FOI research project
University of Glasgow
Background
Context
The University of Glasgow was established in 1451 and is in the top 1% of the world’s universities. The University has a large population of undergraduates and postgraduates from around 120 different countries. There are 6,130 members of staff. The University is also part of the Russell Group of leading UK research universities.
The University of Glasgow is divided over three campuses. These are the Gilmorehill, and Garscube campuses in the West End of Glasgow and Crichton campus in Dumfries. The structure of the University is divided into colleges and schools. The four colleges are the College of Arts; the College of Medical, Veterinary and Life Sciences; the College of Science and Engineering; and the College of Social Sciences. The schools are divided into these four colleges. This change to a colleges and schools system happened in August 2010.
The Data Protection and Freedom of Information Office (DP & FOI Office) was established at the University of Glasgow in 2006. The current procedures that are in place to respond to FOI requests were initiated in 2007. The process of logging and answering FOI requests uses a centralised database system, “Supportworks”, to log and assign unique call numbers to each request. The structure of the University means that there is an FOI co-ordinator specific to each school or University service. Therefore, it is straightforward to track a request from when it arrives at the DP & FOI Office to when it goes out to the various Colleges and Services throughout the University. The University of Glasgow also has a policy that any “business as usual” request received by the Schools and Services are answered by them.
The FOI request procedures are continuously reviewed to ensure they are fit for purpose to ensure requests are handled in accordance with the legislation. In 2009, the DP and FOI Office was specifically commended for its FOI procedures by the Office of the Scottish Information Commissioner. The University of Glasgow’s assessment report by OSIC can be viewed at the following URL:
http://www.itspublicknowledge.info/uploadedfiles/assessmentreportglasgowuniversity.pdf
The University receives a very high number of FOI requests each year, with some 343 received in 2011. These requests are received from a wide variety of applicants and cover a range of topics which scrutinise all aspects of the University’s work, on both the academic and administrative sides. Requests are often complex and may require the collation of information from across different areas of the University or the careful consideration of the implications of releasing information and the possible application of exemptions.
Aims and objectives
The ‘Calculating the resources required to respond to FOI requests’ project was of particular interest to the University of Glasgow because it would provide the DP & FOI Office with the tools to analyse how much FOI requests actually cost to respond to. By choosing five random requests this meant that the information would be varied and therefore, be responded to by a number of departments from around the University. The provision of the tools and the size of the project meant that this would be focused and manageable for the DP & FOI Office without taking up too much time from all the staff involved. The project would allow for this information to be dissected and analysed in a number of ways to be able to provide data for a number of questions.
This project was undertaken to provide the University of Glasgow with the opportunity to quantify the work and staff time costs that are involved in answering Freedom of Information requests. It would also allow for a detailed analysis of the staff time and costs involved in the different areas of answering a request. By focusing on five randomly selected requests this allowed for a variety of requests to be tracked through various departments. Therefore, it would be possible to see how departments differ in the way they handle requests. In turn, this provided the opportunity to examine the process involved in answering a request, as well as how information governance is implemented throughout the university.
Undertaking this project also provided good experience in project management for the records management graduate trainee. The trainee was able to gain a good grounding in all aspects of responding to a Freedom of Information request. It also meant that the trainee was made aware of how these request are dealt with by different university departments.
Project approach
The nature of the project, coupled with the system the University has in place to answer FOI requests, meant an additional step was required in the procedure for handling FOI requests. The University already uses a database programme, “Supportworks” to log and track all aspects involved in handling an FOI request. The database system also provided each request with a unique code which made the tracking of the five random requests straightforward. “Supportworks” is a call management system offered by Hornbill (www.hornbill.com) which the University uses to manage its IT helpdesk. This has been heavily customised for the FOI Office’s requirements.
The main area of focus involved in implementing this project was staff awareness. The DP & FOI Office held a departmental meeting to inform staff about the research study. The meeting also informed them of what would be required of them if they received one of the five random requests involved in the study.
The next most important area of focus was ensuring staff members handling the request in the departments were aware of the project and the potential that they may be involved with one of the five random requests. The University utilised the network of FOI co-ordinators which were already in place to disseminate this information. A general email was sent to the co-ordinators at the start of January informing them of the project and their potential involvement and reassuring them that established procedures should be followed.
Those co-ordinators from the departments who provided information for the five requests were sent a template alongside the memo they usually receive explaining the FOI request and asking them to respond. The template was in the form of a Word document which explained the project in further detail and what their role was to help provide the necessary staff time and pay information. Due to the number of FOI co-ordinators across the University, the DP & FOI Office made the decision to manage the completion of the JISC spreadsheet in order that any confusion could be avoided from multiple authors accessing the spreadsheet and interpreting the terminology differently.
