Monday, November 16, 2015

Twitter FOI killer

Unfortunately, the tweets below summarise what happened as a result of my appeal against the ICO's decision:

I did not appeal on whether Twitter was a valid way of making a FOI request - my actual appeal was on what a I perceived to be an illogical consequence of how the DN was written. 

My appeal was on these grounds:

1. whether the ICO was correct in deciding that s.1(1)a obligations are not covered in the same way as s.1(1)b when it comes to the medium of communication
2. Whether the ICO's decision notice means that a public authority can ask for an alternative address for the purposes of fulfilling s1(1)a obligations
3. If a public authority can ask for alternative contact details, how would this not be a breach of the 3rd Data Protection Principle

On this, although my appeal overall was dismissed, the FTT stated at para 33:

We consider that the provisions of the Act are clear, concerning how the public authority should communicate with the applicant in fulfilment of its duty to confirm or deny under s1(1)(a). It should communicate to the ‘address for correspondence’ stated by the applicant in the information request. Thus we agree with Mr Ghafoor that the public authority cannot demand, for carrying out the duty to confirm or deny pursuant to s1(1)(a), an address different from the one stated in the request.

So, it appears that I won on my very narrow point. But it is it a totally pyrrhic victory because both the ICO and got our asses handed to us on a point that was not under appeal - the use of Twitter to make the requests. 

There are two issues here:

  • that the Twitter handle is not an appropriate address as per s8
  • that my name was in the request but only in my profile and that there is no reason to impose a burden on a PA to click on a profile

On the address issue, para 28 states:

In our view Mr Ghafoor’s tweet of 7 August 2014 did not satisfy the requirements of s8. In our judgment a Twitter username is not ‘an address for correspondence’ within the meaning
of s8. A means of communication which is limited to 140 characters is unsuitable for correspondence between the public authority and the requester concerning the request.
[my emphasis]

I agree that it CAN be unsuitable, but I am not sure it IS unsuitable. 

For example, a request like this:

@cabinetoffice can I please have under FOI a copy of meetings of minutes between PM and Putin on 12 Feb 2014?

Can be answered like this in 125 characters:

@FOIkid Not held. To appeal, let us know in 2 months. You can complain to ICO, details at

I cannot see what more this reply needs. 

As pretty much every government department, council, NHS body, etc, has a Twitter account and teams of people spouting propaganda at us all day long, it is deemed a medium where complex ideas are set out. It is also a mistake to think of Twitter as only being about the 140 characters. 

I just spent a minute looking through DWP's timeline - I cannot see any instances where they are purely using 140 characters rather than also embedding graphics or linking to documents. I am sure that there are SOME such tweets, but they are the exception. Twitter is commonly and clearly used in a more sophisticated way than the FTT thinks. I think that it can be suitable. In fact, I almost think that the way in which some organisations are linking to their own documents, that it is probably nearly always suitable (aside from some parish councils, etc). 

Turning to the second issue, on whether my name was in the tweet - I agree, it was not there. Para 29 states:

A Twitter user’s real name may or may not be stated in the user’s Twitter profile. We acknowledge that on the facts of this case Mr Ghafoor’s name was readily available to the public authority; in this case it was a simple matter for the authority to look at his profile. But there is a question of principle here. Section 8 does not entitle a requester to impose on a public authority the task of looking elsewhere than the request itself to discover the requester’s real name. On the contrary, s8 explicitly requires the request to state the name of the applicant. Mr Ghafoor’s request did not do so. The fact that, in the particular circumstances of this case, ascertaining the applicant’s real name could not have been easier, did not convert a request not meeting the requirements of s8 into a compliant request. 

It is good that the Tribunal accepts that it is really easy to ascertain my name - I would add that you don't even need to click on the profile - just a hover on the handle is enough. While s.8 does not explicitly lay this burden on the public authority, it is true that they interact with members of the public through Twitter all the time - this task is undertaken all the time. 

With Twitter having become such a common mechanism for communication, the wording of the act is slightly behind (fair enough, Twitter was created six years after the Act was drafted). However, the way in which Twitter is used by all regular users is so clear and the 'task' to looking up the name of the requestor is so slight, that this interpretation is too theoretical and does not take account of how we all use this medium. 

