FOI Man

February 27, 2012

Disclosure Logs

Filed under: Freedom of Information Act — FOIMan @ 12:13 pm
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FOI Man explains why he’s a convert to Disclosure Logs

One of the suggestions in my evidence to the Justice Select Committee is that consideration be given to making disclosure logs mandatory for large public sector bodies. It seems sensible to me that if responding to an FOI request is de facto disclosure to the world at large then why don’t we do just that?

I’m not alone – I know that others suggested it too. But why do I think it is such a good idea?

Towards the end of last year I implemented a disclosure log at my own organisation. Most responses are published there. My experience so far has been very positive. I’ve been able to refer several requesters to the information already published, saving my time and allowing a prompt response. Referral to the answers in the disclosure log is much more common than referral to information published through our publication scheme.

The publication scheme, I think, is just too blunt a tool to answer most requests. Most requesters want to drill down further than the published information, which tends to be at a high level. They want to know things that aren’t routinely published.

But having said that, I’ve noticed that in the case of my current organisation at least, many subjects do come up time and time again in requests. So responses published through the disclosure log are actually useful, both to me and to prospective requesters.

So based on my own experience so far, I’d definitely encourage fellow FOI Officers to consider introducing a disclosure log if they haven’t already. Interestingly, when the Protection of Freedoms Bill becomes law, we’ll all be required in effect to maintain a disclosure log for datasets (section 102(4) amends the FOI Act to the effect that publication schemes must include datasets disclosed under the Act), so maybe that will prompt more public bodies to maintain logs for all disclosures.

February 26, 2012

FOI Man talks!

Filed under: Freedom of Information Act,Save FOI Campaign — FOIMan @ 5:23 pm

At the end of last week I was interviewed for a podcast produced by the journalism.co.uk website. You can hear me talking about FOI and the Save FOI Campaign.

There’s also a great piece on their website about the launch of the Save FOI Campaign last week.

Submissions to the Post-Legislative Scrutiny

Filed under: Amendments,Freedom of Information Act,Save FOI Campaign — FOIMan @ 5:14 pm

FOI Man highlights a useful new resource available via the Save FOI Campaign website

If you want to dip into the submissions made to the Justice Select Committee’s post-legislative scrutiny of FOI, a useful resource has been made available on the Save FOI website. The written evidence was originally published in one, rather overwhelming, pdf document.

If you head over to the Save FOI website, the Resources section now has a page listing all the organisations and individuals who submitted evidence with links to their individual submission.

While you’re there, do please have a read of Tim Turner’s excellent post explaining how changes to FOI could leave local authorities more accountable than central government and the NHS because they will still be subject to the Environmental Information Regulations.

February 20, 2012

Why 2012 is the year to Save FOI

Filed under: Amendments,Freedom of Information Act,Save FOI Campaign — FOIMan @ 7:21 am

Today (Monday 20th February), a group of us are formally launching a new campaign. As the title of this post suggests, we are campaigning to #saveFOI.

This week sees the beginning of the long heralded post-legislative scrutiny of FOI promised by the Coalition Government last year. On Tuesday morning, the first witnesses, including the head of the Campaign for Freedom of Information, Maurice Frankel, will be appearing before the Justice Select Committee.

Last week the Committee published the written evidence that it has received. What is striking about this evidence is how many public authorities have called for restrictive amendments to the Freedom of Information Act. Some have called for charging to be introduced. Some have suggested that the cost limit for answering requests should be brought down, so that more demanding requests can be refused. Others have even suggested bringing in whole new exemptions for information that they hold.

This comes hot on the heels of comments from the outgoing Cabinet Secretary Lord Gus O’Donnell who has been openly critical of the Information Commissioner’s decisions in respect of Cabinet minutes. Others will be aware that our former Prime Minister Tony Blair considered himself a “nincompoop” for introducing FOI. There have been plenty of others queuing up in recent months to add their voices of complaint to the chorus of disapproval of this legislation, only 7 years after it came into force.

It is hard to think of another requirement on public bodies that attracts such venom and open hostility. And these views are diametrically opposed to the views of most people outside the public sector who welcome this important tool for holding public authorities to account.

Even some inside Government are suspicious of the motives of the Act’s government critics. The Minister responsible for FOI in the Ministry of Justice, Lord McNally, commented in a recent House of Lords debate that:

“…when Prime Ministers and mandarins object, this Act might actually be doing something that it was intended to do.”

