Information on review of Trans inclusion toolkit

Response to this request is long overdue. By law, under all circumstances, Vale of Glamorgan Council should have responded by now (details). You can complain by requesting an internal review.

Dear Vale of Glamorgan Council,

This is a request under the Freedom of Information Act 2000 (FOIA).

Please provide any information you hold which relates to any review of the Vale of Glamorgan's 'Trans inclusion toolkit', including
- whether or when such a review has taken place and the process followed
- any outcomes, reports, risk assessments, advice or evaluation
- details of who has been consulted and contributed to any review.

At the Council meeting June 2018 Council recommended adopting the 'Trans Inclusion toolkit' document, and stated that it should be reviewed in twelve months.
https://www.valeofglamorgan.gov.uk/Docum...

In response to a FoI request in the Council responded in July 2021:
"... as the law has developed and new information has become available the toolkit is currently subject to review, and further consultation. Legal colleagues are engaged to review the legalities of the content of the toolkit."
https://www.whatdotheyknow.com/request/p...

Yours faithfully,
Genette Crispin

Vale of Glamorgan Council

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Subject: Freedom of Information request - Information on review of Trans
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From: Genette Crispin <[FOI #856849 email]>
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1. mailto:[Vale of Glamorgan Council request email]

Vale of Glamorgan Council

Dear Genette Crispin

FREEDOM OF INFORMATION ACT 2000 - INFORMATION REQUEST

Thank you for your request for information about:

Information on review of Trans inclusion toolkit

Your request was received on 25/04/2022 and is being handled under the
terms of the Freedom of Information Act 2000.
Your query has been given the reference 00203692

In some circumstances a fee may be payable and if that is the case I will
let you know. A fees notice will be issued to you, and you will be
required to pay before I will proceed to deal with your request.
You will receive the information requested within 20 working days unless
the Council does not hold the information or there is a reason for it to
be withheld. I will write to you in any event.
If you have any requirements regarding the format any information should
be supplied in, e.g. the language to be used, audio, large print and so
on, then if you have not already done so please let me know.

If you have any queries or concerns then please do not hesitate to contact
me. Please remember to quote the reference number above in any future
communications.
Further information about your rights is also available from the
Information
Commissioner at:

Information Commissioner's Office - Wales

Second Floor, Churchill House

Churchill Way,

Cardiff

CF10 2HH

029 20678400 / Fax:029 20678399

[email address]

Yours sincerely

Information Governance Officer

Legal Services

Vale of Glamorgan Council / Cyngor Bro Morgannwg

tel / ffôn: 01446 700111

mob / sym:

e-mail / e-bost: [email address]
[email address]

 

 

Consider the environment. Please don't print this e-mail unless you really
need to.

Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir
angen.

 

Visit our Website at [1]www.valeofglamorgan.gov.uk

Ewch i'n gwefan yn [2]www.bromorgannwg.gov.uk

 

[3]Find us on Facebook / Cewch ddod o hyd i ni ar Facebook

[4]Follow us on Twitter /Dilynwch ni ar Twitter

 

Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y
Gymraeg neu yn Saesneg.

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FOI Unit, Vale of Glamorgan Council

Dear Genette Crispin

Thank you for your request for information with regards to the review of Trans inclusion toolkit, which we received on the 24th of April 2022.

Your request
Please provide any information you hold which relates to any review of the Vale of Glamorgan's 'Trans inclusion toolkit', including
- whether or when such a review has taken place and the process followed
- any outcomes, reports, risk assessments, advice or evaluation
- details of who has been consulted and contributed to any review.

Our response
In June 2020 the safeguarding officer for Learning & Skills Directorate was assigned to carry out a review of the tool kit. In the summer of 2020 the Safeguarding Officer became aware of local / regional and national challenges to Local Authority TG toolkits/policies. This included a challenge to Vale of Glamorgan Council TG Toolkit. Time was then spent in researching and preparing with Legal Services a response to the author of challenge.

In September 2020, due to COVID restrictions and difficulties a remote task & finish group was convened to carry out a balanced review, the group included original contributors of the 2018 TG Toolkit, Equalities Team and Youth Workers. An initial meeting took place and a decision was made that it would be necessary to include further contributors to the review such as young people / those affected by TG issues / School staff.

