House of Commons - Post-legislative scrutiny of the Freedom of Information Act 2000

Post-legislative scrutiny of the Freedom of Information Act 2000 - Justice Committee Contents

2 The objectives of the Act

11. Drawing on the White Paper which preceded the Freedom of Information Act as well as debates and speeches in Parliament, the Ministry of Justice's Memorandum on Post-Legislative Scrutiny of the Freedom of Information Act 2000 (the Memorandum) identified four objectives for the Act: openness and transparency; accountability; better decision making; and public involvement in decision making, including increased public trust in decision making by government.[19] In research examining the impact of the Act, the University College Constitution Unit teased out a further aspect of this final objective: better public understanding of government decision-making.[20] The Constitution Unit also divided the objectives into primary and secondary aims, as Dr Ben Worthy, from the Unit, told us:

The two core aims were to increase the transparency of Government and to increase accountability. Flowing from them were another four secondary objectives, which were to increase public understanding, to improve the quality of decision making, to improve public participation and to improve public trust.[21]

The expectation of a new culture of openness and transparency

12. Reactive openness, where a public body responds to a request for information, and proactive transparency were two avowed aims of those bringing in the freedom of information legislation. During the Second Reading of the Freedom of Information Bill in December 1999, Jack Straw MP, told the House that the Government anticipated a widespread culture change as a result of the new statutory right to access information:

Unnecessary secrecy in Government and our public services has long been held to undermine good governance and public administration [...] the Bill will [...] help to transform the culture of Government from one of secrecy to one of openness. It will transform the default setting from "this should be kept quiet unless" to "this should be published unless". By doing so, it should raise public confidence in the processes of government, and enhance the quality of decision making by the Government.[22]

13. The Act sought to create the new culture by providing both the statutory right to access information held by public authorities contained in section 1 and imposing a duty on every public authority to develop and publish a proactive publication scheme, subject to approval by the Information Commissioner.[23] We will consider the impact of these two approaches in turn.

Openness

14. The Act covers a very wide variety of public authorities, including central and local government, NHS organisations, publicly-funded universities, regulators and organisations with unique public functions such as the Association of Chief Police Officers. Unsurprisingly, the Act appears to have varying degrees of success in encouraging a culture of greater openness and transparency in different types of public body. There was agreement from both those using the Act and those responding to requests that central Government was now more open. Alexandra Runswick of Unlock Democracy told the Committee: "the Government are certainly considerably more open and transparent than they were before the Freedom of Information Act."[24] David Hencke, Senior Investigative Journalist for ExaroNEWS who appeared before us on behalf of the National Union of Journalists, told us there had been an enormous change, evidenced by the now routine publication of information that previously was a closely-guarded secret, such as releasing information on the gifts given to the Prime Minister:[25] "Things that were secret at the beginning of the 21st century are now routine and available for the public to find out."[26] The Rt Hon Lord McNally, Minister of State, Ministry of Justice and Deputy Leader of the House of Lords, observed: "When I started working in Whitehall and Westminster over 40 years ago, there was still a culture of the man in Whitehall knows best. I do not think that is true anymore."[27] Lord Hennessy of Nympsfield agreed: "I am pretty Pollyanna-ish about the world that you are examining. Compared with the one when I was a young journalist on The Times, it is almost cornucopic in its openness for all the problems and the bumping and grinding. It is a different world."[28] The Society of Editors told us: "The Act has become an essential journalistic tool which has helped create a climate of genuine openness and transparency in British public life."[29] The London Evening Standard agreed: "there is no doubt that the advent of the Freedom of Information Act has significantly improved transparency, accountability and good governance in British public life."[30] Our witnesses suggested that the change was not wholesale, however. Martin Rosenbaum of BBC News, among others, said: "There has been a change in culture, but I think that that change is still partial and inconsistent and has a long way to go."[31] Mr Rosenbaum suggested that this partial openness related to the type of information being sought:

Characterising the sort of information that the Act now enables us to obtain on a very crude level, you will now find that it is much easier to get facts and figures—how much was spent on this, statistics about the performance of public services and so on. The sorts of things that were harder to get previously now tend to be very easy to get, but what it has not produced, and the civil service is certainly very resistant to this, is internal discussion, documents, policy discussion, minutes of meetings and so on.[32]

We discuss the complex issues surrounding the publication of policy documents in Chapter 6.