So, here are my next steps...

I wonder if the ICO will appeal - this makes its guidance on Twitter requests out of date... wouldn't it be a total hoot if we both appealed. That would almost be cute. 

Update 18/11/15 9.40pm: I have been thinking about appealing this decision notice and have been getting lost in the arguments - but the killer argument I got was courtesy of @foimonkey in the pub this lunchtime who pointed out that since I made my initial request Twitter's fuctionality has been changed in two critical ways: DMs have become open and have no word limit. 

If I appeal my case, they will look at the facts of the case as Twitter was functioning at the time of the request - which means that I have no fall back position on arguing that a public authority can DM a longer reply

So, I think that I will have to leave this.

I do feel bad as I am sure that the FTT is wrong, but I am equally sure that I will lose on the facts of this case. I think that you can continue to use Twitter for requests, so long as you insert your name or your handle is your name. You can also ask them to DM you the reply if they need more space. 

Obviously, if they end up refusing you, and you need it, I would be happy to help with any appeals.   

Thursday, June 18, 2015

Using Twitter to make FOI requests (revisited)

The Department for Work and Pensions made a bold claim some months ago on Twitter about how 99 per cent of the jobs on Universal Jobsmatch are genuine. I felt that this was probably nonsense given that they still do not have an effective way of vetting jobs that I am aware of.

So I tweeted a FOI request to them asking them for: 
...copy of internal report or assessment, including all data considered and method, for this assertion...
They not only failed to give me the information, but their denial about the lateness of the reply was arrogant (a simple 'sorry' would have won me over).  

The decision notice has been published at

This is the same sort of DN that the ICO issues in these circumstances, saying that requests via Twitter as valid, and that yes, my name was in the profile, blah, blah.

The only interesting thing is in relation to my complaint over section 11 - whether I could force them to tweet the reply (on principle, when a public authority tweets something that is likely to be nonsense, it would make sense to want it to use the same medium to provide evidence):
16. Section 11(1)(a) of the Act allows the applicant to express a preference for the form (or format) that the requested information should be communicated in, not the communication of whether information is held. The Commissioner finds that the DWP did not breach section 11.
Now, the error I made was that when I got no joy via Twitter, I emailed them to chase. Consequently, they had a mechanism for replying to me off Twitter. Had I not chased, but had gone to the ICO, I could have said that asking for an email address was against the 3rd Data Protection Principle, in that it was excessive - they had a mechanism for replying - by publishing the reply on the disclosure log and tweeting me a link.

I suppose that I could ask them to stop processing my email address, but it unlikely to succeed. More broadly, this DN is hard to understand in relation to section 11. Does this mean that if I email my FOI request, that a public authority can demand a postal address to confirm or deny whether it holds the information? That makes no sense.

I am toying with FTT... but I need to think... comments/free advice appreciated (although I have to say, this is hardly the most important FOI issue in the world and I don't really want to waste anyone's time).


The Cabinet Office: is it cricket?

There has been much irritation on Twitter with news articles such as that in the Telegraph, which somehow seem to imply that deletion of records is against the FOI Act.

Of course, it isn't. The nearest thing is section 77 FOIA, where deletion of information after a request has been received in order to avoid having to disclose the information is the big no-no.

FOIMan has already given an account of the tension between good records management and FOI.

I am interested in expanding on my thoughts based on a debate that @tim2040 and I were having on Twitter. Tim, absolutely correctly, is maintaining that such news stories, with their air of conspiracy and lack of understanding of FOIA are harmful.
Where we disagree is that I think that such news stories, while being factually wrong, jingoistic, and misguided are helping shine a light on the practices of the Cabinet Office when it comes to FOI.
The real pity of it is that articles like this by the excellent @foimonkey, which are accurate and fair do not make headlines, whereas dramatic articles like  that on the BBC are read by millions. 
Ministers can easily protect themselves from embarrassment by deleting from their email inbox anything that might be subject to a future FOI request, ex-insiders have told BBC News.
What a silly thing to say - this is an argument for never deleting anything at all, as anything COULD become subject to a future FOI request.  

