30^th January 2009

NB/BM/FOIA978(R17)

01437 775240

Neil Bennett

[email address]

Vicky Gray

[email address]

Dear Ms Gray

Internal Review

I refer to your e-mail of 28^th January.

The figure of 781 was arrived at following the examination of the new HR database and extracting recorded cases on the old database and amalgamating the two results.

As I explained in my correspondence of 26th January 2009, you should be aware that whilst we believe the figure of 781 is reasonably accurate, we cannot be absolutely sure without examining every relevant staff file. Pembrokeshire County Council employs over 6000 staff and, whilst disagreeing with your estimate of 1 minute to examine a file, even using your timescale, it would take in excess of 100 hours, approximately fourteen working days, to complete the task. This is far over the two and a half days allowed.

The suggestion that a process of examining every file and “scribble a note…” is, in fact, creating a new document and in the latest guidelines issued by the Information Commissioner's Office it states “it is not necessary to create new information in order to answer a request, even if this can be easily done from other information that is held”.

I would reiterate that the figure of 781 is the most accurate figure we can provide using the recorded information held by the Authority.

If, however, you believe that the figure of 781 is not accurate enough, we will withdraw this figure and exempt your question 1 under S12 on the grounds of the cost that would be involved in examining every relevant staff file.

Yours sincerely

Neil Bennett

Head of Information and Cultural Services.