Council-tax, payroll and electoral records feed a fraud-checking system involving councils, NHS organisations, colleges and government agencies. Approved private-company access can include identifiable information without requiring each person’s consent.
Audit Scotland has issued a revised fraud-checking code explicitly describing how approved private companies can obtain personal information from the National Fraud Initiative, the UK-wide system supplied with records by councils, NHS organisations, colleges and other public bodies.
The code, published on 8 October 2026, sets out levels of access ranging from anonymous indicators and redacted results to names, dates of birth, National Insurance numbers and addresses. More detailed outputs may include dates and financial or benefit-related information, depending on the authorised purpose and access level.
The Scottish privacy notice names Synectics Solutions’ SIRA service and LexisNexis Risk Solutions Ltd among the fraud-prevention organisations involved. Only a subset of NFI information is made available through these arrangements; the documents do not give every participating business unrestricted access to every record.
The Scottish Government itself, Scottish Water, Revenue Scotland, the Scottish Police Authority and the Scottish Prison Service appear in the participant schedule. Their inclusion concerns specified information supplied to the programme, not everything held by those organisations.
The revision replaces a code published in 2018. It is not evidence that commercial access began this month. Audit Scotland’s August report had already described private organisations searching the NFI data pool in recent years to check matters such as an applicant’s identity or residency.
Records Beyond Benefit Claims
The Scottish collection is much wider than a list of people suspected of fraud or claiming benefits. Under the heading for council-tax single-person discounts, Audit Scotland instructs councils to provide all current accounts, whether or not a discount or exemption applies. Its electoral-register requirement is for the full register, not the edited version available commercially.
A household paying its council-tax bill without claiming a reduction can therefore fall within the submitted information. These are administrative records held by public bodies, not simply information that anyone could already inspect online.
The 2026/27 participant instructions require all 32 councils, all 22 health bodies and 19 incorporated colleges to take part, alongside central-government organisations, Strathclyde Partnership for Transport and Tayside Contracts. Depending on the organisation, required datasets include payroll, pensions, housing tenancies and waiting lists, supplier payments, Blue Badges, taxi-driver licences and adult concessionary travel records.
The standard requirements for health bodies, colleges and most central-government participants concern payroll and supplier records. Their participation does not establish that medical case files, police investigations or entire student records are being made available to commercial companies.
The instructions also identify a change for this exercise: personal-budget and private supported-care-home data will be collected within the main programme. The privacy notice says the system can identify that someone receives particular support or lives in a care home without holding the medical condition underlying that support. It is not a general transfer of clinical case notes.
Police Scotland’s own participation notice makes clear that inclusion does not put a particular person under suspicion. A match may identify an inconsistency requiring investigation, but fraud, error and another explanation cannot be separated until that investigation occurs.
Checks at the Point of Application
The main public-sector exercise runs every two years. Participating organisations submit information through a secure system, receive possible matches and investigate them. Other NFI services allow checks when someone applies for a benefit, service or employment, rather than waiting for the next national exercise.
The UK Government’s guidance for private organisations describes the commercial applications directly. Banks and financial institutions can check new credit applications in real time and submit existing customer information for retrospective batch checking. The same guidance describes screening payroll, pensions, housing tenancies and supplier payments.
A person can therefore encounter a commercial fraud check drawing on this infrastructure while applying for a service, not only when a council reviews an existing entitlement. The purpose described in the guidance is detecting possible fraud; it does not establish that an NFI match is itself a credit score or an automatic decision to refuse borrowing.
The NFI’s 2025 strategy presents private-sector collaboration as part of its wider prevention work, identifying uses involving car rental, insurance and the water industry. Those are UK-wide examples. They do not establish which Scottish records each business receives or how many Scottish residents have been checked.
The Companies Behind the Services
Synectics Solutions is a Staffordshire-based fraud-prevention business whose clients include financial-services and insurance companies. Investment firm Synova announced an investment in the company in April 2024, alongside the founding Shanahan family. Synectics operates National SIRA, a separate commercial fraud-information service, as well as providing NFI infrastructure.