15. At local government level, Kent County Council said: "The Act has definitely forced traditionally secretive cultures to become more transparent [...] Within KCC, there [...] is an acceptance that no longer can business be conducted "behind closed doors".[33] Dr Ben Worthy, of the UCL Constitution Unit, agreed the Unit's research showed greater openness in providing information at local government level, although this inevitably varied between different councils, a fact reflected in the evidence given by some of the individual contributors to the inquiry.[34] Witnesses from the media were less inclined to identify a greater culture of openness among councils than the councils and academics. Ben Leapman, of the Sunday Telegraph, thought change had been partial at local as well as central Government level: "FOIA has brought important benefits for the public, by lifting, in part, the veil of secrecy over the affairs of central and local Government."[35] The Kent Messenger Group among others suggested that changes to governing structures in local government meant that, despite the Act, councils were becoming "more secretive"[36] overall:

FOI has been particularly useful in holding local councils to account in the context of the introduction of cabinet government (LGA 2000) which many journalists believe has diminished the flow of information and allowed authorities much greater control over the flow of information about executive decisions.[37]

David Higgerson, Digital Publishing Director of Trinity Mirror Regionals, who appeared before us on behalf of the Newspaper Society, agreed that structural changes in a variety of public bodies made the Act a valuable tool:

[...] most councils have adopted opaque 'cabinet style' structures, many health bodies have done away with public meetings when gaining 'Foundation Trust' status, and police forces are reluctant to release even basic details about their work, FOI has proved invaluable.[38]

16. Public authorities in other sectors thought the Act had increased openness. Liverpool Heart and Chest Hospital NHS Foundation Trust believed: "The Act works well in principle and widely supports the openness and transparency agenda [...]. This can only be beneficial for public accountability and an assessment of efficient use of public resources, services and finances."[39] Portsmouth Hospitals NHS Trust said that the Act "has facilitated a much more open public sector culture."[40] Of the many submissions from the higher education sector none addressed the issue of whether the Act had encouraged openness within the sector; however, Professor Ian Diamond, Vice-Chancellor of the University of Aberdeen, Chair of Research Policy Network, Universities UK, told us that, while he emphasised universities had already had a culture of openness, the Act had had the effect of improving record keeping.[41]

17. The Memorandum concluded that "the Act has become a vital element in opening up Government [...] [and] has resulted in disclosure of significant amounts of information which might otherwise have gone unreleased."[42] We agree with the Ministry of Justice that the Act has contributed to a culture of greater openness across public authorities, particularly at central Government level which was previously highly secretive. We welcome the efforts made by many public officials not only to implement the Act but to work with the spirit of FOI to achieve greater openness. Our evidence shows that the strength of the new culture of openness is, however, variable and depends on both the type of organisation and the approach to freedom of information of the individual public authority.

Transparency

18. While closely related there is a clear distinction between reactive responses to requests for information and the proactive publication of data, commonly referred to as transparency. The first puts the power in the hands of the individual seeking to be informed: he dictates the parameters of the information he is seeking and, subject to exemptions and cost, the public authority will provide him with what he asks for. Proactive transparency means that the body publishing the data controls what is published and the format in which it is released.

PUBLICATION SCHEMES

19. The duty to produce proactive publication schemes in section 19 of the Act is supplemented by extensive guidance from the Information Commissioner's Office on model publication schemes.[43] It was generally agreed that proactive publication had the potential to reduce the need for freedom of information requests and WhatDoTheyKnow told us it could "forestall significant numbers of requests",[44] however, there was some debate about whether the publication scheme approach was the right one, and how extensive the benefits of proactive publication could ever be.

