Response to 2019 Public Health service cut consultation

City of London Corporation Nid oedd gan y wybodaeth y gofynnwyd amdani.

Dear City of London Corporation,

During 2019, the joint City of London & Hackney Public Health service was revisioned, and staff numbers were significantly cut.

I want to understand the stakeholder consultation process which underpinned this.

Please provide:

1. Any records to show whether your organisation was consulted as part of the restructure of the City & Hackney Public Health service in 2019.
2. Copies of all material which was given to you setting out the proposal (including any assessments of risks to health inequalities, to services, or to data protection).
3. Copies of any response your organisation made, and notes of any related meeting minutes, copies of emails or any other documentation.
4. It would also be helpful to know whether:
a. you supported the staff cuts or new service vision
b. you received sufficient information
c. your input was reflected in the final vision and structure of the service

If you are unable for any reason to provide a full response, a partial response would still be appreciated.

Yours faithfully,

Sam Flowers

COL-EB-InformationOfficer, City of London Corporation

Dear Sam Flowers,

FREEDOM OF INFORMATION ACT 2000 (FOIA) – REQUEST FOR INFORMATION

The City of London (CoL) acknowledges receipt of your request for information of 27 October 2020.

Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.

The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the “Square Mile”, ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (City of London - Interactive Mapping), which shows the local authority area covered by the CoL:
https://www.mapping.cityoflondon.gov.uk/...

The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.

Yours sincerely,

Information Officer
Comptroller & City Solicitor’s Department
City of London
Tel: 020-7332 1243
www.cityoflondon.gov.uk

dangos adrannau a ddyfynnir

DCS FOI, City of London Corporation

1 Atodiad

Dear Sam Flowers

 

FREEDOM OF INFORMATION ACT 2000 - INFORMATION REQUEST

 

We have been dealing with a continued high number of FOI requests,
together with competing statutory deadlines in other areas of our
departmental work and therefore would like to extend the deadline to close
of 12 December 2020.

Given the delay, we are required to inform you of the complaints
procedure, as follows.

If you wish to make a complaint about the way the CoL has handled your
enquiry, please make your complaint in writing to email address:
[email address]. For a link to the CoL’s FOI complaints
procedure, please visit the following page:
[1]www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied; you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone:
(01625) 545700.  Website: [2]http://www.ico.gov.uk/.

Please note that the City (the "Square Mile") has a resident population of
about 9,720* which includes approximately 1,770 children aged up to 19
years old.

 

*Office of National Statistics 2020

 

The FOIA applies to the CoL as a local authority, police authority and
port health authority. Subject to any other statutory provisions requiring
the CoL to disclose information, release of information outside the scope
of the Act is subject to the discretion of the CoL.

 

The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner.

 

Yours sincerely

Business Support Assistant | Business Unit Team
City of London Corporation [3]www.cityoflondon.gov.uk

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
1. https://corpoflondon.sharepoint.com/site...
2. http://www.ico.gov.uk/
3. http://www.cityoflondon.gov.uk/

DCS FOI, City of London Corporation

1 Atodiad

Dear Sam Flowers

 

FREEDOM OF INFORMATION ACT 2000 - INFORMATION REQUEST

 

Following receipt of your request for information on 27 October 2020, our
acknowledgement of 29 October 2020 and our extension request of 24
November 2020, please accept our apologies that we have not been able to
respond to your enquiry.  I anticipate that we will be able to respond by
close of business on 23 December 2020.

Given the further delay, we are required to inform you of the complaints
procedure, as follows.

If you wish to make a complaint about the way the CoL has handled your
enquiry, please make your complaint in writing to email address:
[email address]. For a link to the CoL’s FOI complaints
procedure, please visit the following page:
[1]www.cityoflondon.gov.uk/Feedback, at the end of which is located the
FOI complaints procedure. If, having used the CoL’s FOI Complaints
Procedure, you are still dissatisfied; you may request the Information
Commissioner to investigate. Please contact: Information Commissioner,
Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone:
(01625) 545700.  Website: [2]http://www.ico.gov.uk/.

Please note that the City (the "Square Mile") has a resident population of
about 9,720* which includes approximately 1,770 children aged up to 19
years old.

 

*Office of National Statistics 2020

 

The FOIA applies to the CoL as a local authority, police authority and
port health authority. Subject to any other statutory provisions requiring
the CoL to disclose information, release of information outside the scope
of the Act is subject to the discretion of the CoL.

 

The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner.