And yesterday, writing in the Observer, the Information Commissioner himself made it quite clear where he stands. He dismissed Lord O’Donnell’s criticisms, and dispensed with suggestions from universities that they need a whole new exemption for research data.

Nevertheless, the mood music suggests that there is a desire to contain this young legislative upstart. Some of us even inside the public sector feel very strongly that to do so would be a backwards step. Yes, some individuals abuse the right to access information. Some requests are expensive to answer. It can feel personal when a request affects your work. But the overall benefits, whilst difficult to quantify in hard numbers, far outweigh the problems. It has forced public authorities to open up in a way that would have been unimaginable a decade ago. It has allowed groups from protesters against library closures to disability rights campaigners to make their case to Government on something approaching an equal footing. It has exposed unfairness and inequality in our country. I believe it is starting to make an impact on the effectiveness and efficiency of some public authorities. In short, it makes the UK a fairer country to live in.

And the UK doesn’t exist in isolation. Countries across the globe are adopting FOI legislation. As Nigeria and the Philippines debate the opening up of their governments, is it right that the UK can be considering reducing the rights of its citizens?

So we are standing up to make the case for FOI this year. And we want as many people as possible to join us. So please take a look at our campaign website and consider how you can help us to #saveFOI.

February 13, 2012

Is Michael Gove’s email held by DfE?

Filed under: Definition of held,Freedom of Information Act — FOIMan @ 8:36 pm

FOI Man considers whether an email from the Secretary of State for Education to several colleagues is held by the DfE for the purposes of FOI.

In the Autumn of last year, Chris Cook, the Education correspondent of the Financial Times, broke a story which is of interest to FOI watchers everywhere. He had uncovered evidence suggesting that the Education Secretary, Michael Gove, and special advisers in the department, had been using private email accounts to conduct Government business. The suggestion was that this was being done to avoid the emails coming to light through FOI.

The story has led to an investigation by the Information Commissioner, new guidance from the Commissioner, and questions in Parliament. And Chris himself has proved tenacious in pursuing this story.

For their part, the Department for Education and Mr Gove himself have argued that they had been following Cabinet Office guidance (though Cabinet Office responses to FOI requests have suggested that if such guidance existed, it was not written down), and that the emails themselves related to party political business, and were therefore not held by DfE.

Chris has been at an advantage in this matter. He already had the emails before he made his FOI request, so knew what he thought he should have received. When they weren’t all received, he complained to the Information Commissioner. That investigation is ongoing.

Today, Chris has published one of the emails that DfE insist is “party political” on his FT blog. I’ve studied this email.

There are certainly aspects of the email that are party political. It talks about Labour’s record in negative and explicit terms. You wouldn’t expect a Minister to write to a civil servant in that way.

But here’s the rub. One of the recipients was a civil servant. If civil servants are supposed to be politically neutral, why would you copy one in on a party political email? I’ve never worked in a Ministerial Office or even a government department, so I can’t be sure, but it seems odd.

And there are aspects of the email that sound rather more like departmental business. It discusses communications planning, apparently for the Department rather than the Conservative Party. It asks for information about his Ministerial diary.

It seems to me that parts of the email at least relate to departmental business.

What does the Information Commissioner’s guidance say about this issue? It lists the factors to consider when deciding whether email in a private account relates to Government business:

  • the focus of the request, indicated by the words used by the requester;
  • the subject matter of the information which falls within the scope of the request;
  • how the issues to which the request relates have been handled within the public authority;
  • by whom and to whom was the information sent and in what capacity (e.g. public servant or political party member); and
  • whether a private communication channel was used because no official channel was available at the time.

There doesn’t appear to be any dispute over the focus of the request – if the email is departmental business, it’s covered by the request. We have little knowledge of how such business would normally be carried out, but surely communications planning for DfE is normally a departmental matter. We do know that the information was sent by the Secretary of State for Education, and the recipients were his Special Advisers (who admittedly have an ambiguous role, but are based in the Department), and a civil servant (to their private email address presumably, but nonetheless significant). We can’t know for sure why this channel was used.

