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The UK's Department of Work and Pensions (DWP) claims it needs to collect gender in order to help differentiate people. I asked for a count of how many distinct people have the same full name and data of birth as another person, and of those, how many could be distinguished by gender. DWP refused, claiming it would cost too much, citing the following estimate:

• Request process overview and requirements: The work involved in raising, approving, developing, testing, and executing a script request for DWP and Supplier teams. The DWP team draftsthe request requirements and submits them for peer review andadmin logging. This work would take 3.5 hours.
• Impact and assignment: The Supplier team picks up the request, assigns a resource, reviews the requirements, and provides an impact. This work would take 3 hours.
• Development and testing: The Supplier team develops the script, performs peer review, tests the script, documents the test results,and sends them to DWP for approval. This work would take 15 hours.
• Live proving run and changes: The Supplier team prepares the script package and the DWP team executes the script, assures the results, and raises any questions or changes if required. This work would take 3.5 hours.
• Live production run: The Supplier team raises a live change anddiscusses it at the Change Approval board. The DWP team executesthe script, assures and shares the live results. This work would take 5.5 hours”.

This sounds like bullshit, and in any event includes a lot of administrative overhead that they shouldn't be allowed to count, so I complained to the Information Commissioner's Office.

They upheld my complaint and told DWP they could not rely on cost to deny the request.

Choice quotes:

The Commissioner considers that any estimate must be sensible, realistic and supported by cogent evidence.

The complainant has argued that DWP’s estimates “include a lot of work not strictly required to fulfil my request”

The nature of the work listed by DWP isn’t always clear to the Commissioner; nor is it clear to him that all of the work falls under the permitted activities set out in the Fees Regulations (see paragraph 14), even if DWP’s internal processes require such work.

DWP has listed some work that may not be required. For instance, under ‘live proving run and changes’, DWP said changes would be raised if required, yet under ‘live production run’ DWP assumes changes will be required and talks about a ‘live change’ being raised and discussed at an
approval board.

The Commissioner [...] asked DWP to clarify its estimate [...] however, in response DWP simply upheld the calculations it had provided at internal review, and emphasised the burden of the request

The full decision note should be published as IC-293545-M9K0 next week.