There does need to be balance - good records management means that information should be filed sensibly so that it can be easily accessed and used - and part of this is the deletion of information and records that are not needed. The 5th DP principle tells us that personal data should not be kept longer than necessary, which also points to having good records management.

The section 46 Code of Practice on RM says in the foreward, para (IV):

Freedom of information legislation is only as good as the quality of the records and other information to which it provides access. Access rights are of limited value if information cannot be found when requested or, when found, cannot be relied upon as authoritative. Good records and information management benefits those requesting information because it provides some assurance that the information provided will be complete and reliable. 
Note the word 'complete'. This, of course, does not mean that you keep everything - that is silly and would make RM impossible. The Cabinet Office puts the onus on its staff to know what to to save. That is right - RM is everyone's job and no records manager can read everything and make these decisions. My problem is that I doubt that the most important decision making body in government has staff who are doing this. And all without supervision or oversight - although I am happy to be shown that they are. Of course, in other organisations, this does not happen effectively either. But the Cabinet Office is supposed to lead the way in these things - it is supposed to be exemplary. I am not going to moan about a parish council when the I can sense a rotting smell from the top.  

Some records managers will say that this is an effective policy at managing a huge amount of information and it may well be - but I struggle to believe that whoever signed this off did not also think that it would enable the Cabinet Office to hold less data and therefore be able to be less transparent. I would put money on this serving a dual purpose.

So, given the Cabinet Office's lamentable record on FOI, I sense, along with other people, that this is not about it being a world leader in records management.
@igwales has it right when he responding to @foiman asking if this policy was good RM or FOI avoidance -

I have known other organisations that have internal instance messenger systems that simply do not retain a record of the conversation once the window has been closed. They are designed not to keep records.

Gone are the days of everything being minuted - and that is right - but I have been surprised to attend meetings in some organisations where things were not minuted explicitly in order not to leave a record (and when I emailed a summary to my boss for his information, I was ticked off, with his shaking his head at me in sorrow). I don't work there anymore.

And what are the consequences for other public authorities? I have worked for several organisations where I know that the policies are weak, that they are not acted on and no one cares (or has time to care). If people read misguided and inaccurate stories and then start writing to public sector organisations and asking questions about how they keep records, how they ensure good RM and ensure that the organisations leaves a good account of how it made decisions, then I cannot see that any of my colleagues in the FOI or DP or RM worlds are harmed by this. While it might not be fun at the time, in the long term, most practitioners I know really care about information and this may be what public authorities need to be hassled about to ensure that their policies and practices are good.
Is the way the Cabinet Office's way of dealing with information illegal? Of course not.
Is it cricket? Not bloody likely.

Friday, February 27, 2015

NADPO and the PCS strike at the ICO

My friends warned me not to get involved in this strike and union business. I am still glad that I did speak my mind, but pretty irritated by the ICO branch of PCS for having declared that NADPO was boycotting the ICO DP conference.

Although I have said on Twitter and I think that my post about the strike was pretty clear, I want to reiterate for anyone who happens to still be confused that NADPO is not taking a view on strike and is not boycotting the conference.

I am pleased that the PCS branch clarified this:

However, I am pretty pissed off that they decided to drag the name of NADPO into this at all, given that the view that I had given on the strike was clearly a personal one - in fact the caveats that I prefaced it with were nearly as long as the opinion.

Part of this is a sympton of the current government squeezing unions - there is less facility time, they have less money, staff have less flexibility to do their union duties. I know this as I was a PCS rep. But I would have expected ICO staff to be able to read a straight forward and pretty unambiguous blogpost and not draw bullshit conclusions from it.

Sorry ICO PCS branch - I still support your strike, I will still not go to the conference (although NADPO will be there), but you have lost a friend in FOI Kid - although, of course, the Secretary of NADPO is still entirely neutral towards you.

As usual, Tim said it best:

Update 2.45pm Friday 27 Feb:

Just had a couple of emails from PCS saying that they had not meant to misrepresent the NADPO view. So, anger assuaged and honour satisfied.

