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FOI Fest skills session #2: Q&A

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The session begins with a discussion on the personal approach to making Freedom of Information requests, specifically whether to use the public platform WhatDoTheyKnow or submit requests privately. Martin explains that while he highly regards WhatDoTheyKnow as an excellent resource for researching existing requests and learning the correct terminology used by authorities, he personally prefers to keep his own requests private to maintain full control over the process. He notes his secretive nature leads him to handle inquiries individually rather than publicly. Another audience member shares a similar sentiment but asks if there is a way to submit requests privately first and then publish them later; this is not currently possible on the platform, as the system requires a request to be filed through WhatDoTheyKnow to verify its legitimacy and ensure that responses have not been tampered with. The conversation then shifts to whether filing a request publicly versus privately influences how authorities respond or handle the inquiry. While some research suggests that public requests might yield better results, panelists note that experiences vary significantly across different organizations. Some authorities may feel compelled to provide more context in their responses when they know the information will be published online, whereas others treat all requests identically regardless of the filing method. There is also a complex dynamic regarding how authorities perceive FOI requests; some view them as antagonistic, while others, particularly journalists, are often given extra explanatory details because it is assumed they will report on the findings. The panel acknowledges that while publicizing complaints can generate public discussion and support, the actual administrative handling of the request by the authority remains largely consistent. A significant portion of the Q&A addresses the validity and practicality of submitting FOI requests via social media, as well as the challenges surrounding disclosure logs. Although the Information Commissioner's Office (ICO) has ruled that social media submissions are legally valid, experts advise against using this method due to character limits that prevent detailed explanations and the risk of requests being overlooked. The discussion also highlights a major hurdle in encouraging public bodies to maintain disclosure logs, which are records of information already held by an organization. Many authorities, including police forces and NHS trusts, have abandoned or never adopted these logs because they fear inadvertent disclosures could lead to worse consequences than simply responding to individual requests. While some councils like Barnet found that comprehensive logs reduced the volume of repetitive requests by clarifying what information was available, many others remain skeptical, believing that publishing more data will only stimulate more inquiries rather than reduce them. In conclusion, the session underscores the tension between transparency and the administrative burdens faced by public authorities. Although there is a clear expectation for organizations to publish significant decisions, the development of universal disclosure logs has been slower than anticipated due to concerns about workload and potential liability. The panelists express a collective desire to see a central repository where disclosure logs from various authorities, such as the Scottish Government, could be aggregated to improve public access to information. Ultimately, while platforms like WhatDoTheyKnow facilitate transparency and community support, the reality of FOI work involves navigating varying institutional attitudes, legal constraints, and the practical difficulties of encouraging consistent record-keeping across different sectors.
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Welcome to FOI Fest 2026. [music] Let's start with one online, which is to you, Martin. Which is, do you make requests publicly on WhatDoTheyKnow, or mostly privately? >> Answer honestly, it's okay. >> So, I always make my requests privately rather than use WhatDoTheyKnow because uh I like to have my own complete personal control over the process. Uh I have to say, I do think WhatDoTheyKnow is a wonderful thing. It's a great resource. I look at it all the time. And it's very, very useful from the point of view of seeing what requests have been answered already. Uh very useful, often I think, to get the right phraseology of a request. Um is to see the phraseology, the jargon, the terminology the public authority has used itself in the past. I find it particularly useful for that reason. Uh but um when I make a request, I've got to say I, personally, am really secretive, and I just do it myself. >> Brilliant. Thank you. Uh do you have any questions in the audience? We do indeed. >> Uh hi. This is actually uh I'm also very secretive, so I also do them myself. But, I was wondering uh because I also use WhatDoTheyKnow as a kind of way of figuring out like like Martin, what's already been done. It helps me shape my requests and everything. And so, to give something back, I I I would Is there a way for me to then give you my requests afterwards after I've I've had my way with them? >> So, unfortunately not at the moment. Um you've got to have to make your request on WhatDoTheyKnow for it to appear there. The reason for this is mainly so we can kind of prove that this request did come from an authority, not that we've just uploaded some, you know, random information. You know, we don't without it being made and the process going through WhatDoTheyKnow, we can't really prove, you know, whether that whether the information released or the responses were, you know, modified in any way. Um and just on the complete privacy point with the um privacy period, you can always keep extending that privacy period if you wish um and on WhatDoTheyKnow. [snorts] >> Um so, I was just curious. I've always wondered if you've seen a difference in when in FOI requests being filed individually versus what they know because obviously what they know is exposed to they know it's being filed through what they know, so they know it's going to be public afterwards. Um, and I was wondering if that has any impact on whether you've been filing them privately because you're worried about that. Um, also the same question to the what they know team. Do you are you aware of