A Synectics service-definition document published through the government’s Digital Marketplace explains the relationship between the two systems. NFI information is held separately from National SIRA. The document describes access for an agreed fraud-prevention purpose at additional cost, with Synectics able to help arrange an agreement while government retains control.
That document carries a 2024 copyright date and refers to the Cabinet Office, which administered the programme at the time. It provides earlier evidence of a paid access arrangement, not a current price quotation. Purchasing the commercial service does not, by itself, confer permission to search the entire NFI collection.
LexisNexis Risk Solutions is part of RELX, the information and analytics group. Its UK consumer guidance describes products used by credit, insurance and utility providers and other organisations to verify identities and support fraud and compliance checks. The company says it does not use or sell that information for marketing and subjects customers to checks on their purpose for accessing it.
The NFI privacy documentation separates work undertaken on government’s instructions from commercial use of NFI-derived results. Where fraud-prevention organisations configure those insights within their own products, including tools used by clients, they act as independent data controllers and their own privacy notices apply. They are not simply storing information on behalf of the public body that originally supplied it.
Named Private Participants and the Businesses Eligible for Checks
The published NFI notices identify private organisations beyond the two commercial fraud-data providers, Synectics Solutions Limited and LexisNexis Risk Solutions Ltd. They also name Airbnb Ireland UC and the Insurance Fraud Bureau, although their involvement concerns different activities and does not give them identical permissions to search public-sector information.
Airbnb Ireland UC is named as both a source and a recipient of personal information in a separate pilot intended to detect fraudulent subletting of social housing through its accommodation platform. City of Edinburgh Council is explicitly included alongside councils elsewhere in the UK. The dedicated privacy notice describes information being exchanged for that housing-fraud exercise; it does not describe general access to Scottish council, NHS or police databases. It also states that information shared with Airbnb is stored outside the UK, subject to the international-transfer safeguards described in the notice.
The Insurance Fraud Bureau appears among voluntary participants that provide information to the NFI and may receive personal data where it appears in a relevant match. Its inclusion does not establish that every insurer associated with the bureau can search NFI records. The same notice lists private-sector pension schemes, housing associations and other social-housing providers, together with an entry described only as “Tenancy Deposit Protection Scheme”. That entry does not identify a legal operator, so it cannot reliably be attributed to a particular deposit-protection company.
The range of organisations eligible to use NFI screening services is broader than the companies individually named in those notices. Government guidance offers banks and financial institutions checks on new credit applications and existing customer records. Pension schemes can use mortality screening to identify payments continuing after someone has died. Housing associations and other social-housing providers can use tenancy checks. Employers and other organisations, including charities, can obtain payroll and supplier-payment screening to identify potential employment fraud, duplicate payments or other inconsistencies. These services return information relevant to the particular check; they are not a general licence to inspect public records.
Some commercial uses are already documented rather than merely offered. The NFI’s 2025 strategy records that car-rental businesses, insurance companies and the water industry have used information derived from NFI checks within their normal business processes, including checks on applicants’ identities and residency. These are UK-wide examples. The strategy does not identify every business involved or establish which Scottish records each has used.
Credit-reference agencies have another documented role. The national privacy notice says personal records may be supplied to them for matching against their information, with additional information returned securely to the NFI. That is processing undertaken on government’s behalf, not evidence that an agency may freely reuse the supplied records in unrelated commercial products. The notice does not name each credit-reference agency involved.
Eligibility for a screening service is therefore separate from permission to search the NFI data pool. Audit Scotland’s code says the Public Sector Fraud Authority has granted a small number of companies limited search access, with approved datasets and levels of detail determined by the purpose. Those companies may incorporate NFI-derived results into fraud-prevention tools used by their clients, but being a client of a fraud-data supplier does not itself prove access to Scottish records. The published notices do not provide a complete company-by-company register identifying every commercial recipient, its Scottish data permissions and the information available to its customers.
