Other considerations report
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.
Please note that question 5 of this module (timing of the request) 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.
Question 1: Your proactive publication of less sensitive commercial information is ...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 2: Your consideration of requests without reference to the requesters' identity or motives is ...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 3: Your consideration of whether the request is for environmental information is ...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 4: Your consideration of how confidentiality clauses interact with your FOIA obligations is …
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 5: Your consideration of the effect of the timing of the request is...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 6: Your consideration of whether requests about sole traders could also be for their personal information is ...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Question 7: Your consideration of appropriate advice and assistance is...
Rating | Reason for rating | Root cause of issues or success | Action | Delivery owner | Due date |
---|---|---|---|---|---|
Suggested actions:
- Proactively publish information that is no longer sensitive.
- Consider the request without reference to the requester's identity or motives unless you're permitted to do so under FOI.
- Consider whether the request is for environmental information.
- Ensure that confidentiality clauses do not conflict with your FOIA obligations.
- Assess the sensitivity of the commercial information at the time of the request, not when it was produced.
- Consider whether requests about sole traders also constitutes their personal information.
- Provide advice and assistance to requesters whenever possible, including directing them to relevant alternative information.
- Repeat this module within a suitable timeframe to monitor progress and improvement.
Further reading:
- What is environmental information?
- Guidance on regulation 12(5)(e) commercial or industrial information
- What information do we need to publish?
- Duty to provide advice and assistance
- Guidance on outsourcing and your FOIA obligations
- Section 46 - code of practice, records management
- Charging for information in a publication scheme
- Consideration of the applicant’s identity or motives
- What is personal data?
- Section 40 and Regulation 13 – personal information
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.