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London Borough of Camden: Building a compliance culture, streamlining case handling processes

Earlier this year, we published a case study on Camden’s approach to business as usual (BAU) responses. We wanted to look at their other processes in more detail after we reviewed their submissions for the eCase FOI awards 2022, which we helped to judge. Camden won FOI Team of the year at the awards. Sarah Laws, the council’s FOI and EIR Lead and Data Protection Manager, won the FOI Practitioner of the Year award.

ICO comment: what this case study means

This case study shows the benefits of deliberately developing a culture of compliance. Organisations can streamline their case handling processes with customer service and amenability in mind. This creates results that benefit both requesters and the public authority. For example, organisations can create frequently asked questions (FAQs) for hot topics. They can provide training and guidance to colleagues in a flexible, reactive way.

Streamlined request handling

Camden has a centralised FOI team of four information rights officers (IROs). They liaise with contacts across the business to locate and retrieve information. The IROs draft all responses and discuss potential exemptions with relevant departments.

Keen to improve request handling processes, Camden contacted a sample of requesters. They called companies, journalists and members of the general public. The feedback they gathered was that their acknowledgments, clarification requests and responses were too complex and contained unclear legalese. The council were also not explaining exemptions clearly enough.

The consensus was that Camden’s communications were heavy on law and process and light on customer care.

Following this feedback, Camden rewrote their templates to cut out direct citations from the Freedom of Information Act and simplified words and phrases.

Additionally, they decided to take a more amenable approach with requesters. They engaged with requesters more often and earlier in the request process. For example, if people asked vague questions, the council guided them to a better approach. They also suggested that the requester call them to discuss the type of information the council holds and how best to access it.

Building a culture of compliance

Camden understood the positives of transparency. However, senior staff needed to let more junior members of staff know that FOI was part of the day job. They also needed to ensure the Council was meeting deadlines.

This work began with the FOI team having discussions with services about where they had difficulties, and what support they needed for better FOI compliance. They took a supportive, rather than critical, approach. Instead of discussing specific late cases, they thanked colleagues for the Council’s better performance. They also began to push the view that the Council could achieve 100% compliance as part of business as usual.

Proactive disclosure work helped them to make the cultural change. Camden started publishing datasets and services could see the number of FOIs reduce. Following this, staff became positive advocates for greater transparency as they could see the benefits it brought them, in terms of time saved overall.

The cultural change was a combination of:

  • senior managers having a positive approach to transparency;
  • ambitions for Camden to perform to a very high standard; and
  • a particularly keen senior advocate in the Borough Solicitor.

Hot topics

The Council looks for areas with a sudden increase in requests, or topics attracting local press coverage. Once identified, the team produces FAQs on the subject.

Although Camden publish their FOI responses, it’s better for requesters if they are linked to a FAQ rather than multiple previous FOI responses. Additionally, the council can update their FAQs as and when they disclose more information.

Anyone can propose potential subjects for FAQs. If an issue has not passed the threshold of demand to justify creating an FAQ, the team keeps a watching brief on the matter. There are no set criteria for hot topics – the approach is agile and responsive.

So far, the FAQs have been downloaded over 1,500 times.

Training and guidance

FOI training at Camden is flexible and tailored to suit different areas. For example, they offer short, headline training sessions for busy senior staff. It is delivered live, which the team considers crucial to its effectiveness.

When services within Camden are struggling to meet their responsibilities, or where there has been a restructure or a management change, the FOI team offers a training session.

The training sessions are practical and informal, encouraging compliance with internal deadlines and being open and transparent as a default. The training does not attempt to explain complex exemptions. Instead, it focusses on identifying and communicating potential harm or prejudice caused by disclosure. The FOI team has found that when services try and apply exemptions themselves, they struggle with the technicalities. However, they are much better equipped to identify and explain potential harm or prejudice. The FOI team feel that this also leads to fuller, more transparent disclosures.

Networking with local schools

Camden’s FOI team support some local schools when they receive information requests.

A small amount of the schools they support receive a lot of FOI requests. Their business managers have become upskilled through the support offered by Camden. They now send draft responses which Camden can review.

Other schools receive a small number of requests – perhaps two or three a year, usually round-robin requests which have also gone to many other schools. For this cohort of schools, Camden has worked to increase their awareness of FOI and how to identify requests. This allows schools to request advice from Camden promptly and so issue quicker responses.