The ICO exists to empower you through information.

ICO comment: what this case study means

This case study demonstrates how support from senior leaders can help tackle delays in responding to requests. This includes requests which require a high level of sign-off before a response can be issued. It also highlights the benefits of streamlining processes, formalising procedures, and clarifying roles and responsibilities to increase the level of accountability for FOI. We recommend reading this case study along with our short guide on internal consultations.


There had been an increase in the volume of requests being issued after FOI deadlines. The Trust escalated this to their Audit and Risk Committee, and the Committee requested action at executive director level. The Trust shared an overview of request themes and trends with the Committee, highlighting business areas where there were frequent delays in providing data to the Information Rights Team (IRT).

Staff identified that senior colleagues lacked awareness of FOI requests until sign-off stage. This caused delays in responding to requests within statutory FOI deadlines. A lack of accountability by senior managers was a further issue causing delays. Nominated FOI representatives (FOI Reps) usually provided the requested information in relevant business areas. They were quite often junior staff. However, when queries arose about the quality of the information provided, there was often no clear escalation point or senior manager identified. In addition, when requests were escalated, these were usually reviewed by multiple senior managers or executive directors who had no prior involvement with, or knowledge of, the request.

To improve the Trust’s performance, they needed:

  • a better way of tracking a request allocated to business areas; and
  • awareness of the request and responsibility for signing off the response, including overall accountability.


The Trust redesigned their FOI process in the following ways:

  • The IRT used data on themes, trends and response times to produce weekly reports for the executive directors.
  • They provided data in a more streamlined manner across business areas and considered whether a type of data needed further validation and checks.
  • They introduced a four-stage approach to handling requests (allocation, awareness, validation and approval) to make the FOI process more joined-up at all levels.
  • They introduced a standardised procedure for recording requests, establishing consistent phrases and key words.
  • They reviewed and updated their internal and external email templates, to make these clear and concise for both staff and requesters.
  • They introduced a deadline of 12 days for relevant business areas to provide them with data.
  • They updated and reviewed the FOI Reps’ list, to include contact points for each business area or topic, and to increase awareness of requests. They also included the wider service area, in order to identify the relevant executive director from the outset.
  • All executive directors were then given the option to approve the response once the IRT received the data. This enabled the directors to provide support to staff, including senior leaders, from the outset, rather than at the end of the process.
  • Finally, the Trust introduced weekly and monthly calls with key FOI Reps to ensure they addressed any queries in a timely manner.


The Trust has achieved a positive impact in the following areas.

A good organisational culture around FOI

Executive directors now actively engage with the IRT. They feel more confident approving FOI responses, since they’re aware of the request from the point it was allocated to their service area.

Sign-off and weekly reporting enabled the Chief Executive to understand the types of information the public was seeking from the Trust. This level of engagement has gradually improved the response rate to requests. The Trust has also prioritised and cleared its backlog.

Increase in the level of accountability for FOI

The reduction in performance against FOI deadlines enabled the IRT to re-engage not only with the FOI Reps but also with senior management. Highlighting the challenges that staff were facing in locating and collating information has led to greater accountability, at all levels, for responding to FOI requests in a timely manner.

Quality of responses and efficiency

The quality of FOI responses has also improved. There are fewer queries at the point of drafting a response, as these are picked up and worked through with support from managers and, where necessary, the executive director.

When a request is complex, the Trust can act quickly to ensure the FOI Rep is supported and any information is validated before it’s sent to the IRT.

Extended benefits

The Trust is now looking at sourcing a software product to assist in recording better FOI data. They hope to use the data to support proactive publication. They’re also exploring how best to publish all FOI responses.

The wider FOI community has also recognised the Trust’s work. The Information Rights Manager at the Trust was nominated for FOI Practitioner of the Year at the eCase FOI awards 2023.