Tuesday, February 24, 2015

ICO staff salaries and the DP conference

The National Association of Data Protection and Freedom of Information Officers (NADPO), of which I am lucky enough to be secretary, has been growing its links with the ICO over the past year. The ICO has been really kind and sent us speakers for our conferences, often not even asking for travel expenses. The two deputy commissioners are admirable gentlemen and although I often disagree with their conclusions, I think that they are really lovely people.

NADPO has been invited to attend the DP conference, as last year, to run a stall. I was really looking forward to going but today I made the decision that I could not, in all conscience attend the conference because ICO staff are scheduled to be on strike on Monday 2nd March.

When I say 'I', I mean as me, the former member of the PCS union (I am not in a union at the moment as I am freelance - although, as someone who is self employed, I really think very little of my boss). I don't mean 'I' as in secretary of NADPO.

I say this because I want to make it clear that the following post is nothing to do with NADPO, or anything personal about the senior staff at the ICO. This blogpost is entirely personal.

I think that anyone thinking of going to the conference who is from a public sector background should consider whether it is right to attend.

The things that I have been turning over in my mind have been:

  • every few months, on Twitter, someone spots that the ICO is recruiting staff. We all marvel at how little they are paid (personally, I marvel at how bloody good they are at their jobs on such a paltry budget and individual low pay). I am not going to attend because I support staff, especially those at the ICO, whose low pay I have moaned about, are striking over low pay. 
  • the low pay harms all DP and FOI officers. We get a poorer service (although it is amazing despite the pay) than we would have if they were paid the same as in most NDPBs or governement departments. There is no way that the case officers are less than HEOs in central government, yet they are paid much less (and they often end up debating cases with people on at least twice or sometimes thrice their salaries). 
  • the low pay and under budgeting harms the whole FOIA and DPA landscape -  the ICO does not have the money it needs to do anything - and has gone so far as to respond to the MoJ triennial review and suggest fees for appeals - this is a clear sign of desperation for an organisation that rightly champions transparency. Also, its DPA work is so underfunded that it can barely lift its gaze from principle 7 issues. 
  • while lots of really important public sector organisations are underfunded, as DP officers, we are stakeholders (awful word - you know what I mean) and what happens at the ICO affects us. 
  • finally, I cannot help but look at the material that was sent to me a few days ago, and which I published here. I asked the ICO about the stance that the IC had taken, but there was no reply.

  • In conclusion, if you want to send a clear signal (not just to the ICO but also to the people that fund it), and if you want to support the ICO in giving its staff more and being able to support the work that you and I do, DON'T go to the conference. Boycotting the conference is the most helpful thing that you can do for the ICO and information rights.

Friday, February 20, 2015

ICO senior staff payrises

[email addresses redacted]

Information about Executive Team pay increases

             19:43 (13 hours ago)

Dear FOI Kid,
I forward this email to you as an insight into the ICO's own handling of FOI requests it receives for potentially embarrassing information.
Full disclosure of my interest in the matter:
I am unionised member of staff at the ICO about to be on strike about poor pay increases in the context of significant executive pay increases. The union (PCS) made a request for information about the stated "extra duties" justifying extra pay, which the ICO mishandled (first failing to respond, then failing to find information until internal review).
The upshot is that the ICO Data Protection conference may take place during a strike by over half its staff.
I hope the emails are informative about the ICO's ability to comply with its own legislation.
Kind regards,

[name redacted]

---------- Forwarded message ----------
From: [name and email redacted]>
Date: Thu, Feb 19, 2015 at 12:44 PM
Subject: FW: PCS: Information about Executive Team pay increases
To: [name and email redacted]

From: [name redacted]
Sent: 19 February 2015 11:10
Subject: PCS: Information about Executive Team pay increases

Dear members

Please see below for the internal review response PCS has received regarding our requests for information about the Executive Team (ET) pay increases of 8-18% (average 11%). The information disclosed to PCS is attached.

The information speaks for itself, but PCS notes the following:

·         The correspondence between the Commissioner and the Ministry of Justice (MOJ) in June/July 2014 demonstrates the Commissioner was able to hand these huge increases to ET members with only minor, informal queries being raised by the MOJ. Meanwhile, PCS members are told there is no room for manoeuvre with the MOJ or Treasury when it comes to our pay.

