been marked Failed to Participate. He refused to allow me to take away a copy of the data sharing consent form to have a considered read of it (can't think why!). I explained my not signing the form now does not preclude me signing it at a later date but that was rebuffed as well.

I fear that when I have my WSR early next week I will have been reported as FTP. I genuinely do not know what to do next. Today was my 3rd advisor meeting. Each time I have quoted the Provider Guidance and the various FOI stating signatures are not required to register a start/participate, yet each advisor (I have now had meetings with 3 separate advisors due to holidays) refuses to acknowledge the actual programme regulations and tell me a signature is the only marker of participation.

I think the only evidence I have of my participation is the recording of my telephone appointment last week & yesterday's chat about today's appointment but I have no idea if I would be able to submit these to a Decision Maker or even if it's a good idea to mention them to my Work Coach. The advisor I had the phone appointment with last week did acknowledge I attended and I must have particaped given she knew a lot about my past employment, types of work I was looking for etc.

I am all too aware that I have to participate regardless of whether I sign the forms. But as Absolut points out, Restart is supposed to be about me and improving my lot in life. From what I have seen so far my it appears to be the same job search sessions and courses I have done numerous times before, with the added bonus of staff who just seem to make the rules up and are obsessed with not letting me leave the building with an unsigned copy of their precious consent form in my grubby little hands.

Same old program, don't do as they say and they'll lie and say you didn't attend/participate.

Next time just take their consent forms and put them in your pocket. That's what I did on the work health program,I didn't sign their forms and I put their consent form in my bag before I left....

You will be proud of me Catwoman - when he had his back turned the last page with the all important bits about not needing to sign sort of accidently folded itself up and fell into my back pocket.

i am in the same boat in regards to not signing any provider paperwork, my action plan wasnt even presented to me as i had made this clear (didn't sign the induction either)

this scheme isn't designed for jsa claimants, no one from job centre nor provider has realised this yet. hence the mess it causes with not signing their forms

if on jsa quote "im not obligated to sign any provider paperwork"

if they try and entice you to login to their online portal, ask if its mandatory which it isn't and decline to use it..

above applies to jsa claimants only, uc will get sactions by restart design

Ignatius wrote:In response to Absolut's first question following my icy handover at the JCP I was given a JSA598 with details of my first provider appointment.

Ok, thanks.

On each of the face to face visits did you sign in and out of the building? Did you claim travel costs?

So, from what you have written, it appears to me that the Restart provider has refused to register a start, twice in a row, due to your right not to have to sign a consent to share data form after being mandated onto a SAPOE scheme under threat of a benefit sanction by the DWP.

Do you have it in writing from the provider that they have not registered a start and will not do so until you sign a consent to share data form?

I fear that when I have my WSR early next week I will have been reported as FTP. I genuinely do not know what to do next.

There is no FTP without a start date. There is only FTA. You attended. Following a start date on PRaP then the provider can claim FTP, but only that which was notified. FTP is never detached from the phrase without good reason even if the action (to sign away your rights) was mandated, which it wasn't. The signing of provider paperwork does not appear in the JSA Act 1995, the JSA Regulations 1996 or the SAPOE Regulations 2013.

Today was my 3rd advisor meeting. Each time I have quoted the Provider Guidance and the various FOI stating signatures are not required to register a start/participate, yet each advisor (I have now had meetings with 3 separate advisors due to holidays) refuses to acknowledge the actual programme regulations and tell me a signature is the only marker of participation.

A signature for what and why do they get to decide what is and isn't participation when they are not DMs? Who are they to decide that it's ok to have the DWP logo on their website but then fail to follow the DWP's provider documents and the DWP's SAPOE Regulations?  

3.13.You must record and retain evidence of the Start Date which you will be required to be produced during Performance and Compliance Officer checks, see Restart Scheme Provider Guidance Chapter 14 – Performance Management. Examples of acceptable evidence could include but not limited to, induction pack items that have been signed for, site attendance register. If a Face to Face meeting can’t take place in person, then digital evidence could include, but not limited to, a dated electronic receipt from the Participant..

Sorry it's taken so long to reply. I know you must be worried, but they can't claim FTP over lack of consent forms. That's not how mandated SAPOE Schemes work.