Introduction
We are committed to promoting transparency and openness to help build public trust in how we operate, and we will make information available where it is lawful, appropriate, and reasonable to do so.
Aim
The aim of this policy is to ensure we meet our obligations when receiving requests for information under the Freedom of Information Act (FOI) 2000, the Environmental Information Regulations (EIR) 2004, and the UK General Data Protection Regulation (UK GDPR).
Scope
This policy applies to all recorded information including official documents, drafts, emails, notes, and audio and video recordings, held by us or on our behalf.
Roles and Responsibilities
To ensure the effective management and compliance with our obligations, the following roles and responsibilities are defined:
Customer Information Service
The Customer Information Service acts as the operational hub to ensure that requests progress through the statutory process in a timely and consistent manner.
This includes:
- receiving, logging, and acknowledging all incoming information requests
- carrying out initial validation to confirm request type, scope, and statutory deadline
- coordinating and chasing service areas for timely provision of information
- maintaining the central case management system and audit trail
- issuing standard communications and updates to the requester throughout the process
- escalating delays or non-responses to managers where required
Information assurance team
The information assurance team provides corporate oversight, guidance, and assurance relating to information rights. Responsibilities include:
- being the policy owner
- being the first port of call for information rights support and advice
- supporting service areas in interpreting the request, considering the legislation, and applying good practice
- advising on the application of exemptions, exceptions, redaction, and decision making thresholds
- supporting colleagues who are undertaking internal reviews and responding to data protection complaints
- leading awareness, training, and education to ensure staff understand their obligations
- supporting risk assessments and escalation processes where necessary
- being the single point of contact for the information commissioner’s office
Legal Services
Legal Services will provide the following:
- support service areas, the Customer Information Service, customer relations team, and the information assurance team by providing legal advice in interpreting the legislation and statutory guidance
- advice on complex requests involving legal privilege, contractual disputes, litigation risk, or significant corporate impact
- support the assessment of public interest tests and high-risk exemptions and exceptions
- provide legal review where disclosure may affect ongoing legal proceedings or regulatory processes
- support the handling of FOI/EIR complaints to the ICO, appeals, and potential litigation
- ensure the council meets its legal obligations while protecting its legitimate interests
Service areas (information asset owners and decision makers)
Service area responsibilities include:
- identifying, retrieving, and supplying all relevant information within agreed deadlines
- ensuring the completeness and accuracy of the information provided
- highlighting any concerns or sensitivities, including potential exemptions
- responding to points relating to the information’s content and meaning
- owning the request and ensuring requests are dealt with in a timely manner and in line with our obligations
- ensuring that local record-keeping practices support compliance with statutory information rights
- ensuring proportionate and reasonable searches are carried out in response to a request
- taking ownership of all disclosure decisions, including the application of exemptions or exceptions, as the accountable decision makers for the information they hold
- undertaking internal reviews, where appropriate, whenever a requester expresses dissatisfaction with the outcom
- ensuring information that falls within scope of the ICO model publication scheme is proactively published or otherwise made available as a matter of routine