20. Dr Ben Worthy told us that the primary reason why publication schemes were under-used was technological change:

[...] one of the reasons why publication schemes have not taken off in the way that many had hoped is that it has been superseded by the internet search engine and the fact that people can find a way of asking a question rather than looking for the information. I do that myself in all sorts of circumstances, and I am not sure that much can be done about it except to ask people to flag up the information.[45]

Professor Trevor McMillan, Pro-Vice Chancellor for Research, Lancaster University and Chair of the 1994 Group Research and Enterprise Policy Group, agreed: "things like the publication scheme have been slightly bypassed by search engines on the web. It is probably easier to put a request into a search engine than it is to go through formal documents."[46] Roger Gough, Cabinet Member for Business Strategy and Support at Kent County Council, described the publication scheme approach as "fairly antiquated."[47]

21. The Information Commissioner told us that publication schemes had the potential to save public bodies time and money but were not necessarily done well:

We have done a lot of work on the model publication scheme that public authorities should be running for proactive disclosure and for making clear on their websites where information can be found. It is a bit rich to have public authorities saying, "We are assailed by unreasonable freedom of information requests", when they do not have an adequate publication scheme, they have not got their act together in terms of records management and have a rotten website and so on.[48]

The Commissioner also emphasised the importance of his enforcement powers in the area of publication schemes:

If you have a recalcitrant local authority [...] the Information Commissioner has the power to enforce the publication scheme, which goes beyond the exhortation of Whitehall to be open.[49]

Mr Graham told us that the ICO is currently carrying out a consultation on the publication scheme approach.[50]

22. Witnesses representing the media agreed that good publication schemes were useful because information could be accessed without the expense and delay of a FOI request. David Hencke gave us an example: "I was checking a salary with the Cabinet Office. It just said that it was in the public domain and I did not need an FOI. It saves a lot of money. It points you to the press office. If they provide a good publication scheme, in some ways it reduces the need for FOI."[51] Mr Hencke agreed publication schemes could cut down on journalistic 'fishing exercises' where large numbers of public bodies are contacted for the same piece of information but could not think of a good example of a publication scheme for us to consider.[52] WhatDoTheyKnow noted along with other witnesses that publication of information may also produce limited benefits as it can "often [be] hard to actually locate" it on public authorities' websites.[53] Doug Wills, Managing Editor of the Evening Standard, i, Independent and Independent on Sunday, agreed that publication schemes could provide inadequate data:

If you use Birmingham City Council as an example, we could probably go through the press office to ask a question. If you are a member of the public looking through the city council's spending, it will tell you the name of the vendor and the amount spent, and it will give you the incredibly helpful invoice number, but it will not tell you what it was for. If you wanted to know how much the council was spending on grit, you would have to know who supplied grit out of all the firms across 200 pages on a spreadsheet. In Birmingham City Council's case, it says that, if you want to ask any questions about this data, you have to put in a freedom of information request.[54]

23. Tracey Phillips, a solicitor advising on freedom of information at Lambeth Council, was positive about the likelihood that greater transparency would lead to more rather than fewer FOI requests:

[...] publishing more information on our websites takes extra resource internally within service areas to decide what information they are going to publicise and also why that information might be useful. We have the agenda going forward to publicise more open data—raw data—so that it can be interrogated. That is going to take some resource internally but it will be for the better. I do envisage FOI requests coming on the back of that.[55]

Ms Phillips suggested that the publication scheme approach would be enhanced if the Information Commissioner's Office could provide more guidance as "it is quite broad ranging in terms of what they say should go in the publication scheme, but if they could be a bit more prescriptive on defining specific information, that would help us somewhat."[56] Paul Gibbons thought the publication scheme approach was "outdated" and suggested: "A list of information that authorities are required to make available would be more useful, without stipulating where the information should be placed on the authority's website."[57]

24. Professor Hazell told us that the findings of the UCL Constitution Unit showed that the type of information requested by individuals often focused on "micro-politics"[58] and matters such as "allotments, parking and the quality of the roads"[59] which meant that proactive publication only had a limited impact on the volume of requests:

[...] you asked whether it would help reduce the volume of FOI requests if public authorities proactively published more information. That is intuitively plausible, but I think it is unlikely to help significantly to reduce the burden because [...] the extraordinary variety of FOI requests and the variety of motives make it terribly difficult for authorities to guess the sort of things that requesters might want.