Access Is Controlled at UK Level
The revised Scottish code assigns responsibility for private-company access to the Public Sector Fraud Authority, or PSFA. Audit Scotland does not grant that access or control private-sector processing. Audit Scotland and the PSFA are joint controllers for the biennial bulk exercise and application matching undertaken by public bodies.
The UK programme has also changed departmental home. Its national privacy notice records that the PSFA, including the NFI, transferred from the Cabinet Office to the Department for Work and Pensions on 21 July 2026. It identifies DWP as the responsible department and says the move did not change the contracted hosting arrangements or operational workflows.
Scotland’s statutory matching powers were introduced through the Criminal Justice and Licensing (Scotland) Act 2010 and incorporated into the Public Finance and Accountability (Scotland) Act 2000. At UK level, the NFI also operates under powers in the Local Audit and Accountability Act 2014. These are existing legislative routes, rather than powers created by the October code.
The processing does not depend on each resident signing a consent form. The national guidance states that statutory authority permits matching without individual consent. That is not an exemption from all data-protection requirements: organisations still have obligations governing their purposes, information quality, security and people’s rights.
Public bodies taking part must provide privacy information explaining the processing. The UK participation guidance requires confirmation that appropriate notices have been issued. Notification of a statutory use and asking for permission are different processes; the documents require the former without making the exercise dependent on the latter.
Concerns about private-sector sharing have already affected participation. Audit Scotland’s August report says it could not secure enough voluntary housing-association participation for a viable pilot because of concerns about those arrangements. The Scottish Government considered compulsory participation but concluded that legislative change was not sufficiently justified at that stage.
What the Scottish Savings Measure
Audit Scotland’s report published on 19 August 2026 records £21.7 million in Scottish outcomes for the two years to 31 March 2026, reported under the 2024/25 exercise. The total comprises £6 million in actual overpayments and additional income, £8.9 million in estimated future savings and £6.8 million in notional outcomes. It is not a statement that £21.7 million in stolen money has been recovered.
The reported benefits include identifying incorrect council-tax discounts, pension overpayments, business-rates issues and duplicate payments. Such work can recover public money, stop an incorrect payment continuing and reveal weaknesses in financial controls. The programme addresses administrative error as well as deliberate dishonesty.
Private-sector outcomes are not included in that Scottish total. Audit Scotland says they are not allocated or apportioned between the different parts of the UK. The published Scottish savings therefore do not measure either the financial benefit or the scale of commercial checks involving Scottish information.
A Match Is Not a Finding of Fraud
The UK NFI guidance describes computer matching as an automated comparison, not an automated decision. Its results require human investigation before anyone concludes that fraud, an overpayment, an underpayment or another error has occurred. The stated process therefore requires more than two records failing to agree.
The wider commercial consequences of fraud screening are described in Synectics’ own National SIRA privacy notice. It says a client’s determination that someone poses a fraud or money-laundering risk may result in refusal of goods, services, financing or employment, or the ending of an existing service. A risk record may also be passed to other fraud-prevention agencies.
That is a description of the broader SIRA service, not evidence that an NFI match automatically produces such a refusal. The notice also says some risk information can remain for up to six years. That period is not the retention rule for every record supplied to the NFI.
LexisNexis’ UK guidance says it does not decide whether its customers should approve someone for a product or service: its information is one tool used in the customer’s decision. It directs individuals who believe its records are inaccurate to its data-access and correction process. A person challenging a refusal may consequently need to distinguish the organisation making the decision from the organisation supplying information.
The NFI has its own deletion schedule, with different periods for uploaded datasets, matches and investigation records. The 2026/27 schedule gives a twelve-month retention period for AppCheck application data. Material retained by a public body for an investigation, or by a company under its own lawful processing arrangements, is a separate question from deletion within the central system.