In November 2020 a further Task & Finish group meeting took place which also included teachers and Head teachers it was felt very much by all included that there was a definite need for a child and young person consultation. The Safeguarding Officer and a Youth Team manager were tasked with facilitating this.

In early spring 2021, the Youth Team manager was tasked to look at options for convening several youth focus groups, but it was acknowledged that there may be delays due to COVID19 and remote learning. In summer 2021 the Safeguarding Officer and Youth Team manager met once more and it was explained by Youth Team Manager that there was a definite 'Focus Group Fatigue' amongst many children and young people due to the number of focus groups and activities commissioned during COVID19 lockdown. It was decided that at that time any form of focus group may not be meaningful or helpful and there was a definite need to wait till children went back to schools in Autumn 2021 before further consideration was given for focus groups.

In September 2021 the Safeguarding Officer met several times with Brighton & Hove Local Authority over consideration of adoption of their toolkit, as it was considered national best practice by professionals. In February 2022 the Brighton & Hove Toolkit was provided to Vale of Glamorgan Council for consideration of local adoption.

In March 2022 Welsh Government has indicated that they are seeking a Wales-wide approach and are working on their own policy, so a decision has been taken to wait for this. The Welsh Government has committed to publishing this within next 12 months.

If you are dissatisfied with the handling of your request, you have the right to ask for an internal review. Internal review requests should be submitted within two months of the date of receipt of the response to your original letter and should be addressed to: The Monitoring Officer, Civic Offices, Holton Road, Barry, CF63 4RU.

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision.

The Information Commissioner can be contacted at:
Information Commissioner's Office - Wales
Second Floor, Churchill House
Churchill Way,
Cardiff
CF10 2HH
029 20678400 / Fax:029 20678399
[email address]

Yours sincerely

Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg
tel / ffôn: 01446 700111
mob / sym:
e-mail / e-bost: [email address] or [email address]
 
 
Consider the environment. Please don't print this e-mail unless you really need to.
Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir angen.
 
Visit our Website at www.valeofglamorgan.gov.uk
Ewch i'n gwefan yn www.bromorgannwg.gov.uk
 
Find us on Facebook / Cewch ddod o hyd i ni ar Facebook
Follow us on Twitter / Dilynwch ni ar Twitter
 
Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

show quoted sections

Genette Crispin

Dear Vale of Glamorgan Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Vale of Glamorgan Council's handling of my FOI request 'Information on review of Trans inclusion toolkit'.

The response is useful but incomplete - please can you review the response, and provide the missing information as outlined below.

1/ Challenge and Legal services response summer 2020
The response states "This [review] included a challenge to Vale of Glamorgan Council TG Toolkit. Time was then spent in researching and preparing with Legal Services a response to the author of challenge."

My request covered
"- whether or when such a review has taken place and the process followed
- any outcomes, reports, risk assessments, advice or evaluation
- details of who has been consulted and contributed to any review."

The toolkit is still in place, so the Legal Services response mentioned above presumably provides details on the outcome of consideration of the challenge to the toolkit, and clearly falls in the second category of information that I have requested. Please can you provide details of the challenge to the toolkit, and the legal services response.

2/ Legal review 2021
As detailed in my FoI request, the Council responded in July 2021 to a previous FoI:
https://www.whatdotheyknow.com/request/p...
"... as the law has developed and new information has become available the toolkit is currently subject to review, and further consultation. Legal colleagues are engaged to review the legalities of the content of the toolkit."

Your response includes no information on any legal review taking place in 2021. Please can you either:
- provide me with details of this legal review, and any associated reports, responses or outcomes
- confirm that in fact no legal review took place in 2021.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/i...

Yours faithfully,

Genette Crispin

FOI Unit, Vale of Glamorgan Council

Dear Genette Crispin

Case ref: 00203692

Thank you for your email where you are requesting an internal review of the Vale of Glamorgan Council's handling of your FOI request 'Information on review of Trans inclusion toolkit'.

Your request has been logged and passed to the Monitoring Officer who will conduct a full review of the case. A response will be sent to you when the investigation has been completed.

Kind regards

Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg
tel / ffôn: 01446 700111
mob / sym:
e-mail / e-bost: [email address] or [email address]
 
 
Consider the environment. Please don't print this e-mail unless you really need to.
Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir angen.
 