Outcomes
The project has provided the University with some tangible (albeit limited, given the small size and restrictions of the survey) figures to account for the time spent answering FOI requests. These will be of benefit to the DP & FOI Office in assessing resource requirements and in providing evidence as to the impact of FOI which will inform the ongoing effort to communicate and raise awareness of FOI throughout the University. It has been surprising to the staff of the DP & FOI Office that a number of the requests have had relatively low costs associated. However, it is important that these costs are viewed in the context of the limitations of the sample studied and the fact that they are generally not representative of the complexity and scale of requests normally received by the University.
The DP & FOI Office can occasionally bear the brunt of staff exasperation when it comes to having to answer FOI requests. Understandably, staff at the University are employed for a specific purpose and the requirement to answer FOI requests is quite often an unwelcome addition to their day to day work, sometimes prompting the question as to how much it actually costs the University to deal with FOI requests. Therefore, besides having some figures to quote, one of the most valuable outcomes from the project was the appreciation from the staff involved that the project sought to quantify their efforts when answering FOI requests.
Key Lessons Learned
From a practical point of view as a participant institution in this project, one of the lessons learned was that the timing of a project can have an impact on how smoothly it runs. The commencement of this project at the New Year in 2012 caused some problems as this is a time of year when a large number of staff are on annual leave, seeking to make the most of the Christmas break. Further, there was some uncertainty at the outset as regards which requests should be included in the project, due to some requests having been received during the break when the office was closed.
An interesting finding from the project was that the request which cost the most money to process was one that was in fact refused on grounds of Section 12 Excessive cost of compliance. This reveals the impact that a request can have even when the applicant ultimately receives no information in response, as the fees regime in Scotland is so granular and the cost of responding to each question in a request must be considered on an individual basis.
Another aspect uncovered by the project is that one of the most time-consuming parts of the FOI process is the task of reviewing the information considered for release. This is a task that appears to be performed at a variety of levels across the University. When the requested information is gathered, time is spent in the relevant office reviewing if they think the information is accurate and suitable for release. This can involve the input of senior managers who may have greater awareness of any issues or implications that should be borne in mind. Furthermore, time is then spent in the DP & FOI Office analysing the response received from elsewhere in the University, ensuring it contains all the required information to answer the request fully and to consider if any exemptions might apply and the justification for these. This would suggest that the University does not necessarily struggle to retrieve the information it holds, but that establishing the accuracy of the information received from across the University and whether it is suitable for release are more onerous tasks.
Overall, however, the project confirmed that the University’s FOI procedures are sound, with no outcomes to suggest that current practice should be altered.
Summary and reflection
The project has given a more tangible affirmation of the significant impact FOI requests have on the University. It has widened our appreciation of the number of staff involved in answering a request. In accordance with the University’s procedures, FOI requests are sent to a named FOI co-ordinator within each College or Service with responses routed back to the DP & FOI Office through the FOI co-ordinators. Consequently, the input of other staff is often hidden, and, therefore, this project has made the involvement of other staff alongside the co-ordinators more transparent.
Given the widening of the net as regards those involved in dealing with FOI requests that the project has revealed, the DP & FOI Office hopes to reflect on its current training arrangements for the University. While an “Introduction to FOI” training course is offered by the DP & FOI Office, staff constraints mean it can only be offered twice a year at the moment. As such, the DP & FOI Office are keen to look at other methods for ensuring FOI training reaches the many different staff across the University who will encounter FOI. An option which will now be considered is the development of an online training module in addition to face to face training courses in order that a basic level of knowledge can be ensured across the University.
While acknowledging that the project has provided actual figures with which to measure the impact of FOI on the University, it must also be accepted that these figures will be incomplete. Although they account for the staff time spent on FOI requests, such costs fail to take into account the unseen costs of FOI which result from a removal of staff from their core activities, often at short notice, to respond to FOI requests. Nor do the figures account for any time spent by colleagues picking up on work that the responding member of staff has had to put aside. These lost times can obviously add up to create a knock on effect on the progress of certain projects or pieces of work in areas where a high volume of FOI requests are received. Finally, the approach institutions take to “business as usual” requests may also disguise costs that may more legitimately be ascribed to FOI.
However, it has been an interesting and thought-provoking exercise for the University to take a step back from the day to day procedural approach to handling FOI requests to contribute to a project which may have the potential to influence the UK Government’s Post Legislative Scrutiny of the Freedom of Information Act. While this does not directly apply to Scotland, any findings would certainly be of note within the Scottish sector, and the DP & FOI Office has found participation in the project to be worthwhile.