requests being handled differently because they're being filed through what they know? >> Well, I can't answer that directly, but a lot of people publish via WhatDoTheyKnow because they want to publicize their request and their complaint to other people. Uh, there's often, you know, very angry comment by the poster and so on and it's impossible to see that that makes any difference to, you know, to the authority. They will just deal with the request in the same Well, I assume in the same way as they would if it came through email individually. >> Yeah, if I could just say from my point of view, I not really noticed that there is any particular It might be the case that authorities, cuz it's going to be on WhatDoTheyKnow, think, "Okay, we've got to put this bit of context in order to explain what the answer is because we know anybody could read this." But sometimes they if you're a journalist request, they will add that kind of bit of context anyway cuz they think you're going to report it and they want you to use that extra bit of information. So, I can't say that I have noticed a difference in that regard. >> We're definitely aware of some research which suggests that requested in public does get better responses. Um, but yeah, I'm sure there are lots of different um ways that individual public authorities might perceive a request in public versus a private request. I think someone mentioned earlier that sometimes FOI can be seen as a little bit antagonistic. Um, so you know, I think some people do feel that as well. So, I think it's a complex area. >> Yeah, Stuart, isn't it? From Privacy Laws & Business. Um, two points. So, when I was working with Consumer Association many years ago, it was very active in the Freedom of Information field. So, simple question is, is Consumer Association still active? Second question is, the ICO says that if people are making a subject access request under the Data Protection Act, organizations should realize that people might um apply for free sorry, Data Protection access via social media. Today, we've In the original old days, it was always letters. Then it was now it's all emails. But, do organizations actually accept a Freedom of Information requests via social media? >> Uh yeah, so on the second point, uh organizations certainly are meant to accept requests via social media, and there have been cases where the ICO has ruled um that a request made via social media is a valid request. Uh from my point of view, it's not a sensible way to make an FOI request because you've got character limits, you can't really explain everything in detail. Uh and it may well easily be missed and not treated as an FOI request. So, it's it's not a sensible way to make an FOI request, um but it is a legal way to make an FOI request. Uh and I think the people who are doing it were basically doing it largely to prove a point. Uh I don't know the answer to the first question, Morris, do you? >> So, that the first question, information not held is the I'm afraid the response to that. >> On disclosure logs, uh is there a way that we can encourage organizations to have disclosure logs in Norfolk? The police, who were criticized by the ICO, no longer have one. Our integrated care board doesn't have one. The NHS trust don't have one. And most of the councils don't have one that is publicly available. >> Uh so, um I thought there would be much more of a development of perhaps even a universal development of disclosure logs than there has turned out to be. And there's been quite a few examples of authorities actually and the hospital in Norwich is one example of this from many years ago having their own disclo- disclosure logs and then dropping them. And talking to FOI officers, what they say to me about it is it's a it involves a lot of work. They weren't consulted very much. They were hoping that people would look at the log before they put in their FOI request and it would save them time from that point of view. And actually request is don't do that. And also organizations like police, I know from talking to police FOI officers, are worried about if they make a mistake in this inadvertent disclosure of information to an FOI request which has happened. If they put it on a disclosure log, the consequences are worse than if they've just sent it off to one individual requestor. So, the police were certainly adopting a policy of trying to stop local forces from having disclosure logs for that reason. So, I think there's a number of reasons why they haven't developed in the way that I did actually think that they would. >> I mean, I think the direct answer is there is no obvious way of persuading a public authority that doesn't want to have a disclosure log to have it. It's described as good practice. Um we were asked to do some consultancy work for the MOJ years ago about the case and the impact of it, which we did and it's not gone beyond that. Uh The the the expectation is that authorities will publish significant decisions, not all decisions. Um but if you look at Barnet, we looked at a few years ago, were publishing very comprehensive disclosure logs and they calculated that it had a significant impact on the number of requests they received about council tax and parking, which were levels of high FOI requests. Um the combination of the disclosure log and the data sets they published, they calculated led to a something like I can't remember what it was, a 30% 20 or 30% drop in the expected number of FOI requests in those areas. So, there is an issue of self-interest where it may benefit the authority. They never believed that when you told them if you publish more information, it will reduce the number of requests because authorities say the more you publish, the more requests you will stimulate. But actually Barnet found that wasn't the case. >> Thanks. I just goes back to the the point about um recording other requests. Um I know for example Scottish government, all their FOI requests are published online. I'm just wondering is there a a central repository that Is anyone collecting these in a central way that you anyone is aware of and are there other authorities are doing it? >> Oh, so is anyone uh like collecting a central archive of disclosure logs, for example? Uh not that I'm aware of, but I would love to see it happen. I've It's a thought I've had of can we do this on What They Know, but >> Well, Maurice, Martin, Julia, and Gareth, thank you very much indeed. >> Hello to our most completest listeners. 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