Visit our Website at www.valeofglamorgan.gov.uk
Ewch i'n gwefan yn www.bromorgannwg.gov.uk
 
Find us on Facebook / Cewch ddod o hyd i ni ar Facebook
Follow us on Twitter / Dilynwch ni ar Twitter
 
Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

show quoted sections

FOI Unit, Vale of Glamorgan Council

1 Attachment

Dear Genette Crispin

We are writing to you in respect of your request for an internal review, which is in the e-mail trail below. It has been referred to the Council's Monitoring Officer for consideration.

Your original request and the response you received are attached. The request was:-

Please provide any information you hold which relates to any review of the Vale of Glamorgan's 'Trans inclusion toolkit', including
- whether or when such a review has taken place and the process followed
- any outcomes, reports, risk assessments, advice or evaluation
- details of who has been consulted and contributed to any review.

The Council's response included the following:-

In June 2020 the safeguarding officer for Learning & Skills Directorate was assigned to carry out a review of the tool kit. In the summer of 2020 the Safeguarding Officer became aware of local / regional and national challenges to Local Authority TG toolkits/policies. This included a challenge to Vale of Glamorgan Council TG Toolkit. Time was then spent in researching and preparing with Legal Services a response to the author of challenge.

In September 2020, due to COVID restrictions and difficulties a remote task & finish group was convened to carry out a balanced review, the group included original contributors of the 2018 TG Toolkit, Equalities Team and Youth Workers. An initial meeting took place and a decision was made that it would be necessary to include further contributors to the review such as young people / those affected by TG issues / School staff.

In November 2020 a further Task & Finish group meeting took place which also included teachers and Head teachers it was felt very much by all included that there was a definite need for a child and young person consultation. The Safeguarding Officer and a Youth Team manager were tasked with facilitating this.

In early spring 2021, the Youth Team manager was tasked to look at options for convening several youth focus groups, but it was acknowledged that there may be delays due to COVID19 and remote learning. In summer 2021 the Safeguarding Officer and Youth Team manager met once more and it was explained by Youth Team Manager that there was a definite 'Focus Group Fatigue' amongst many children and young people due to the number of focus groups and activities commissioned during COVID19 lockdown. It was decided that at that time any form of focus group may not be meaningful or helpful and there was a definite need to wait till children went back to schools in Autumn 2021 before further consideration was given for focus groups.

In September 2021 the Safeguarding Officer met several times with Brighton & Hove Local Authority over consideration of adoption of their toolkit, as it was considered national best practice by professionals. In February 2022 the Brighton & Hove Toolkit was provided to Vale of Glamorgan Council for consideration of local adoption.

Your request for an internal review is on the following basis:-

1/The toolkit is still in place, so the Legal Services response mentioned above presumably provides details on the outcome of consideration of the challenge to the toolkit, and clearly falls in the second category of information that I have requested. Please can you provide details of the challenge to the toolkit, and the legal services response.

2/ Legal review 2021
As detailed in my FoI request, the Council responded in July 2021 to a previous FoI:
https://gbr01.safelinks.protection.outlo...
"... as the law has developed and new information has become available the toolkit is currently subject to review, and further consultation. Legal colleagues are engaged to review the legalities of the content of the toolkit."

Your response includes no information on any legal review taking place in 2021. Please can you either:
- provide me with details of this legal review, and any associated reports, responses or outcomes
- confirm that in fact no legal review took place in 2021.

With regard to your two aspects for clarity, the Monitoring Officer has given consideration to this and is of the view that these are new requests.

The reasoning for this is that your first question is in response to the information you received which refers to a legal challenge. The response you received was wider than the your request as you did not ask about legal challenges. The work undertaken with legal services in 2020 from the above answer related to a potentially litigious matter not a review as such and related to preparation of a response to a potential challenge. This is not the same as a review.

Your second question in relation to a legal review is different because your original request did not state legal review and the original response sent to you as detailed above does not refer to a legal review, it does consider what was carried out internally by the relevant service area at the time. You have considered the response received and then advised of an earlier response which you now in effect are indicating you believe to be at odds with the more recent response. You are therefore seeking clarity in light of the inconsistency you have referred to.

In light of this, the Monitoring Officer is of the view that these two questions are new requests because they emanate out of the information you have received in reply to request under reference number 00203692. It is therefore intended that they should be referred back to the relevant services areas for their consideration as new requests. They will then be considered further as new requests and a response sent to you. If you are dis-satisfied with those responses you will have the right to a further internal review.