25. Professor Hazell suggested that disclosure logs were one of the best ways for public authorities to maximise the benefits from proactive publication:

The most that they can do, and some of them do this, is to publish on their websites what are called disclosure logs. They publish lists of all previous requests, and you can click on them and find out what the request was and what information was disclosed; it is, as it were, a back record of things that people have asked us.[60]

This avoids the difficulty identified by Helen Cross, an individual user of the Act, where the passage of time leads to repeat requests for updated information on the same topic.[61] Julian Brookes, of NHS South of England, told us that his organisation used the detail of FOI requests not only to proactively publish information which was the subject of interest but also to consider how it was presented:

There are lots of things now where we can judge, from the basis of regular freedom of information requests and so on, where it is really important for us to be consistent and accurate in the way in which that information is portrayed. Wherever possible, we also apply the test that, if this is something that is consistently being asked for, we will put that into the public domain. We will extend around the scheme of publication that we would have and standards that we expected.[62]

26. The relationship between publication schemes and the wider transparency agenda is somewhat unclear. The Government has made increasing transparency a priority. In the Foreword to the Coalition Agreement, the Prime Minister and the Deputy Prime Minister declared: "we will extend transparency to every area of public life."[63] Lord McNally told the House of Lords that:

The transparency agenda is about much more than historical information; it is about much more than government records in the traditional meaning of the phrase. It is about the information and data that we deal with day to day to inform our decisions and provide our public services. Making that information available is what makes the transparency agenda truly revolutionary. More information than ever is being published proactively by this Government. In excess of 7,500 datasets have been made available to increase accountability, empower the public and foster innovation and economic growth [...][64]

27. Local government, in particular, has been subject to a number of measures involving the release of information since the Act was passed. Some witnesses questioned the efficacy of certain measures. Kent County Council told the Committee that publishing the cost of every item of expenditure over £500 was resource-intensive:

Due to the constraints of KCC's financial database which was not designed for this purpose (KCC hasn't got the spare £millions to replace or update), it costs approximately £120 a month plus dozens of hours of officer time to redact and prepare data for publication [...] in the 16 months since this information has been published on our website, there have only been 3000 visits to this webpage [including] internal [...] hits, it is questionable whether publishing this information is actually value for money [...][65]

28. Edward Hammond, of the Centre for Public Scrutiny, told us that complaints like that of Kent County Council arose from the lack of a truly joined-up approach between the freedom of information regime and the transparency agenda: "Although there is an increased drive for transparency coming from central Government, it is not [...] a particularly coherent drive. There are different drivers coming from different directions. It makes it very difficult for local authorities to respond in anything other than a reactive way."[66]

29. Two of the Ministers from whom we heard accepted that the relationship between the freedom of information regime and the transparency agenda was important to both. Lord McNally emphasised the complementary effect of the two approaches: "The transparency agenda, by its very nature, is what we want to tell you; the FOI Act is what you want us to tell you. They are not totally overlapping in that respect, but they can exist side by side."[67]

30. The Rt Hon Francis Maude MP, Minister for the Cabinet Office, told us that Government was aware of the need to 'join-up' the two policy streams:

[...] the agendas are very closely linked. Are we perfectly joined up? No. Are the Government ever perfectly joined up? No; nor will they ever be, but we work pretty closely together. Tom and I are giving evidence together. Tom sits on the transparency board, which I chair, which is driving forward the transparency agenda. The two agendas probably originate in different places, but they need to be seen very much as a single range of issues.[68]

31. While proactive transparency clearly has the potential to reduce the burden of responding to information requests on hard-pressed public authorities, the proactive publication of data cannot substitute for a right to access data because it is impossible for public bodies to anticipate the information that will be required. Nevertheless, proactive publication is important in achieving the primary objectives of the Act of openness and transparency.

32. Government must ensure that the freedom of information regime and the transparency agenda work together to ensure best value for money. Individual initiatives in different departments must be examined before implementation in the light of existing policy to see whether they constitute the most effective approach. Equally, existing initiatives should also be assessed after a period of time to ensure they both offer value for money and have not produced unintended consequences.

Has the increase in openness and transparency increased accountability?

33. The evidence we heard suggested that greater access to public information has led to an increase in accountability. Dr Ben Worthy told us that the Constitution Unit had found that the Act "has made local and central Government more transparent and more accountable—transparent not only in terms of the information provided but in fostering a more open culture and it has improved accountability."[69] Professor Hazell agreed that Government accountability had been increased.[70] The National Union of Journalists thought the Act made public bodies more accountable and the Society of Editors agreed.[71] Representatives from NHS organisations also thought accountability had been improved.[72]

34. The Information Commissioner noted that the increase in accountability through the Act had the potential to be undermined if the freedom of information regime did not apply to private providers of public services.[73] We consider this issue in depth in Chapter 8.

