The Trust was nominated for the Rising Star award at the eCase FOI awards 2023. The ICO helped to judge the awards. We’re keen to share examples of practice that other public authorities can learn from, so we’re publishing this case study.
ICO comment: what this case study means
A well-designed triage system and resources like templates can speed up request handling. Making sure senior staff are informed keeps them engaged and can pre-empt problems and identify opportunities. Step-by-step guides can also assist colleagues in developing a general understanding of FOIA requirements. In general, good FOI practice requires a strong network of informed staff working across an organisation.
Triage and request handling
For the 2022/23 financial year, the Trust received 622 FOI requests and a single EIR request.
For the purposes of handling FOI requests, Wye Valley splits the trust into divisions. The majority of divisions have established a point of contact. They either answer questions directly or can refer the request to relevant staff within the division. The level of seniority of staff in the network varies across areas, but it is usually managers that send across information to the team.
Central request handling staff regularly check and challenge responses provided to ensure that they are accurate. They also check that staff are applying exemptions correctly.
Staff report compliance figures to the Trust’s monthly information governance committee. They also provide these figures to heads of divisions. This allows the Trust to:
- recognise any problems in good time;
- identify trends in requests; and
- consider opportunities to address patterns of requests by proactively disclosing datasets.
When the team receives a new request, they create an email folder. Any emails sent or received about the request go into that folder.
A logbook tracks open requests. This is a simple spreadsheet that tracks deadlines – not only the deadline for issuing a final response, but also internal deadlines about the request’s handling. For example, when someone refers a request to another team, that team works to a 10 working day deadline. The logbook also tracks which other team or department is dealing with the request, the date of most recent correspondence and its current status.
The Trust also holds a contact log spreadsheet, detailing which division or person to get in touch with to answer certain types of requests.
Managers have regular access to the logbook stats, to consistently inform them of the Trust’s FOI position. The Trust plans to start proactively publishing the logbook’s compliance figures.
Due to the volume of requests the Trust receives, they have decided that this method suits their needs. They do not need to spend money on a casework system that outstrips their level of demand.
Guidance, templates and training
The Trust has two sets of guidance. One is for team members who formally process FOI requests, and one is for general staff who answer questions about requests and provide information which falls under the scope of a request.
The guidance for team members takes the form of an FOI process manual. The manual goes through the process of handling a request step by step. It highlights information sources the Trust holds that are useful for request handlers, like their log of past responses.
They have templates for various common responses, which staff can adapt to suit the response. They have a generic S.12, S.21, S.22 and S.40 (ii) template. This speeds up the process of replying, but also sets out the expected structure of a request. This prompts staff to gather and outline the relevant information required to set out the reasoning behind applying an exemption.
The manual includes checklists that explain what information a case handler needs to hand in order to apply an exemption. They have a specific checklist for the application of S.43.
For staff who are not handling requests day-to-day, the Trust has a step-by-step poster. It explains the difference between an FOI request and a subject access request. It also explains which members of staff people should pass requests to, if they receive one. Additionally, the Trust has a general FOI FAQ on their intranet.
Impact
In 2022, Wye Valley NHS Trust had a compliance rate of 71%.
As of March 2023, following the introduction of their new triage system, they were at 95%.