A Tribunal decision last year looked in detail at whether information was held by a university, and I think that some of their observations in that case are relevant here:

“The effect of this subsection [s. 3(2) FOIA] is to confirm the inclusion of information within the scope of FOIA s1 which might otherwise have been arguably outside it. The effect of paragraph (a) is that information held by the authority on behalf of another is outside s.1 only if it is held solely on behalf of the other: if the information is held to any extent on behalf of the authority itself, the authority ‘holds’ it within the meaning of the Act. The effect of paragraph (b) is that the authority ‘holds’ information in the relevant sense even when physically someone else holds it on the authority’s behalf.”

The judge who reviewed the case when it was appealed to the Upper Tribunal was very clear that in his view “held” had its normal English meaning. It shouldn’t be over-analysed:

“A key feature of the FOIA regime is the need to balance the interests of the requester and the public interest in the free flow of information with the legitimate interests of public authorities and third parties.  Moreover, that balance is struck not by over-complicating the simple factual concept of whether information is “held” by a public authority – rather, it is achieved by the matrix of absolute and qualified exemptions and the application, where appropriate, of the public interest test.”

(for a fuller analysis of this case, read what barrister Robin Hopkins of 11KBW had to say about it).

My reading of this is that if in doubt, the information should be considered to be held by the public authority. It might still be withheld using exemptions, but it has to be considered. I believe there is enough doubt in the case of the email the FT has published to suggest that it should have been dealt with as though held by the DfE. And the lawyers that Chris has consulted all agree.

Of course, that doesn’t mean that the Secretary of State was deliberately attempting to avoid FOI. But it does raise more questions about the DfE’s interpretation of the Act.

Why promptly might not be as prompt as all that

Filed under: Environmental Information Regulations,FOI Officer,Freedom of Information Act — FOIMan @ 12:34 pm

FOI Man explains why responses to even the simplest FOI requests may take a little while to reach you

The length of time that it takes public authorities to answer an FOI request is one of the most common complaints about FOI. A quick glance at the decision notices relating to timeliness of responses on the ICO website is enough to confirm this.

And sometimes requesters make a point of stressing in their request that they should receive a response within 20 working days. Sometimes they go even further. They remind us that they should receive a response “promptly”.

In FOI, section 10(1) requires that a response is sent out “promptly, and in any case within 20 working days”. The EIR equivalent at regulation 5(2) calls for a response “as soon as possible and no later than 20 working days” after the request was received.

So what exactly does “promptly” or “as soon as possible” mean? Well, as I explained in a post last year, the Information Commissioner does accept that public authorities have to balance their responsibilities. So it doesn’t mean that everything else will be dropped to answer your request.

Depending on how the authority manages requests, and for instance, how many requests they receive, there could be lots of responsibilities to balance. Even the people directly responsible for answering FOI requests – people like me – can have quite a few things to juggle.

A few months ago I featured a guest post here, where another FOI Officer highlighted the struggle they had to keep on top of FOI requests at a time of diminishing resources. And whilst I can’t claim to be struggling quite as much with my FOI workload (touch wood), I have a range of other responsibilities.

As well as FOI, I am also responsible for, in no particular order – compliance with the Data Protection Act, Privacy and Electronic Communications Regulations and copyright licensing requirements, records management, student complaints and student disciplinaries. Oh, and the official archives.

I’m not complaining – variety is the spice of life, so they say. But perhaps you can see why it might take us longer than you feel it should to answer even the simplest requests. Sometimes they just have to form an orderly queue.

February 6, 2012

FOI requests via Twitter – a Supreme problem

Filed under: Freedom of Information Act,Procedures — FOIMan @ 2:28 pm
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FOI Man looks at whether FOI requests can be made via Twitter, and concludes that it just isn’t a very good idea.

Earlier today, the UK’s Supreme Court started to use Twitter to much excitement (well, a little, and mostly from lawyers and geeky-types like me). Their first Tweet directed Twitter followers to their Twitter policy, available on the Supreme Court website.

Personally I was impressed that the Supreme Court actually had a Twitter policy. But the stirrings in my Twitter-stream were not about that. No, some of you were concerned about a short statement half way down the page:

“Sending messages to our Twitter feed will not be considered as contacting the Supreme Court for any official purpose (including the administration of cases or Freedom of Information requests).”