Secondary objectives

INCREASING PUBLIC CONFIDENCE IN PUBLIC AUTHORITIES

35. The Memorandum found that the objective of increasing public trust and confidence in Government, Parliament and other public authorities may have been unrealistic because, as found following research by the Constitution Unit, the vast majority of people experience freedom of information through news stories and these are more likely to be negative in tone than otherwise.[74] However, the Memorandum also noted that "the very existence of the legislation gives [the public] some confidence that public authorities have little to hide behind. They know they can be scrutinised and this of itself tends towards a different relationship between public authorities and the public."[75] These conclusions reflected the evidence we heard on this issue. The Constitution Unit told us that its research showed the Act had had "no generalisable impact on trust."[76]Maurice Frankel, of the Campaign for Freedom of Information, told us he saw an increase in trust among those who directly sought information from public bodies rather than the majority who experienced the fruits of the freedom of information regime through the media.[77] Doug Wills noted that the existence of the Act meant distrust arising from the inability to obtain data was less likely to arise: "If the information was not available, then there would be distrust. That is positive in itself."[78] Martin Rosenbaum thought that it was not reasonable to expect the Act to increase trust in itself; greater trust and confidence was always going to be dependent on the information uncovered:

The Act enables people to know more, and what they discover as a result may or may not increase their trust. There are obvious reasons why it has not increased their trust in Parliament. There are very clear reasons for that. It is not the fault of the Act that there has been a failure to increase trust. The point of the Act is to give people more information. Whether it improves their trust levels or not is not something to hold at the door of the Act.[79]

David Hencke agreed that the information uncovered by a freedom of information request was a substantial factor in whether the Act contributed toward greater public trust noting: "Parliament did not do itself any favours over the expenses business when, in the preamble to it, someone put up a Private Member's Bill that was trying to exempt Parliament from freedom of information [...]"[80]

36. As the Memorandum notes, however, the information published following a freedom of information request and reported in the media is more likely to "identify deficiencies in decision-making or inefficiencies in spending decisions" than it is to be positive. This reflects the evidence we heard from a number of public authorities that they frequently respond to requests from journalists that do not result in news stories.[81] Scrutiny and criticism of those in power is part of the constitutional role of a free press. The fact that irregularities, errors and deficiencies will usually be more newsworthy than the revelation a public body is operating appropriately and efficiently is inevitable. It can, however, have the unfortunate consequence of encouraging secrecy rather than fostering a culture of openness. Lord O'Donnell, former Cabinet Secretary, told us:

If you are open, you get criticised for the things that you are open about. I had an interesting example myself [...] I decided to release, since I am not paid by anybody at the minute but I am a Member of the Lords, some hospitality information. I do not think anybody else does that. Surprise, surprise, you get a snidey press story in Private Eye as a result of this.[82]

Such outcomes, Lord O'Donnell concluded, constituted a "perverse incentive" to keep information secret, a conclusion he noted had also been reached by former Prime Minister Tony Blair in his autobiography.[83] Francis Maude MP agreed that the relationship between openness and trust was not straightforward but said, "Can [openness] lead to embarrassment? Yes. Do we have to be a bit grown up about that? Yes, we do."[84]

37. Our evidence on the impact of the Act on trust generally agreed with the findings of the Memorandum. Whether the Act will contribute to an increase in public confidence in the Government, Parliament and other bodies is primarily dependent on the type of information which is published following a request. The majority of people will receive information published under the Act through the media. Evidence of irregularities, deficiencies and errors is always likely to prove more newsworthy than evidence that everything is being done by the book and the public authority is operating well. In these circumstances, the expectation of a substantial increase in public trust following the introduction of the Act was always going to prove unrealistic.

38. Greater release of data is invariably going to lead to greater criticism of public bodies and individuals, which may sometimes be unfair or partial. In our view, however this, while regrettable, is a price well worth paying for the benefits greater openness brings to our democracy.

