Dear Pembrokeshire Council,

We are submitting the following Freedom of Information Request for documents relating to uses of data analytics, predictive analytics, or algorithmic automated systems used for risk assessment, scoring systems or automated decision making within the jurisdiction of your authority. This could include the use of these data systems in order to draw insights from large and integrated datasets, or to influence decisions about resources, funding or service delivery. This could include, but may not be limited to, uses of predictive analytics in child welfare, health care, adult social care, fraud detection, or policing.

Specifically, we are requesting:

· Any briefing notes, reports, evaluations, or summaries concerning uses of algorithmically driven data systems. Ideally this would include information about software, hardware, operations and types of data

· Any overviews about how system outputs are produced.

· Any training manuals or materials (e.g. slides, etc.) for staff about data collection, analysis, assessment and reporting as related to the use of the systems.

. Any impact assessments

· Any data visualisation outputs connected to the systems.

· Any promotional material, presentation material, or staff educational material related to the systems.

. Any contracts relating to the systems. We argue that the release of contracts does not compromise commercial sensitivity. The full argument is provided below.*

Also, please note we are not requesting datasets or any data about individuals.

Please let us know if any information requires clarifying.

We would like to receive electronic copies of this information.

All the very best,

Data Justice Lab

Please note that we are following the Information Commissioner’s guidance on the Freedom of Information Act which specifies that requests can be made by organisations and there is no need for a named individual (pages 9-10, sections 38-39).
Source: https://ico.org.uk/media/for-organisatio...

*Addressing the commercial sensitivity question:
a) Section 20 of the Department for Communities and Local Government’s ‘Local Government Transparency Code 2015’, which encourages greater transparency in the public interest, notes:

‘The Government has not seen any evidence that publishing details about contracts entered into by local authorities would prejudice procurement exercises or the interests of commercial organisations, or breach commercial confidentiality unless specific confidentiality clauses are included in contracts. Local authorities should expect to publish details of contracts newly entered into – commercial confidentiality should not, in itself, be a reason for local authorities to not follow the provisions of this Code’.

Source: https://assets.publishing.service.gov.uk... (page 9, section 20)

b) There is always the potential for a company in any area to act in bad faith, but this should not be a reason to deny access to information about how public money is spent.

c) Contract and tendering details are provided regularly by a range of government bodies in the public interest. For example, many police and fire services release contractual information through the Bluelight database ( https://www.blpd.gov.uk/foi/foi.aspx ).

d) There may be core aspects of the systems contracted that have competitive commercial value and we appreciate that such details will be redacted from any documents released. We argue that commercial interests will not be compromised by revealing other details that may be provided in contracts or related communications with contracted companies. Details that could be released include details about the existence of a system, it's purpose, the tasks being contracted, continued relationships, general descriptions, types of data being used, how this data is shared.

Freedom Of Information, Pembrokeshire Council

If you have received this email in error, please notify us by telephone on 01437 764551 and delete it from your computer immediately. Os ydych chi wedi derbyn yr e-bost hwn trwy gamgymeriad, byddwch cystal â rhoi gwybod inni trwy ffonio 01437 764551. Wedyn dylech ddileu’r e-bost ar unwaith oddi ar eich cyfrifiadur.

Good Afternoon,

Unfortunately we are unable to process this Freedom of Information request without a name.
Please could you provide us a name.

Kind Regards,

Jodie Aylward
Administrative Assistant, The FOI Team
Cynorthwyydd Gweinyddol, Y Tîm RhG

Pembrokeshire County Council / Cyngor Sir Benfro
County Hall / Neuadd y Sir
Haverfordwest / Hwlffordd
SA61 1TP

Tel / Ffon: 01437 774600
Email / E-bost: [email address]

Publication Scheme: https://www.pembrokeshire.gov.uk/publica...
Cynllun Cyhoeddi: https://www.sir-benfro.gov.uk/cynllun-cy...

Disclosure Log: https://www.pembrokeshire.gov.uk/freedom...
Cofnod Datgeliadau: https://www.sir-benfro.gov.uk/rhyddid-gw...

 

dangos adrannau a ddyfynnir

Freedom Of Information, Pembrokeshire Council

If you have received this email in error, please notify us by telephone on 01437 764551 and delete it from your computer immediately. Os ydych chi wedi derbyn yr e-bost hwn trwy gamgymeriad, byddwch cystal â rhoi gwybod inni trwy ffonio 01437 764551. Wedyn dylech ddileu’r e-bost ar unwaith oddi ar eich cyfrifiadur.

Dear Data Justice Lab,

Thank you for your email. In accordance with section 8 of the Act, we require a valid persons name to be able to log and process your request.

