Freedom of Information Policy

Roles and responsibilities - FOI Policy

Oxford City Council’s Monitoring Officer (Head of Law & Governance) holds lead responsibility for the management of information requests.

Delivery of managing information requests is the role of the Information Governance Team specifically:

However, managing information requests is the responsibility of the whole council as set out below.

Lead OCC officer for information requests management, acting as the Council’s Qualified Person
Owner of FOI policy and procedures
Lead officer for Information Commissioner’s Office (ICO) complaints and notices on behalf of the Chief Executive
Escalation officer for Information Governance Team
Escalation in the event of FOI non-compliance by services or other significant issues

End to end management of all OCC FOI requests received including internal reviews, in accordance with statutory timeframes
Council’s point of contact for requester, managing correspondence including updates, clarification questions, advice as required and responses
Council’s point of contact for FOI complaints received by Information Commissioner and lead for co-ordinating responses
Management of information requests case management systems and procedures and related staff training
Liaising with and advising services on FOI requests (including Internal Reviews and ICO complaints), including the application of exemptions and redactions
Escalation of non-compliance by services or matters of concern to Service Head / Head of Law & Governance
Identifying any contentious issues emerging from requests and flagging to Heads of Service, Executive Directors, Press Office and Elected Members (if necessary)
Management of Disclosure Log and Publications Scheme
Production and publication of FOI data including performance, trends, any emerging issues and dissemination to Senior Management (CMT) and Members
Maintaining OCC FOI webpages

Lead council representative for Information Commissioner’s Office (ICO) complaints and notices (delegated to Monitoring Officer)

Oversight of FOI requests / responses escalated to Internal review or Information Commissioner complaint level for their directorate, providing guidance where necessary
Escalation leads in the event of FOI non-compliance by services or other significant issues

Oversight of all media FOI requests and responses providing advice where necessary
Advisor on draft responses to requests considered politically sensitive (delegated to Communications Manager)

Oversight of service area requests received and outcomes
Review of service area performance reports (digest emails)
Identification of two lead officers for handling FOI requests and liaising with Information Governance team (Service Information Officers)
Checks on services responding to FOI Requests Officer/Information Governance team requests within timeframes (as notified by Information Governance team)
Advise on any contentious or sensitive issues
Monitor service area FOI training levels and enforce uptake

Via the designated Service Information Officers, co-ordinating collation of available information and providing / advising if information unavailable to FOI Requests Officer as requested within deadlines, working in line with agreed procedures and case management systems
Supporting the FOI Requests Officer / Information Governance team to provide responses including Follow Up Questions, Internal Reviews and ICO complaints
Ensure information provided is accurate and consistent with information provided for similar requests
Flagging contentious or sensitive issues and information that may be subject to exemptions with Information Governance team / Information Requests Officer and Heads of Service, including reasoning and explanations or calculations of time required to produce information if necessary
Supporting updates to Publications Scheme and proactive publication of information when a topic becomes a frequent topic of requests
Responding to requests designated as service requests or complaints (not FOI requests) as appropriate

Providing information for requests via Committee & Member Services Manager as requested within deadlines, or advising if information unavailable, working in line with agreed procedures and systems
Oversight of FOI performance, trends, emerging issues, reviewing weekly FOI reports (digest emails)
Advising Information Governance team if member of public has raised the issue of their request to them
In exceptional circumstances review of proposed responses by Portfolio Holders to ensure oversight

Manage all requests wholly concerning their organisation, ensuring requesters are able to contact their organisations directly with their requests and acting according to statutory duties including Internal Reviews and ICO complaints
Advise requesters to make new requests to OCC if information requested is held by OCC
Co-operate with any consultation on responses within required timeframes
Provide statistical reporting to OCC elected Members and CMT at least quarterly, to include number of requests received, % responded to within the statutory time limit, number of Internal Review requests received and time taken to respond, and highlighting any ICO involvement including decision notices, complaints or advisory correspondence. The Council’s statutory officers will be responsible for highlighting any concerns with the shareholder, where necessary and appropriate.

Contractors/suppliers to OCC (inc. ODS and OCHL) need to be aware that they may be contacted regarding requests for information concerning their contracts and/or work with the Council and that information may be disclosed about the work or contract
Contractors to liaise with the OCC FOI team if there is a question about commercial sensitivity or information they consider should be exempt for any other reason