Oh dear. The thing is, this goes against advice provided by the Information Commissioner’s Office last year. After some deliberation, they came out with a statement saying that as long as the name of the Twitterer was clear (perhaps in their profile), and the information requested was clear, a Tweet could be a valid FOI request. And I agree with their analysis.

This all comes down to the definition of a request at section 8 of the FOI Act. To be valid, a request has to be in writing; it must provide the name and address of the requester; and it must describe the information that they are looking for. That’s all. It’s long been accepted that you could in principle make a request via text message. It’s not much of a stretch therefore to say that the same applies to Twitter.

In short, if someone does make a valid request to the Supreme Court via their Twitter address, and they ignore it, the requester could complain, and the Information Commissioner could slap them on the wrists for not complying with the Act. So their statement is pretty meaningless. And of course, because they’ve said it, there are now people up and down these isles submitting requests that they wouldn’t have done if the statement wasn’t there, just to prove a point.

My view on this is that using Twitter to make an FOI request is generally a waste of everybody’s time. Of course you can make a request through that route. But why? Firstly, it’s not the easiest thing to fit a request into 140 characters – there are ways round that (eg links), but if you’re going to link to another document why don’t you just use email in the first place? Secondly, if, like the Supreme Court, the authority clearly isn’t geared up to receive requests through that route, the chances are that your request won’t be seen. So then you complain. Well, woopy-doo (I believe I may have invented a new utterance of celebration, but bear with me) – you’ve successfully caught the authority out. But you haven’t got the information you wanted. So who wins here?

Somebody made the excellent point that it’s not a massive job to instruct whoever is maintaining the Twitter feed that they might get FOI requests and to be on the look out for them. That’s absolutely true. But in practice, most authorities probably aren’t aware that requests can come through that route. Jonathan Baines blogged last year about one surprising authority that didn’t seem to be (I promise you, you’ll love this, if you haven’t heard about it before). Also, even those of us who are aware – is this really a priority amongst the many messages that we want to get out to colleagues about FOI (and other things)? I have mentioned it to the people in my authority who maintain official Twitter accounts (and mine isn’t one before you unleash a thousand Tweets in my direction, those of you of a mischievous disposition – @foimanuk is a personal account), but I’m pretty sure that they will still be surprised the first time that it happens (that being the point – it’s still a very unusual thing to do).

And let’s be clear. There are lots of ways to make a valid FOI request that would most likely get you nowhere. In theory, next time your bins are being emptied, you could hand a written note to your waste collection operative, and as they’re providing a service for the council, that would arguably count as an FOI request. Good luck with that.

I’ve got no problem with FOI requests being made in any format or via any media in principle. Some authorities are very good at adjusting to new technologies and providing new ways for the public to interact with them. But many aren’t so good, or have limited resources to support additional communication portals. Is there really any point in sending a request through unusual media if the likelihood is that the authority won’t see your request?

Postscript, Tuesday 7 February

Shortly after I published this post on Monday, the Supreme Court Communications team tweeted the following, addressed to myself and Andy Mabbett, who Tweets as @pigsonthewing, (and who had first alerted me to the Twitter Policy):

“@pigsonawing [sic] @foimanuk Fair point! We’ll accept FOIs via Twitter and will amend our policy accordingly.”

And true to their word, the statement in their policy now reads:

“We would prefer to receive Freedom of Information requests via email or letter, in order to assist us in giving them a full response, but we note the Information Commissioner’s Office guidance on the validity of Twitter as a channel for receiving such requests and will handle them in accordance with that guidance.”

A swift and sensible response to the points raised, and it reflects well on the Communications team at the Supreme Court. Let’s hope there will be more moves towards openness in our court system. For more on that, I do recommend Adam Wagner’s post from earlier today.

February 2, 2012

Post-Legislative Scrutiny – My submission

Filed under: Amendments,Freedom of Information Act — FOIMan @ 10:30 pm

FOI Man sums up what he told the Justice Select Committee as they prepare to carry out their post-legislative scrutiny.

Tomorrow, Friday 3 February, is the deadline for submissions of evidence to the Justice Select Committee for their post-legislative scrutiny. After days of writing – and rewriting – my despatch, I finally sent it off on Tuesday. Hopefully many of you have written to say how important you think FOI is, and why.