Please note the Monitoring Officer has also asked that it be drawn to your attention as your requests relate to potential legal challenges and/or legal advice you may not receive a detailed response because the relevant service area may consider applying exemption 42 under the Act which states:-

42Legal professional privilege

(1)Information in respect of which a claim to legal professional privilege or, in Scotland, to confidentiality of communications could be maintained in legal proceedings is exempt information.
(2)The duty to confirm or deny does not arise if, or to the extent that, compliance with section 1(1)(a) would involve the disclosure of any information (whether or not already recorded) in respect of which such a claim could be maintained in legal proceedings.

However that will be a matter for the service area to consider once they have looked at your further requests for information.

If you are dissatisfied with the response to our review of your Freedom of Information request then you have the right to apply directly to the Information Commissioner for a decision.

The Information Commissioner can be contacted at:
Information Commissioner's Office - Wales Second Floor, Churchill House Churchill Way Cardiff
CF10 2HH

Tel: 029 20678400 / Fax: 029 20678399
[email address]

Regards
Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg tel / ffôn: 01446 700111 e-mail / e-bost: [email address];
or [email address]

Consider the environment. Please don't print this e-mail unless you really need to.
Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir angen.

Visit our Website at www.valeofglamorgan.gov.uk

Ewch i'n gwefan yn www.bromorgannwg.gov.uk

Find us on Facebook / Cewch ddod o hyd i ni ar Facebook
Follow us on Twitter / Dilynwch ni ar Twitter

Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

show quoted sections

FOI Unit, Vale of Glamorgan Council

1 Attachment

Dear Genette Crispin

Further to the response to your internal review that was sent on the 1st of July 2022 we have raised two new requests as per the recommendation from the Monitoring Officer. The case references are:
00204004 - Questions regarding outcome of consideration of the challenge to the Trans inclusion toolkit;
00204005 - Requesting details of legal review taking place in 2021 in respect of Trans Inclusion Toolkit.

In some circumstances a fee may be payable and if that is the case I will let you know. A fees notice will be issued to you, and you will be required to pay before I will proceed to deal with your request.

You will receive the information requested within 20 working days unless the Council does not hold the information or there is a reason for it to be withheld. I will write to you in any event.

If you have any requirements regarding the format any information should be supplied in, e.g. the language to be used, audio, large print and so on, then if you have not already done so please let me know.

If you have any queries or concerns then please do not hesitate to contact me. Please remember to quote the reference numbers above in any future communications.

Further information about your rights is also available from the Information
Commissioner at:

Information Commissioner's Office - Wales
Second Floor, Churchill House
Churchill Way,
Cardiff
CF10 2HH

029 20678400 / Fax:029 20678399

[email address]

Yours sincerely

Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg
tel / ffôn: 01446 700111
mob / sym:
e-mail / e-bost: [email address] or [email address]
 
 
Consider the environment. Please don't print this e-mail unless you really need to.
Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir angen.
 
Visit our Website at www.valeofglamorgan.gov.uk
Ewch i'n gwefan yn www.bromorgannwg.gov.uk
 
Find us on Facebook / Cewch ddod o hyd i ni ar Facebook
Follow us on Twitter / Dilynwch ni ar Twitter
 
Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

show quoted sections

FOI Unit, Vale of Glamorgan Council

1 Attachment

Dear Genette Crispin

Thank you for your further requests for information which we received on the 1st of July 2022. Your requests were logged under separate reference numbers however this one response will cover both of the additional points that you have raised. Please refer to your original request and our response to your request for an internal review (see below) for context.

Your requests
Question 1
The toolkit is still in place, so the Legal Services response mentioned above presumably provides details on the outcome of consideration of the challenge to the toolkit, and clearly falls in the second category of information that I have requested. Please can you provide details of the challenge to the toolkit, and the legal services response.

Question 2
Legal review 2021
Your response includes no information on any legal review taking place in 2021. Please can you either:
- provide me with details of this legal review, and any associated reports, responses or outcomes
- confirm that in fact no legal review took place in 2021.

Our response
Unfortunately, we are not able to provide any information that you have requested as this is subject to Legal Professional Privilege and is therefore exempt from disclosure in accordance with Section 42 of the Freedom of Information Act 2000.