IMPROVING THE QUALITY OF DECISION MAKING

39. Our evidence showed that assessing the impact of the Act on improving the quality of decision-making is highly complex. We will consider the achievement of this objective in Chapter 6.

INCREASING PUBLIC UNDERSTANDING OF DECISION MAKING AND THE OPERATION OF AUTHORITIES

40. The Memorandum noted that the Information Commissioner's Office tracker survey found a 54% to 87% increase in the proportion of people agreeing that "being able to access information held by public authorities increases your knowledge of what they do" between 2004 and 2010.[85] The question whether the Act had actually had an effect on public understanding of Government decision making was explored by the Constitution Unit in its major piece of research on whether the Act had achieved its objectives.

IMPROVING PUBLIC PARTICIPATION IN DECISION MAKING

41. As the Memorandum notes, Lord Falconer told the House of Lords that one objective of the Act was "to show citizens how government works—and to show them how decisions are taken."[86] The Constitution Unit, while noting this objective had the fewest mentions in the documents surrounding the Act,[87] found that public participation in decision-making had not been greatly improved in central Government because:

First, many requesters are using FOI in a professional capacity, as journalists or campaigners, rather than as ordinary citizens. Second, a number also use it to non-political ends or private purposes. Finally, FOI is used by people already engaged in the political process, rather than bringing new participants into it.[88]

Moreover, FOI faces the same obstacles of lack of interest, apathy and disengagement that face all the varying attempts to promote wider engagement. Rather than FOI shaping political engagement, pre-existing conditions towards disengagement hinder the impact of FOI.[89]

42. We received limited evidence on the achievement of this objective. Paul Gibbons, author of the FOIMan blog, also thought that the use of the Act by campaigners showed improved public participation in decision-making:

One recent example was the campaign by disability campaigners against the Welfare Reform Bill currently before Parliament. The campaign used responses to the Department's consultation on the Bill, obtained through an FOI request, to produce a report which was then widely circulated through social media and other mechanisms.[90]

One of our witnesses described a cultural change in his sector which was influenced by rather than a direct consequence of the Act. As noted above, Julian Brookes told us:

We have certainly seen improvements in the way in which our records are kept and accountability and decision making. It is partly to do with the Freedom of Information Act but also partly to do with what I would describe as a change in culture in terms of how we operate in the NHS in regard to our decision making. There is increased engagement of key stakeholders in decisions we make, particularly, for example, on service change. The greater awareness that the Freedom of Information Act has brought to those discussions has led to a good and accurate recording of the issues.[91]

43. Having received limited evidence on the impact of the Act on increased public participation in decision making, we would not seek to disagree with the findings of the Constitution Unit that this objective has not been achieved, at least in central Government. We welcome, however, the suggestion that, while the Act may not have had a direct impact on increasing public participation in decisions made in the NHS it has assisted in a move towards a culture of greater public involvement.

Understanding of the Act

REQUESTORS

44. The primary aim of the Act was to create a statutory right to access information. The Rt Hon Jack Straw MP told the House of Commons:

The Bill [...] lays down for the first time in our constitutional history that the public have a right to know about the work of Government and all other public authorities.[92]

45. Lord Hennessy put it another way: "Even the most difficult fruit cakes in the United Kingdom have rights when it comes to FOI, which is as it should be."[93] The then Government's intention that the Act should create a universal right to access public information was not, however, appreciated by many of our witnesses. We heard a large number of complaints that the Act was being used by people for whom it was not intended. Complaints focused on journalists,[94] commercial enterprises,[95] individuals pursuing purely private agendas[96] and individuals with frivolous requests.[97] These complaints misunderstand the intention behind the Act. While we examine whether the Act should continue to be used in all these ways in Chapters 3 and 5 below, the use of the Act by many different groups of people should be regarded as a facet of the universality of the right to access information, not a failure of the Act.

MISUNDERSTANDING THE ACT

46. The NHS Business Service Authority recognised that misunderstanding of the Act had an impact on how it was viewed:

The benefits have taken time to be realised as requesters and public authorities have developed their understanding of it. Clearer central guidance, as provided under the Cabinet Office transparency agenda, would have meant faster realisation of the benefits.[98]

Throughout this inquiry we have borne in mind the potential for misunderstanding of the Act being behind some of the criticisms we have heard rather than genuine flaws in the current regime.

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