Correcting a Record Across Organisations
Someone disputing personal information can ask the organisation holding it to investigate its accuracy and correct an error. The Information Commissioner’s Office advises identifying the specific inaccuracy, explaining the correction sought and supplying supporting evidence where available. It recommends keeping a written record of the request.
The regulator also says that where inaccurate information has been disclosed to others, the organisation must tell those recipients about a correction unless doing so is impossible or involves disproportionate effort. Correcting the originating record and ensuring that recipients receive the correction are therefore both relevant when information has travelled between organisations.
These rights are not absolute. Fraud and crime-prevention exemptions can restrict access to information in particular circumstances, but the ICO’s guidance does not make the existence of a fraud-prevention purpose a blanket exemption. The organisation must assess whether the legal conditions apply to the particular processing and request.
For a disputed commercial decision, the practical starting points are the organisation that made the decision and the company holding the information in question. Unresolved concerns about the handling of personal information can be taken to the ICO after the organisation has had an opportunity to respond.
The Scottish Participation Schedule in Full
The following tables cover the Scottish bodies specified by Audit Scotland’s July 2026 instructions, including the five invitations that the appendix marks as not yet finalised. The instructions identify councils, health bodies and incorporated colleges collectively; their individual names have been expanded using the official Scottish Government and Scottish Funding Council directories.
This is a schedule of required participation and recorded invitations, not confirmation that every organisation has uploaded its files. It is not a list of databases that private companies can freely search. Commercial access remains restricted to information and purposes approved by the Public Sector Fraud Authority.
The instructions refer to 55 central-government entries, but five appear under an explicit pending-invitation heading. They are separated below. The 11 council-administered pension funds are included within council participation, not counted as 11 additional public bodies.
All 32 Councils
All Scottish councils are required to participate. Their specified returns cover payroll, supplier records and relevant council-tax, electoral, housing, licensing, transport, pension and social-care datasets.
| No. | Council |
|---|---|
| 1 | Aberdeen City Council |
| 2 | Aberdeenshire Council |
| 3 | Angus Council |
| 4 | Argyll and Bute Council |
| 5 | City of Edinburgh Council |
| 6 | Clackmannanshire Council |
| 7 | Comhairle nan Eilean Siar |
| 8 | Dumfries and Galloway Council |
| 9 | Dundee City Council |
| 10 | East Ayrshire Council |
| 11 | East Dunbartonshire Council |
| 12 | East Lothian Council |
| 13 | East Renfrewshire Council |
| 14 | Falkirk Council |
| 15 | Fife Council |
| 16 | Glasgow City Council |
| 17 | The Highland Council |
| 18 | Inverclyde Council |
| 19 | Midlothian Council |
| 20 | Moray Council |
| 21 | North Ayrshire Council |
| 22 | North Lanarkshire Council |
| 23 | Orkney Islands Council |
| 24 | Perth and Kinross Council |
| 25 | Renfrewshire Council |
| 26 | Scottish Borders Council |
| 27 | Shetland Islands Council |
| 28 | South Ayrshire Council |
| 29 | South Lanarkshire Council |
| 30 | Stirling Council |
| 31 | West Dunbartonshire Council |
| 32 | West Lothian Council |
The 11 Pension Funds Included Within Council Participation
Audit Scotland includes council-administered pension funds within the council requirement. The Scottish Public Pensions Agency identifies the following 11 funds.
| No. | Pension fund |
|---|---|
| 1 | Dumfries and Galloway Pension Fund |
| 2 | Falkirk Council Pension Fund |
| 3 | Fife Council Pension Fund |
| 4 | Highland Council Pension Fund |
| 5 | Lothian Pension Fund |
| 6 | North East Scotland Pension Fund |
| 7 | Orkney Islands Pension Fund |
| 8 | Scottish Borders Pension Fund |
| 9 | Shetland Islands Pension Fund |
| 10 | Strathclyde Pension Fund |
| 11 | Tayside Superannuation Fund |
All 22 Health Bodies
The standard health-body requirements concern payroll and supplier records, not a general submission of patients’ medical files. The Scottish Government supplies those records for the Mental Welfare Commission; NHS payroll may also be collected centrally where the arrangements allow.