Section 42 applies whenever complying with a request would reveal information that is subject to 'Legal Professional Privilege' (LPP) or the equivalent Scottish rules. LPP protects information shared between a client and their professional legal advisor (solicitor or barrister, including in-house lawyers) for the purposes of obtaining legal advice or for ongoing or proposed legal action.

In the Council's reliance on Section 42 we have taken into consideration the public interest test.

Factors favouring disclosing information:
. The public's interest in openness and accountability;
. Promotes transparency.

Factors against disclosing information:
. The issue which the legal advice has been requested is ongoing;
. Disclosure would weaken the confidence in legal professional privilege.

Taking account of the above we consider that, as the case is ongoing, the release of the requested information would not be appropriate at this time and therefore this outweighs the public interest in disclosing it.

This letter is therefore a formal refusal notice under section 17(5) of the Act for the information requested.

If you are dissatisfied with the handling of your requests, you have the right to ask for an internal review. Internal review requests should be submitted within two months of the date of receipt of the response to your original letter and should be addressed to: The Monitoring Officer, Civic Offices, Holton Road, Barry, CF63 4RU.

If you are not content with the outcome of the internal review, you have the right to apply directly to the Information Commissioner for a decision.

The Information Commissioner can be contacted at:
Information Commissioner's Office - Wales
Second Floor, Churchill House
Churchill Way,
Cardiff
CF10 2HH
029 20678400 / Fax:029 20678399
[email address]

Yours sincerely

Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg
tel / ffôn: 01446 700111
mob / sym:
e-mail / e-bost: [email address] or [email address]
 
 
Consider the environment. Please don't print this e-mail unless you really need to.
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Ewch i'n gwefan yn www.bromorgannwg.gov.uk
 
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Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

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6 August 2022

Dear Information Governance Officer

I would like to request a review of your response to my FoI request. (00203692, and subsequently 00204004 00204005 as created by you)

On 24 April 2022 I made a request for any information you hold relating to any review of the Council’s Trans Inclusion Toolkit, including whether or when any review had taken place, the process followed, and any outcomes, reports, risk assessments, advice or evaluation. I noted that it had been stated in June 2018 that there would be a review, and that your earlier response to an FoI request made by Harriet Jones in July 2021 had stated "as the law has developed and new information has become available the toolkit is currently subject to review, and further consultation. Legal colleagues are engaged to review the legalities of the content of the toolkit".

In May you replied with a narrative summary of various events, but did not provide the full information held by the Council relating to any review of the Toolkit that I had requested. The response described various steps that had been taken by the safeguarding officer from June 2020 onwards following legal challenges in the Vale of Glamorgan and elsewhere. It made no reference to the review by lawyers that the Council had said was taking place in the July 2021 disclosure, to which my request had specifically referred.

I requested an internal review, asking you to provide the missing information on:

a) the challenge to the toolkit mentioned in your response and the Council’s response to it;
b) whether lawyers actually carried out the legal review that your July 2021 disclosure they had been engaged to carry out;
c) the outcome i.e. what the Council concluded as a result of any legal advice or review.

Your response stated that you were treating this as a new request (00204004 00204005). It wrongly claimed that my original request had not referred to a legal review. It indicated that the Council would regard a request for information about reviews as not covering legal reviews or reviews resulting from legal challenges. That was wrong. My original request was not limited to any particular kind of review.

I do not accept that my internal review request was a new FoI request. It was a request for you to provide information I had already requested.

You have now replied that you are "unable" to provide any of the information mentioned in my internal review request because it is exempt under section 42 of the FoI Act (legal professional privilege). I take it that you mean that you think you are not required to disclose the information by virtue of the exemption. (FoI Act exemptions do not make you "unable" to disclose information.)

I consider it extremely unlikely that all the information you hold relating to the legal challenge and the legal review is covered by legal professional privilege (LPP). LPP covers requests for legal advice and the content of that advice. It may in some cases cover the fact that advice was sought, but in this case you have already disclosed that information yourselves in response to a previous FoI request and my own request. Furthermore, LPP does not cover information about the grounds on which a legal challenge was brought against the Council, how the Council responded to that challenge or any other action the Council took as a result of the challenge. Nor does LPP cover whether the legal review of the Toolkit, disclosed by yourselves in 2021, was actually completed or what was done as a consequence of it.