Kind regards,

The FOI Team

Pembrokeshire County Council / Cyngor Sir Benfro
County Hall / Neuadd y Sir
Haverfordwest / Hwlffordd
SA61 1TP

Tel / Ffon: 01437 774600 / 775380
Email / E-bost: [Pembrokeshire Council request email]
Publication Scheme: https://www.pembrokeshire.gov.uk/publica...
Cynllun Cyhoeddi: https://www.sir-benfro.gov.uk/cynllun-cy...

Disclosure Log: https://www.pembrokeshire.gov.uk/freedom...
Cofnod Datgeliadau: https://www.sir-benfro.gov.uk/rhyddid-gw...

dangos adrannau a ddyfynnir

Dear FOI Team,

In regards to a name, please refer to the section of our request where we address this and provide a link to guidance provided by the Information Commissioner's Office. Here is the relevant section again:

"Please note that we are following the Information Commissioner’s guidance on the Freedom of Information Act which specifies that requests can be made by organisations and there is no need for a named individual (pages 9-10, sections 38-39).
Source: https://ico.org.uk/media/for-organisatio... "

Yours sincerely,

Data Justice Lab

Freedom Of Information, Pembrokeshire Council

Dear Justice Lab

We are more than happy to help with this FOI request.

However, to ensure we do not breach GDPR regulations I would like to request that you provide me with the relevant section of legislation which entitles you to this information without the provision of a name.

I look forward to hearing from you.

Jodie Aylward
Administrative Assistant, The FOI Team
Cynorthwyydd Gweinyddol, Y Tîm RhG

Pembrokeshire County Council / Cyngor Sir Benfro
County Hall / Neuadd y Sir
Haverfordwest / Hwlffordd
SA61 1TP

Tel / Ffon: 01437 774600
Email / E-bost: [email address]

Publication Scheme: https://www.pembrokeshire.gov.uk/publica...
Cynllun Cyhoeddi: https://www.sir-benfro.gov.uk/cynllun-cy...

Disclosure Log: https://www.pembrokeshire.gov.uk/freedom...
Cofnod Datgeliadau: https://www.sir-benfro.gov.uk/rhyddid-gw...

dangos adrannau a ddyfynnir

Data Justice Lab

Dear Jodie Aylward,

Thank you for following this up.

We are not requesting person level data or any datasets, so we are unsure at which point GDPR would become relevant to our request. The most relevant legislation to our request is the Freedom of Information Act 2000. In our previous correspondence we have quoted and linked to advice regarding the application of the Freedom of Information Act 2000 from the Information Commissioner's Office.

We are providing a name, the name of our organisation: Data Justice Lab. The ICO's advice indicates this is appropriate, as quoted in our previous correspondence.

Please to not hesitate to ask any more clarifying questions or point us in the direction of a source which indicates our request would be in breach of GDPR in any way. Otherwise, do you have everything required to process our request?

Yours sincerely,

Data Justice Lab

Freedom Of Information, Pembrokeshire Council

If you have received this email in error, please notify us by telephone on 01437 764551 and delete it from your computer immediately. Os ydych chi wedi derbyn yr e-bost hwn trwy gamgymeriad, byddwch cystal â rhoi gwybod inni trwy ffonio 01437 764551. Wedyn dylech ddileu’r e-bost ar unwaith oddi ar eich cyfrifiadur.

Dear Data Justice Lab,

Thank you for your email. The previous email you received was composed by a colleague while I was on leave. I agree the issue here is using the name 'Data Justice Lab', and has nothing to do with GDPR.

The ICO's guidance indeed states that a 'registered company' can use its 'legal trading name' instead of a persons name to make FOI requests.

As the ICO suggests in its guidance, I have checked the Companies House Register, and I have not located 'Data Justice Lab' on the Companies Register. If you are a registered company can you please provide evidence of this.

Kind regards,

Katy

Katy Holman
Information Governance & Freedom of Information Officer /
Swyddog Llywodraethu Gwybodaeth a Rhyddid Gwybodaeth

Pembrokeshire County Council / Cyngor Sir Benfro
County Hall / Neuadd y Sir
Haverfordwest / Hwlffordd
SA61 1TP

Tel / Ffon: 01437 775380 (internal ext. no. 4600)
Email / E-bost: [email address]

Publication Scheme: https://www.pembrokeshire.gov.uk/publica...
Cynllun Cyhoeddi: https://www.sir-benfro.gov.uk/cynllun-cy...

Disclosure Log: https://www.pembrokeshire.gov.uk/freedom...
Cofnod Datgeliadau: https://www.sir-benfro.gov.uk/rhyddid-gw...

dangos adrannau a ddyfynnir