 

Yours sincerely

 

Business Support Assistant | Business Unit Team
City of London Corporation [3]www.cityoflondon.gov.uk

 

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
1. https://corpoflondon.sharepoint.com/site...
2. http://www.ico.gov.uk/
3. http://www.cityoflondon.gov.uk/

DCS FOI, City of London Corporation

2 Atodiad

Dear Sam Flowers

 

FREEDOM OF INFORMATION ACT 2000 - INFORMATION REQUEST

 

Following receipt of your request for information on 27 October 2020, our
acknowledgement of 29 October 2020, our extension request of 24 November
2020 and further extension of 11 December 2020, the City of London (CoL)
apologises for the delay and responds as follows:

 

During 2019, the joint City of London & Hackney Public Health service was
revisioned, and staff numbers were significantly cut.

 

I want to understand the stakeholder consultation process which
underpinned this.

 

Please provide:

 

1.            Any records to show whether your organisation was consulted
as part of the restructure of the City & Hackney Public Health service in
2019.  N/A

 

2.            Copies of all material which was given to you setting out
the proposal (including any assessments of risks to health inequalities,
to services, or to data protection). 

Please see attached redacted document and section 40(2) below.

 

3.            Copies of any response your organisation made, and notes of
any related meeting minutes, copies of emails or any other documentation. 

This exercise is not customary for staffing restructures.  There was
informal engagement with some stakeholders by the interim DPH.  No notes
were taken of these meetings/conversations since they were informal and
the stakeholders understood that their comments were given in confidence
and would not be shared.

4.            It would also be helpful to know whether:  N/A

a.         you supported the staff cuts or new service vision

b.         you received sufficient information

c.         your input was reflected in the final vision and structure of
the service

 

This response acts as a partial refusal notice in accordance with section
17 of the FOIA.

Please note with regard to this response, that the CoL has applied the
FOIA Section 40(2) exemption (personal information) to any CoL or Hackney
Council staff names where such staff are below the higher managerial level
and are not already on the CoL website or otherwise routinely in the
public domain. This exemption has also been applied to details of the
Public Health workforce profile due to small numbers. The CoL considers
that disclosure of the specific level of detail could result in
information being associated with identifiable individuals. This
information has been redacted in the attached Equalities Impact
Assessment.

It is applied as the CoL believes the disclosure of this information under
the FOIA would be a breach of the Principle 1 under Article 5(1)(a) of the
General Data Protection Regulation (GDPR), ie the Principle of lawfulness,
fairness and transparency, as also embodied in the Data Protection Act
2018 (DPA).

There is no general expectation by staff, other than the most senior
managers, that their place of work should be automatically disclosed
following FOI requests, which requests we legally have to treat as being
in effect a disclosure to the public at large. It is also one of the
reasons why our website gives only a few named contacts (being mainly
limited to departmental managers).

We also do not consider that the information that a particular named
individual is a public sector employee of a particular named public
authority is information which in itself would constitute information of
general public interest. On the contrary, in relation to the vast majority
of public sector employees, such information is manifestly of no general
public interest.

Please note that a public authority has to consider a disclosure under the
FOIA as a disclosure to the world. We note the Information Tribunal’s
statement that “Disclosure under [the] FOIA is effectively an unlimited
disclosure to the public as a whole, without conditions” (Information
Tribunal Appeal Decision EA/2006/0011 & 0013), which was also referred to
by the Information Commissioner (Information Commissioner's Decision
Notice FS 50294078). We would therefore have to consider disclosure of the
names as a public overriding of the DPA.

In conclusion, with regard to this exemption, the CoL does not see any
legitimate interests in the public having access to the information and
considers that disclosure would not pay due respect to the rights and
freedoms of the data subjects, ie in this instance members of staff. We do
not see any conditions under Article 6 (which concerns conditions for
processing personal data) of the GDPR which would permit disclosure.

The CoL also does not consider that there are any conditions under Section
1(2) of the DPA (which refers to the General Data Protection Regulation,
and in this instance the relevant Article of which would be Article 6,
concerning conditions under Principle 1 for processing personal
information) which would permit disclosure.

The section 40(2) exemption is an absolute exemption, meaning it is not
subject to the public interest test.

Please note that the City (the "Square Mile") has a resident population of
about 9,720* which includes approximately 1,770 children aged up to 19
years old.

 

*Office of National Statistics 2020

 

We hope that this response is of assistance.

 

If you wish to make a complaint about the way the CoL has managed your
enquiry, please use the following link to the CoL’s FOI complaints
procedure : [1]www.cityoflondon.gov.uk/Feedback, at the end of which is
located the FOI complaints procedure. If, having used the CoL’s FOI
Complaints Procedure, you are still dissatisfied, you may request the
Information Commissioner to investigate. Please contact: Information
Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.
Telephone: (01625) 545700.  Website: [2]http://www.ico.org.uk/.

 

The FOIA applies to the CoL as a local authority, police authority and
port health authority. Subject to any other statutory provisions requiring
the CoL to disclose information, release of information outside the scope
of the Act is subject to the discretion of the CoL.

