 In 2014, Prime Minister David Cameron, at a Policy Exchange speech in 2014 mentioned a "career psychopath", which was interpreted by several media outlets as a reference to Cummings, although the two had never met.In 2012, a senior female civil servant received a payout of £25,000 in a bullying case she took against Cummings and a senior member of Michael Gove's team, when Cummings was a special adviser at the Department for Education.During his time as an official working for Gove, Cummings received a warning from the Information Commissioner's Office (ICO) for use of private Gmail accounts to deal with government business, saying it should be 'actively discouraged'.