The rules of the Committee mean that I’m not allowed to publish my full statement here without permission – I’ve asked the Clerk of the Committee to allow that. However, in the meantime I can summarise the key points I made. Most of this won’t be a surprise to regular readers.

Fundamentally, I think the FOI Act is a brilliant piece of legislation. It’s introduced a right to know that now seems an important part of our democracy; and by and large I think it balances this right with the need to ensure that public services can be run effectively.

It’s met all of its objectives to some extent or another – the Ministry of Justice had already put forward plenty of evidence of FOI making the public sector more open and transparent; I also pointed out how it was allowing campaign groups to engage better with decision makers. I argued that it was almost certainly improving decision-making; and I put forward a defence against suggestions of a “chilling effect”.

The limits of cultural change within the public sector was one of my key themes. I pointed out that whilst senior figures such as former Prime Ministers and Civil Servants were openly and aggressively attacking the legislation, it was always going to be difficult to win people over. In future these attacks need to be aggressively countered from within Whitehall if FOI is ever going to become embedded in our organisations and its full benefits felt.

And linked to that, we can’t ignore those who make requests irresponsibly. The requesters who submit the same request to hundreds of public bodies; the people using the Act to pursue their personal vendettas; and others who don’t understand that the way they use FOI will affect whether it survives. I’ve proposed a Code of Practice for requesters – an FOI “highway code” to promote good practice amongst those using the Act – rather like my Guide to Making FOI Requests. I’d rather see education than litigation used to manage issues with FOI.

I don’t want to see transparency go backwards in the UK. I’ve called for any changes to be subject to a transparency impact assessment, and I’ve also asked the Committee to bear in mind the commitment the current Government has made to transparent and open public services.

I want to see more proactive disclosure, and public authorities encouraged to introduce Disclosure Logs if they don’t already. But I agree with those who think that Publication Schemes are unnecessary to make this happen. I’ve also suggested statutory reporting on compliance and asking requesters to say when they are making a request under FOI. And I’m very keen to see the limitation on prosecution under s.77 of the Act extended beyond the ridiculous 6 months that it stands at now.

Finally, I’ve argued against changes to the fees regulations. I fear that the changes that some have suggested could limit legitimate and reasonable research, so I hope this won’t be a change put forward by the Committee. If there must be changes, let’s focus them on those who use the Act irresponsibly – I think the restrictions on vexatious requesters are probably adequate as they are, but perhaps they could be clarified and maybe linked to the “Code of Practice” I suggested above.

Fundamentally, now is not the time for change. At this time of economic uncertainty, when Government and public services are making difficult and challenging decisions, the scrutiny that FOI offers is needed more than ever. Let’s hope the Committee’s post-legislative assessment reaches the same conclusion.

 

January 28, 2012

Evidence to the Post-Legislative Scrutiny

Filed under: Amendments,Freedom of Information Act — FOIMan @ 12:14 pm

FOI Man reminds readers of recent blog posts that you might find of use if you are submitting evidence to the Justice Select Committee’s Post-Legislative Scrutiny of FOI

The deadline for submitting evidence to the Justice Select Committee’s Post-Legislative Scrutiny of FOI is this coming Friday, 3 February. If like me, you are spending this weekend preparing your submission to the inquiry, here are a few recent posts from this blog that you might find useful if you’re looking for inspiration. If you’re not, you might find them of interest anyway!

My FOI Wishlist – Part I

My FOI Wishlist – Part II

2012 – The Battle for FOI

What do FOI Officers think about FOI?

Remote Ivory Towers or engaged with the modern world? Universities must decide

Should Cabinet papers remain in the closet

To give and not to count the cost

If you are preparing your submission to the Committee, good luck!

To give and not to count the cost

Filed under: Amendments,Charging,Freedom of Information Act — FOIMan @ 12:10 pm

The following is a piece I wrote recently for a print publication but in the event it wasn’t used. I’m publishing it here for your interest, and in case it is of use to you in preparing submissions to the Post-Legislative Scrutiny.

This year FOI is going to be subject to more scrutiny than it has for a long time. Whilst the Coalition Government has pushed for more proactive publication of information, there have been hints that there are some voices at least within the Government that are keen to clip the wings of the general right of access.