| No. | Health body |
|---|---|
| 1 | Healthcare Improvement Scotland |
| 2 | Mental Welfare Commission for Scotland |
| 3 | National Waiting Times Centre Board / NHS Golden Jubilee |
| 4 | NHS 24 |
| 5 | NHS Ayrshire and Arran |
| 6 | NHS Borders |
| 7 | NHS Dumfries and Galloway |
| 8 | NHS Fife |
| 9 | NHS Forth Valley |
| 10 | NHS Grampian |
| 11 | NHS Greater Glasgow and Clyde |
| 12 | NHS Highland |
| 13 | NHS Lanarkshire |
| 14 | NHS Lothian |
| 15 | NHS Orkney |
| 16 | NHS Shetland |
| 17 | NHS Tayside |
| 18 | NHS Western Isles |
| 19 | Public Health Scotland |
| 20 | Public Services Delivery Scotland |
| 21 | Scottish Ambulance Service Board |
| 22 | State Hospital Board for Scotland |
All 19 Incorporated Colleges
The incorporated colleges are required to provide payroll and supplier records. This is not a requirement to submit every student’s education record. Non-incorporated colleges are not additional entries within this mandatory college category.
| No. | College |
|---|---|
| 1 | Ayrshire College |
| 2 | Borders College |
| 3 | City of Glasgow College |
| 4 | Dumfries and Galloway College |
| 5 | Dundee and Angus College |
| 6 | Edinburgh College |
| 7 | Fife College |
| 8 | Forth Valley College |
| 9 | Glasgow Clyde College |
| 10 | Glasgow Kelvin College |
| 11 | New College Lanarkshire |
| 12 | North East Scotland College |
| 13 | South Lanarkshire College |
| 14 | UHI Inverness |
| 15 | UHI Moray |
| 16 | UHI North, West and Hebrides |
| 17 | UHI Perth |
| 18 | West College Scotland |
| 19 | West Lothian College |
The 50 Central-Government Entries Outside the Pending-Invitation Group
“Scottish Government” in the submission column means the government supplies payroll and supplier records on the body’s behalf. “Own systems” identifies the submitting organisation; it does not mean every database it holds is submitted. Exceptions recorded in the appendix are shown individually.
| No. | Body | Submission route |
|---|---|---|
| 1 | Accountant in Bankruptcy | Scottish Government |
| 2 | Care Inspectorate | Own systems |
| 3 | Community Justice Scotland | Scottish Government |
| 4 | Creative Scotland | Own systems |
| 5 | Crofting Commission | Scottish Government |
| 6 | Crown Office and Procurator Fiscal Service | Own systems; listed as “Crown Office” |
| 7 | Disclosure Scotland | Scottish Government |
| 8 | Education Scotland | Scottish Government |
| 9 | Food Standards Scotland | Own supplier records; Scottish Government supplies payroll |
| 10 | Forestry and Land Scotland | Own systems |
| 11 | Scottish Forestry | Own systems |
| 12 | Highlands and Islands Enterprise | Own systems |
| 13 | Historic Environment Scotland | Own systems |
| 14 | National Galleries of Scotland | Own systems |
| 15 | National Library of Scotland | Own systems |
| 16 | National Museums of Scotland | Own systems |
| 17 | National Records of Scotland | Scottish Government |
| 18 | Office of the Scottish Charity Regulator | Scottish Government |
| 19 | Police Investigations and Review Commissioner | Scottish Government |
| 20 | Registers of Scotland | Own systems |
| 21 | Revenue Scotland | Scottish Government |
| 22 | Risk Management Authority | Scottish Government |
| 23 | Royal Botanic Garden Edinburgh | Own systems |
| 24 | Scottish Canals | Own systems |
| 25 | Scottish Children’s Reporter Administration | Own systems |
| 26 | Scottish Courts and Tribunals Service | Own systems; listed as “Scottish Court Service” |
| 27 | Scottish Criminal Cases Review Commission | Scottish Government |
| 28 | Scottish Enterprise | Own systems |
| 29 | Scottish Environment Protection Agency | Own systems |
| 30 | Scottish Fire and Rescue Service | Own systems |
| 31 | Scottish Fiscal Commission | Scottish Government |