Even so far as LPP does apply to any of the information I have requested, section 42 only creates a qualified exemption. It is only if the public interest in withholding the information outweighs the public interest in disclosure that you may withhold it under section 2 of the Act. Your response merely notes general considerations that would be relevant in all case involving information subject to LPP, without engaging in any way with the specific circumstances of this request.

It is clear that there is a compelling public interest in favour of disclosure in this case because:

1) The Toolkit relates to a highly contentious topic, with a high profile in public life, on which public bodies are regularly accused in the media of adopting policies without proper public scrutiny or support. There is a strong public interest in knowing how the Council has been dealing with these issues and what position it is taking.

2) The Toolkit has been subject to a number of complaints and challenges, but is still being relied on by schools in the Vale of Glamorgan as advice on how to comply with equality law, so it is vital to know whether the Council believes that it accurately reflects the law. Having published a document which contains statements and advice about equality law, it is not acceptable for the Council to refuse to say whether it stands by that advice, or to keep any more recent legal view it has formed about the Toolkit secret. Refusing to share the legal basis for retaining such a controversial policy contributes to the impression that it is unlawful.

3) Stonewall, who were involved in the production or approval of the Toolkit, have been criticised (including in an official review for Essex University) for misrepresenting equality law to public institutions and giving them advice which has in turn led them to misstate the law. It is therefore particularly important to know how the Council is interpreting equality legislation and what advice it is receiving.

4) The issues that have been raised in relation to the Toolkit relate to the safety of children. There is a particularly strong public interest that policies relating to safeguarding must be transparent and legally sound.

These arguments in favour of disclosure clearly outweigh any public interest in the Council being able to obtain legal advice about the Toolkit in confidence. The public has a right to know whether the Council is continuing to endorse (by failing to withdraw it) a policy or advice document that the Council now considers to be legally unsound. If the Council has come to the view that the Toolkit is not legally sound, that might be embarrassing for the Council to acknowledge, but it is definitely not a public interest argument for refusing to provide information about the Council's legal position; quite the contrary.

Even if there is some information covered by my original request that you are not required to disclose because of the LPP exemption, there is no evidence in your response that you have considered whether there is any other information covered by the request that you are nevertheless required to disclose. It seems highly unlikely that all information relating to the legal challenge and legal review that you have mentioned is subject to LPP and that the balance of the public interest favours withholding all of it.

In line with your duty to provide advice and assistance to requesters under section 16 of the FOI Act, you should proactively consider what information you can disclose, whereas your response suggests that you are simply trying to find excuses to withhold information to avoid embarrassment on a sensitive issue.

Please look again at all the information you hold that comes within the terms of my original request and identify the information that you are required to disclose under the FOI Act, either because it is not subject to LPP or because the public interest in disclosing it outweighs the public interest in maintaining the exemption under section 42 of the FoI Act.

As stated above, this information was clearly requested in my original FoI request, dated 24 April 2022 - there was no justification for treating this as a new request other than to delay and avoid disclosure. I have now been waiting over three months for a response. If I do not receive a satisfactory response promptly, I intend to complain to the Information Commissioner.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/i...

Yours faithfully,

Genette Crispin

FOI Unit, Vale of Glamorgan Council

Dear Genette Crispin

Thank you for your request for an internal review of our response to your Freedom of Information requests - case refs: 00204004 and 00204005.

Your request has been logged and passed to the Monitoring Officer who will conduct a full review of the cases. A response will be sent to you when the investigation has been completed.

Kind regards

Information Governance Officer
Legal Services
Vale of Glamorgan Council / Cyngor Bro Morgannwg
tel / ffôn: 01446 700111
mob / sym:
e-mail / e-bost: [email address] or [email address]
 
 
Consider the environment. Please don't print this e-mail unless you really need to.
Ystyriwch yr amgylchedd. Peidiwch ag argraffu'r neges hon oni bai fod gwir angen.
 
Visit our Website at www.valeofglamorgan.gov.uk
Ewch i'n gwefan yn www.bromorgannwg.gov.uk
 
Find us on Facebook / Cewch ddod o hyd i ni ar Facebook
Follow us on Twitter / Dilynwch ni ar Twitter
 
Correspondence is welcomed in Welsh or English / Croesewir Gohebiaeth yn y Gymraeg neu yn Saesneg.

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