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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

  • 3: Good
  • 4: Adequate
  • 0: Unsatisfactory

Your overall rating is Adequate.


Please note that question 4 of this module (logical connection between disclosure and harm) is weighted to reflect the importance of this factor. This may result in a different overall rating to the same combination of answers in other modules.

Q Question Rating Reason for rating Root cause of issues or success Action Delivery owner Due date
1 The way you consider whether you could release the requested information or any part of it is...


2 The way you consider whether requested information is a trade secret is ...


3 The way you consider whether there is a commercial interest in the requested information is ...


4 When relying on sections 43(2) and 43(3), the way you consider whether there is a logical connection between the requested information and the likely harm or prejudice to commercial interests is ...



When relying on sections 43(2) and 43(3), the way you consider the likelihood of harm or prejudice (ie "would" or "would be likely" to prejudice) to commercial interests is…



The way you consider the balance of the public interest is…



The way you consider the neither confirm nor deny exemption is…



Suggested actions

  • Assess whether any part of requested information can be disclosed.
  • Link the identified harm to commercial interests to the disclosure of the information you've withheld, or to revealing whether requested information is held. Avoid making generic arguments.
  • Consult with third party organisations where applicable.
  • Carry out a balanced public interest assessment giving appropriate weight to both the factors in favour of, and against upholding the relevant exemption.
  • 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.

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