·         No additional duties were given to the Deputy Commissioners to justify their increases of 8.5% and 18.5% respectively. Graham Smith explicitly confirms this in one email. The explanations the Commissioner provided to the MOJ about the ‘additional responsibilities’ largely relate to the ICO’s general organisational duties and tasks which are actually performed by ordinary staff and PCS members, rather than the Deputy Commissioners themselves.

·         The Commissioner refers to the effects of the two year pay freeze and further two year 1% pay cap when explaining why he considers it necessary to increase David Smith’s pay by 18.5%. All staff have had their pay frozen and capped in the same way.

·         When the Commissioner informed the MOJ of the changes to the Level H salary range (from £52-85k to £70-100k), he said: “This is for negotiation with the recognised unions as part of the pay architecture debate”. However, in reality he did not negotiate, the changes were made secretly, and he only informed PCS after the event. He has since refused to discuss this change with unions and has claimed all responsibility for determining ET pay lies with the Remuneration Committee only.

·         The day after PCS had announced a car park meeting to coincide with the visit of Simon Hughes MP in September, the Commissioner wrote to Mr Hughes to offer a “heads up” on the ET pay rises.

·         In response to request 2 for details of the additional responsibilities for the Deputy Commissioners, the only information held is a series of internal exchanges discussing how to explain the pay rises to staff and PCS.

Timeline of the request

PCS first requested this information on 5 November 2014 and it has taken until now for it to be disclosed. The Commissioner responded to PCS twice without providing any recorded information, and the information was only disclosed at the internal review stage. Please see below for details.

PCS request for information
Details of the ‘appropriate agreement’ from MoJ relating to the original ICO pay remit; and precise details of the alleged additional responsibilities of the Deputy Commissioners
ICO (Christopher Graham) refusal notice #1
“I have nothing to add to my earlier replies at this stage, but I expect to answer questions on this at my two Town Hall meetings next week”
PCS FOI complaint to ICO about defective response
Complaint still under investigation
PCS chaser

ICO (Christopher Graham) refusal notice #2
“No information held”
PCS request for internal review

ICO internal review response
Lots of information held


[PCS officer name redacted]

FOI request - response to internal review

Sent: 18 February 2015 16:57
To: [name redacted]
Subject: Internal review of FOI request of 05 November 2014

Dear [name redacted]

Your request for an internal review of the handling of your information requests of 05 November 2014 has been passed to me to undertake.  I have carefully considered all the relevant information, including your requests, and the comments you made when you asked for an internal review. I have reached the following findings.

Request 1

Please provide us with details of the ‘appropriate agreement’ from MoJ relating to the original ICO pay remit, including: the ICO’s case put to MoJ for significant increase to ET pay; the rationale for MoJ accepting; a copy of any recorded information relating to the issue.

The ICO’s response of 21 January 2015 stated that there was no recorded information held in relation to this request. Having considered your comments, and the context in which the request was made, I have taken the reference to the ‘appropriate agreement’ to be wider than just any formal agreement to the ET pay increases received from the MoJ, and to include any recorded information by which the MoJ was kept in the picture on this matter. On this basis I have identified the following recorded information that falls within the scope of your request:

  • An email chain between the Information Commissioner, Christopher Graham, and Simon James, Deputy Director Information Rights and Devolution at the MoJ.
  • An extract of an email from the Information Commissioner, Christopher Graham, briefing Rt Hon Simon Hughes, Minister of State for Justice

The majority of the information above has been disclosed (please see attached). However some information has been withheld under section 40(2) of the Freedom of Information Act (FOIA). I have given the reasons for my decision below.