| 32 | Scottish Funding Council | Own systems |
| 33 | Scottish Government | Own systems |
| 34 | Scottish Housing Regulator | Scottish Government |
| 35 | Scottish Legal Aid Board | Own systems |
| 36 | NatureScot | Own systems |
| 37 | Scottish Parliamentary Corporate Body | Own systems |
| 38 | Scottish Police Authority | Own systems |
| 39 | Scottish Prison Service | Own systems |
| 40 | Scottish Public Pensions Agency | Pension-award data; Scottish Government supplies payroll and supplier records |
| 41 | Qualifications Scotland | Own systems; appendix retains the older label “Scottish Qualifications Authority OS” |
| 42 | Scottish Social Services Council | Own systems |
| 43 | Scottish Water | Own systems |
| 44 | Skills Development Scotland | Own systems |
| 45 | Social Security Scotland | Scottish Government; benefit-award data may also be required for pilot exercises |
| 46 | South of Scotland Enterprise | Own systems |
| 47 | sportscotland | Own systems |
| 48 | Student Awards Agency Scotland (SAAS) | Student-award data; Scottish Government supplies payroll and supplier records |
| 49 | Transport Scotland | Scottish Government |
| 50 | VisitScotland | Own systems |
The appendix retains some older names. Qualifications Scotland is shown under its current name while the table preserves the appendix’s original label. The Scottish Courts and Tribunals Service appears in the appendix as “Scottish Court Service”. Neither naming difference represents an additional participant.
Other Scottish Participants
| No. | Body | Participation |
|---|---|---|
| 1 | Strathclyde Partnership for Transport | Required participant; payroll and supplier records |
| 2 | Tayside Contracts | Required participant; payroll and supplier records |
| 3 | Audit Scotland | Submits its own data in addition to the mandated bodies |
Five Invitations Not Finalised in the Published Schedule
These organisations appear in the appendix under a heading stating that they have been invited but their involvement has yet to be finalised. Their listing must not be treated as confirmation that they have agreed to participate or supplied data.
| No. | Organisation | Recorded status |
|---|---|---|
| 1 | Caledonian Sleeper Ltd | Invited; not finalised |
| 2 | Ferguson Marine Port Glasgow | Invited; not finalised |
| 3 | Loch Lomond and The Trossachs National Park Authority | Invited; not finalised |
| 4 | ScotRail Trains Ltd | Invited; not finalised |
| 5 | Zero Waste Scotland | Invited; not finalised |
The schedule is not a complete register of every indirect contributor or every organisation in the UK-wide initiative. Audit Scotland also reports that councils can submit payroll for arm’s-length organisations and valuation joint boards. No complete named list of those additional Scottish contributors is supplied in the documents examined here.
The Scottish Breakdown
The public-sector participation schedule identifies the bodies expected to contribute, while the code and privacy notices describe categories of information, permitted uses and levels of private access. They do not provide a company-by-company schedule showing which Scottish datasets each private organisation may search, which fields it may receive, or how many searches have involved Scottish residents.
Nor do those documents supply a Scottish count of disputed commercial matches, corrections or decisions changed after a challenge. Audit Scotland’s public-sector outcome report cannot fill that gap: it expressly excludes the commercial results. The October revision explains more of the access framework, but the scale and outcomes of its private-sector use in Scotland remain unquantified in those publications.
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