Skip to main content
Home

Hampshire and Isle of Wight Healthcare NHS Foundation Trust: Strengthening FOI accountability and ensuring compliance

The trust contacted us after reading our blog on successes and setbacks in the health sector. They benchmarked their compliance rates against the statistics included in the blog and found they were above average. They offered to share how they achieved this.

ICO comment: what this case study means 

When organisational change happens, it’s an opportunity to establish a culture that supports FOI compliance. Secure senior staff backing, create an internal network to share responsibility, and embrace proactive disclosure.

Situation

The trust was established in 2024 by merging Southern Health NHS Foundation Trust and Solent NHS Trust. It also took on community, mental health and learning disability services from Isle of Wight NHS Trust, and Hampshire CAMHS services from Sussex Partnership NHS Foundation Trust. The Trust now serves 600,000 patients each year and employs 18,000 staff.

The legacy organisations handled FOI requests differently. This led to fragmented processes, unclear responsibilities, and risks of delays or inappropriate releases. When the Trusts merged, the FOI team was reduced to one full-time staff member. However, the number of requests increased by about 50%.

Solution

The team reviewed their working methods and found several issues:

  • Inconsistent processes inherited from legacy organisations.
  • No defined roles for collating, approving, and signing off responses.
  • No clear escalation pathway as deadlines approached.
  • Services were not fully engaged in the FOI process, causing delays.
  • Absence of a publication scheme and disclosure log.
  • A need for proactive management of frequently requested information.

They took steps to address these issues.

They set up a strong accountability framework, supported by senior management. FOI oversight is now part of directorate-level governance. Performance is reported monthly and updates are given to the Audit Committee.

Each service appointed one or two senior FOI links to coordinate requests and work with the FOI officer. These individuals ensure timely, complete responses and represent their service in FOI matters. The information access team support frontline colleagues with data collection where necessary. When patient care needs to be prioritised over information rights compliance, accountability is shared so both needs can be met.

Escalation methods now include email and MS Teams chats. Using Teams, which is less formal, helps build stronger relationships and makes the FOI team more approachable. Automated reminders are sent 10, 5, 3, 2 and 1 day before deadlines.

They introduced a publication scheme and disclosure log. Additionally, the team reviews recurrent requests every quarter, along with making a more general assessment of what the public seems to be interested in across all services. Then they publish information, including FAQs, to meet those information needs. They have found that proactive publication reduces duplicate requests, enables section 22 exemptions, and improves transparency.

Impact

Strengthened service engagement and clear escalation and accountability mechanisms have established a culture of openness and shared responsibility. As a result, the Trust’s compliance rate is now 97%.

Further reading