In summer last year the Liberal Democrat Minister responsible for FOI in the Ministry of Justice gave an interview in which he highlighted the pro-openness initiatives of the Government. These included the changes in the Protection of Freedoms Bill, the moves made to force local authorities to publish details of expenditure over £500, and the consultations on widening the coverage of FOI to more authorities. He also announced a post-legislative review of the Act. One of the areas that he suggested should be looked at by the review was the cost of compliance with FOI.

Well, here we are 6 months later and the House of Commons Justice Select Committee is calling for evidence for the post-legislative review. The Ministry of Justice has already submitted a memorandum to the Committee setting out its key concerns with the Act, as well as the areas that it is broadly satisfied with. Unsurprisingly, the headline feature of the memorandum is a call for the committee to look at the fees regulations for FOI.

Section 12 of the FOI Act allows a public authority to refuse requests above an “appropriate limit”. The “appropriate limit” is set out in The Freedom of Information and Data Protection (Appropriate Limit and Fees) Regulations 2004 (2004 No. 3244). These allow authorities to refuse requests where the cost of carrying out certain activities is estimated to exceed £600 in central government departments or £450 in other public bodies. The activities referred to are:

  • determining whether information is held;
  • locating information;
  • retrieving information; and
  • extracting information from a document containing it.

The Ministry’s memorandum cites the views of a number of FOI practitioners. The view apparently prevailing amongst those surveyed is that the existing fees arrangements are inadequate to control a growing flood of FOI requests to their public bodies. They propose that the limits of £450 and £600 be lowered. Alternatively, or in addition, the suggestion is that reading, redaction and consideration of requests (perhaps including consultation with third parties and deciding whether exemptions should apply) should be included in the cost estimate. Both would mean that public authorities would be expected to spend considerably less time on answering FOI requests, and would be able to refuse many more of the requests that they are currently obliged to answer.

This isn’t the first time that the fees regulations have been looked at with a view to reducing the burden on public authorities. In 2006 – 7, the Labour Government consulted on a very similar proposal. It was eventually dropped (following the parallel furore over MPs attempting to remove themselves from the Act) by the incoming Prime Minister, Gordon Brown.

Many FOI Officers would welcome such a change. Even more of their colleagues would. It has been interesting to see a series of articles appearing in the media over the last month or so listing the “wasteful” and “trivial’ FOI requests which are a “drain on resources”. In the last year, local authorities have called for requests to be charged for, and in some cases, public bodies frustrated with the Act have taken it upon themselves to charge even though they don’t have the power to.

The Ministry has commissioned research to estimate the cost of answering FOI requests. For the previous government, Frontier Economics concluded that the cost to the public sector of answering FOI requests was £35 million in 2005. This time, in addition to the MoJ’s research, individual sectors are consulting on cost. JISC, the higher education central information service, is carrying out a survey of universities’ handling of FOI requests to support the HE sector’s arguments to the committee. There seems to be a determination to demonstrate how costly the general right of access can be.

The concern over cost is understandable in the current economic uncertainty. As one FOI Officer told the MoJ:

“It’s counterintuitive to impose a greater burden on a public body at the same time as you reduce its ability to deal with it”.

But we should be cautious before we rush to join the calls for changes to the fees regulations. Firstly, any change along the lines that have been proposed will substantially reduce the access to information currently available to anyone. If we believe in a right to information, surely we should be nervous of making such a change. Some individuals are disturbingly enthusiastic about curbing people’s rights in this area.

Secondly, there is very little agreement on how reliable figures on the cost of FOI can be arrived at. Last year one council concluded that answering requests had cost it £346,000 in 2009-10. But this was based on all received requests costing the maximum £450. Other estimates, including Frontier Economics’, have been similarly questionable. There are still no reliable or agreed measures for calculating the true cost of FOI.

Thirdly, it is worrying that the focus is purely on how much FOI costs. There has been very little attempt to establish how much FOI saves the public sector each year. Those savings are very hard to quantify. There are the savings that come from public employees and politicians taking more care over spending public money. There are the errors picked up as a result of FOI requests that shine a light on sections of the accounts that might otherwise have slipped by unnoticed. There are the efficiencies suggested by outside observers who might not otherwise be in a position to do so.

But beyond all the focus on cost, perhaps we’re missing the bigger picture. FOI is being used in all sorts of ways, by all sorts of people. It is part of a whole new way of engaging with government. We should consider carefully before encouraging those in power to curtail it, even in seemingly minor ways.

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