The ICO exists to empower you through information.

How to use this report

You can download this report as a Word document using the button on the top right corner of the page. The report contains a template for an action plan, which we suggest you complete. If you have an problem downloading the report into a word document please let us know.

You may find it easier to complete the report if you change the page orientation to landscape and turn on table gridlines (for more information, please see the help section of your word processing program).

Alternatively, we have created an Excel action plan template for you to complete. This consists of a list of the performance areas and a drop down menu where you can reflect the below ratings. We have added additional columns for you to populate that we think will help you make an actionable plan for improvement.

The action plan is intended to be a working document. It can be customised as appropriate for your public authority. If you:

  • receive an unsatisfactory rating, you must put an action in place and prioritise it;
  • receive an adequate rating, you should put an action in place to improve but this action should not be prioritised over actions relating to unsatisfactory ratings; and 
  • receive a good rating, you should review the area to understand if further improvements can be made or what is required to maintain this performance.

Try not to focus effort on resolving symptoms; tackling symptoms may only move the problem from one place to another. Instead, identify, and put actions in place to mitigate or remove the root causes of the issues.

When devising improvement actions, we recommend you involve decision makers and people who will implement the actions. Your action plan should be agreed at a sufficient level of seniority with assigned responsibility for its delivery.


19 April 2024

  • 2: Good
  • 4: Adequate
  • 0: Unsatisfactory

Your overall rating is Adequate.


Q Question Rating Reason for rating Root cause of issues or success Action Delivery owner Due date
1 The way in which you identify whether the specific requested information is a trade secret is…


2 The way in which you identify the commercial interest in the specific requested information is…


3 When relying on sections 43(2) and 43(3), the way in which you identify the link between the specific requested information, or the request itself, and the harm or prejudice to commercial interests is…


4 When relying on sections 43(2) and 43(3), the way in which you identify the level of the likelihood (ie "would" or "would be likely to") of harm or prejudice is...



The way in which you identify specific public interest arguments is…



The way in which you identify when to rely on the neither confirm nor deny exemption is...



Suggested actions

  • Identify the commercial interest in the requested information.
  • Identify the appropriate level of likelihood of prejudice to the commercial interests.
  • Identify public interest factors in favour of, and against, upholding the exemption you've relied on.
  • Repeat this module within a suitable timeframe to monitor progress and improvement.


What next

You should monitor delivery of the action plan.

Once actions have been completed you could take the relevant module again to establish whether the actions have improved performance and review whether further action is needed to ensure continuous improvement.

We recommend that you share your report with relevant colleagues and other similar public authorities who may learn from it.

In the interests of openness and transparency, we recommend that you publish your action plan.

Thank you for using our FOI self-assessment toolkit. Please consider leaving feedback to help us improve the toolkit.

Next: Other considerations