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ICO comment: what this case study means

This case study shows one of the benefits of proactive disclosure of information. It’s quicker to direct someone to publicly-available information than it is to provide an individual copy of that information every time someone asks for it. The case study also shows that informal, business as usual (BAU) responses can be a quick and effective way of dealing with information requests. Organisations just need to ensure it does not result in any lowering of standards in the time taken to issue the response or in the quality or amount of information provided.


The London Borough of Camden takes a forward-thinking approach to issuing responses to requests as “business as usual.”

Camden issue prompt replies without the formality of a full FOI response when:

  • they can direct the requester to publicly-available information; or
  • when information is readily available and disclosable and it appears that a BAU response would satisfy the requester.

They do this even when a requester specifically cites that they are making their request under the Freedom of Information Act (FOIA).

Camden’s BAU responses begin:

“Thank you for your request. We are dealing with this as a routine request rather than formally as a Freedom of Information Act request so we can provide you with a faster and less formal response…”

and close with:

“…this doesn’t remove or affect your rights under the Freedom of Information Act. So if you’re unhappy with this reply for any reason please let us know. We will then have a look formally under the Act and send you a formal reply within 20 working days of your original email.”

Camden’s starting point for handling BAU responses is to check their previous FOI responses via their Open Data Portal. They then check other records available through the portal. If they have not already proactively disclosed the requested information, the staff handling requests liaise with relevant departments to check if the information is readily available and if they can provide it as BAU.

This approach allows Camden to issue straightforward responses to sometimes complex requests for information. Camden is satisfied that, by doing this, they are in line with ICO’s guidance, which states that:

“The Information Commissioner’s Office (ICO) recognises that some public authorities may initially respond to questions informally, but we will expect you to consider your obligations under the Act as soon as it becomes clear that the applicant is dissatisfied with this approach.”

ICO guidance also states:

"In many cases requests may be dealt with in the normal course of business provided this does not result in lower standards (eg disclosing less information, or taking longer to deal with the request)."


BAU responses now make up a significant amount of Camden’s annual FOI traffic.

For the last two full financial years, Camden has received over 1800 requests, and has closed nearly 30% of them as BAU.

Camden’s informed estimate is that a typical BAU response takes 10 minutes. If they issued those requests with full FOI formal responses, Camden estimate that they would take around 30 minutes. This means that they save around 20 minutes per BAU response.

Issuing 500 BAU responses – as Camden did in 2020/21 – saved 160 hours, which is nearly five working weeks. This frees up time for staff to concentrate on other FOI requests.

Requesters benefit from a very fast reply. Most requesters get a response within three working days, and a significant amount receive it the same working day.

Of course, it is very important that if people wish to have their request handled under FOI, Camden respect their rights. They must issue a response within the statutory time frame, dated from the initial receipt of the request.

Only two requesters have asked that Camden treat their BAU response as a formal FOI response instead. Camden have received no complaints from requesters about their approach to BAU disclosure, and instead receive regular praise for their fast replies.

Camden’s approach to BAU works well because they have invested in proactive disclosure. When public authorities make information readily available to the public, it becomes quicker and easier to handle information requests.