The emails between Christopher Graham and Simon James include details of; the new salaries of the Deputy Chief Executive Officer and the two Deputy Commissioners of the ICO, the percentage pay rises they were each awarded in July 2014, and the pre-rise salaries of the two Deputy Commissioners, which is the personal data of these data subjects. This information has been disclosed to you because I found that to do so would be fair to the data subjects and would not contravene any of the data protection principles. In reaching this decision I considered whether the disclosure was necessary to meet the legitimate interests of the public, in understanding the justification for the 2014 pay rises and the circumstances in which they were awarded, in the context of the pay cap on public sector increases set by the Government. I found that it was. I considered whether the legitimate interests of the public could be met in a way which was less prejudicial to the rights freedoms or legitimate interests of the data subjects, but found that it could not, and that therefore the prejudice to the rights, freedoms or legitimate interests of the data subjects related to this disclosure was warranted.

This email chain also reveals the exact salaries of the two Deputy Commissioners prior to the pre-rise figure that has been disclosed, and dating back to 2006, together with the percentage rises they received in this period. Again this is the personal data of the Deputy Commissioners. I considered that it would be unfair to the data subjects to disclose this historic exact salary information and that this would therefore contravene the first data protection principle. In reaching this conclusion I considered whether the disclosure of this historic salary information was necessary to meet the legitimate interests of the public in understanding the justification for the 2014 pay rises and the circumstances in which they were awarded, and found that it was not. I considered that the public could understand the reasons behind the 2014 pay rises without needing to know historic exact salary levels dating back to 2006 and that therefore the prejudice to the rights, freedoms or legitimate interests of the data subjects that would be caused by disclosing this information would not be warranted. I have therefore withheld this information under section 40(2) of FOIA by virtue of section 40(3)(a)(i).

The information that has been redacted from the email briefing Simon Hughes has been removed as it is outside the scope of your request, not because it is considered to be exempt information.

Request 2

Please provide precise details of the alleged additional responsibilities of the Deputy Commissioners

The ICO’s response of 21 January 2015 stated that there was no recorded information held by the ICO in relation to this request. Having considered your comments and the context in which the request was made I have considered your request to cover any recorded information about the additional duties of the Deputy Commissioners as referenced in the Commissioner’s letter to the PCS of 01 October 2014. I have identified the following recorded information that falls within the scope of your request:

  • Parts of the email chain between Christopher Graham, and Simon James provided in response to Request 1
  • The extract from the email from Christopher Graham, briefing Rt Hon Simon Hughes, provided in response to Request 1 
·         An extract from an email from Christopher Graham to members of the Remuneration Committee, dated 26 June 2014
  • An extract from an email from Christopher Graham to David Smith, dated 27 June 2014
  • An extract from a Commissioner’s blog, placed on the ICO intranet on 07 July 2014
·         An extract from an email from Christopher Graham to ET members, dated 06 September 2014
  • An email from Graham Smith to Christopher Graham, dated 08 September 2014
  • An extract from a Commissioner’s blog, placed on the ICO intranet on 08 September 2014
  • An extract from an email from Graham Smith to Christopher Graham, dated 18 September 2014
  • An extract from an email from Christopher Graham to the Executive Team of the ICO, dated 29 September 2014
  • An extract from an email from Christopher Graham to the Leadership Group of the ICO, dated 01 October 2014
  • An extract from a letter from Christopher Graham to the PCS, dated 01 October 2014

All this information has been disclosed to you (see attached). No information falling within the scope of this request has been withheld as exempt.

In identifying the information held by the ICO in relation to this request I can confirm that I reviewed all the possible repositories of information that you suggested when you requested your internal review.

If you are dissatisfied with the outcome of the review you may make a section 50 complaint to the ICO.

How to complain

Information on how to complain is available on the ICO website at:
By post: If your supporting evidence is in hard copy, you can fill in the Word version of our complaint form, print it out and post it to us with your supporting evidence. A printable Freedom of Information Act complaints form is available from the ICO website. Please send to:
Case Reception Unit
First Contact Team
Information Commissioner's Office, Wycliffe House
Water Lane
Cheshire SK9 5AF

By email: If all your supporting evidence is available electronically, you can fill in our online complaint form. Important: information included in the form, and any supporting evidence will be sent to us by email.

Yours sincerely


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R - #1 email chain CG to Simon James MoJ
PCS FOI request 05 Nov

R - #1 email chain CG to Cara Campbell Simon Hughes