What does good FOI practice look like in the police sector?
We spoke to a number of FOI officers in well performing police forces across the country about what good practice looks like to them, and how this supports FOI performance. We hope all police forces can learn from what they told us.
Senior leadership buy-in
FOI officers reflected on the benefits of FOI visibility at executive command level. Having the FOI function overseen at a senior level and regular reporting of performance at this level strengthens senior management commitment to FOI, and promotes a culture of transparency within organisations. Monthly reports on FOI items of interests, including ICO and Information Tribunal FOI decisions relevant to the police sector are seen as useful. Regular reporting to senior information risk owners can help address compliance gaps or risks.
Good internal relationships
FOI officers felt it was really important to develop and maintain good relationships with information owners. Having single points of contact for business areas is seen as a key element of maintaining relationships. This can help increase the impact of messaging on the organisational benefits of not treating FOI as a chore when handling competing priorities. In-person or virtual meetings have proved useful to resolving challenges, and facilitating timely responses to enquiries.
Multi-functional teams
Having multi-functional business areas or increased number of staff with a generic role profile has helped tackle sudden increases in FOI request volumes. This can also significantly reduce the impact of long-term staff absence on FOI performance, and has proved useful now that the vetting process for new staff in the police sector takes much longer.
Request handling practices
FOI officers reflected on request handling practices and a few things stood out on setting expectations in relation to; recording searches, minimising the risk of personal data breaches when sharing information for disclosure, and section 77 of the FOIA. A pro-forma request handling memo containing these expectations along with other useful information on processing requests, is shared with information owners by one of the forces each time a FOI request is received. Another force flagged the Freedom of information Authorised Professional Practice published by the College of Policing as a useful resource for FOI practice in the police sector. Officers are also proactive in flagging topics that have generated media interest with business areas to help them prepare relevant information in anticipation of FOI requests.
Proactive disclosures
In addition to publishing information on common subjects such as crime statistics, most of the forces responsively proactively publish information on emerging FOI ‘hot topics’ such as, staff-related sexual misconduct data and enforcement activities relating to dangerous dogs. Some forces maintain a disclosure log which requesters are referred to when appropriate.
Networking
Being part of national and regional network groups is seen as essential. They have been useful when handling thematic FOI requests that cut across various police forces. Relationships formed from these networks have led to the sharing of good practice between forces.