 

The CoL holds the copyright in this communication. Its supply does not
give a right to re-use in a way that would infringe that copyright, for
example, by making copies, publishing and issuing copies to the public or
to any other person. Brief extracts of any of the material may be
reproduced under the fair dealing provisions of the Copyright, Designs and
Patents Act 1988 (sections 29 and 30) for the purposes of research for
non-commercial purposes, private study, criticism, review and news
reporting, subject to an acknowledgement of the copyright owner.

 

Yours sincerely,

 

Business Support Manager |  Commissioning and Partnerships Division 

City of London Corporation |Telephone 020 7332 3498|
[3]www.cityoflondon.gov.uk

 

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
1. http://www.cityoflondon.gov.uk/Feedback
2. http://www.ico.org.uk/
3. http://www.cityoflondon.gov.uk/

Dear DCS FOI,

Thank you for replying to part of my request.

It is very disappointing that these important stakeholder meetings were considered 'informal', and no notes were taken to ensure that the Interim DPH could be accountable for the work. We could assume that other senior health stakeholders were willing to be accountable for their input. Was this process documented in any way?

On part 2 of my request, you sent me part of a staff equalities impact assessment which I did not ask for.

You did not send me "any assessments of risks to health inequalities, to services, or to data protection" which I did ask for, or give a reason that you did not provide these, as required under the act.

Please can you complete this request now?

Yours sincerely,

Sam Flowers

COL-EB-InformationOfficer, City of London Corporation

Dear Sam Flowers,

 

The City of London (CoL) acknowledges receipt of your complaint of 19
January 2021, as set out below.

 

In accordance with guidance published by the Information Commissioner’s
Office, the CoL aims to respond to complaints within 20 working days
beginning from the first working day following receipt of the complaint.

 

Yours sincerely,

 

Information Officer

Comptroller & City Solicitor’s Department City of London

Tel: 020-7332 1243

[1]www.cityoflondon.gov.uk

 

dangos adrannau a ddyfynnir

COL-EB-InformationOfficer, City of London Corporation

2 Atodiad

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Dear Sam Flowers

 

FREEDOM OF INFORMATION ACT 2000 (FOIA) - Complaint

 

Following your complaint of 19 January 2021, and our acknowledgement 20
January 2021, regarding our FOIA response of 23 December 2020 to your
request of 27 October 2020, please find our independent assessment of your
complaint, compiled from the information made available to us, as follows.

 

Your request of 27 October 2020 asked for the following information, I
have included our response:

 

1.             Any records to show whether your organisation was consulted
as part of the restructure of the City & Hackney Public Health service in
2019.  Please see our response at Question 3

 

2.             Copies of all material which was given to you setting out
the proposal (including any assessments of risks to health inequalities,
to services, or to data protection).  A redacted copy of the Staff
Equalities Impact Assessment was provided

 

3.             Copies of any response your organisation made, and notes of
any related meeting minutes, copies of emails or any other documentation. 

This exercise is not customary for staffing restructures.  There was
informal engagement with some stakeholders by the interim Director of
Public Health, Dr. Sue Milner.  No notes were taken of these
meetings/conversations since they were informal and the stakeholders
understood that their comments were given in confidence and would not be
shared.

4.             It would also be helpful to know whether:  Information not
held

a.         you supported the staff cuts or new service vision

b.         you received sufficient information

c.         your input was reflected in the final vision and structure of
the service

 

In Your complaint you requested

 

It is very disappointing that these important stakeholder meetings were
considered 'informal', and no notes were taken to ensure that the Interim
DPH could be accountable for the work.  We could assume that other senior
health stakeholders were willing to be accountable for their input.  Was
this process documented in any way? No

 

On part 2 of my request, you sent me part of a staff equalities impact
assessment which I did not ask for.

 

You did not send me "any assessments of risks to health inequalities,  to
services, or to data protection" which I did ask for, or give a reason
that you did not provide these, as required under the act. Information not
held

 

Following receipt of your complaint we have carried out a review of the
documentation held in respect of the restructure of City and Hackney
Public health Service and no further documentation is held apart from that
which was provided to you in our response of 23 December 2020. The Staff
Equalities Impact Assessment was provided as this was the closest document
to what was requested and may have been of use to you.

 

In conclusion the CoL does not uphold your complaint concerning the FOIA
response

 

We hope this independent assessment of your complaint regarding your FOIA
response has been helpful. However, if you have any queries or concerns,
please contact us.

 

If you are still dissatisfied, you may request the Information
Commissioner to investigate. The Information Commissioner is a Crown
appointment, responsible for monitoring compliance with the FOIA. Please
contact: Information Commissioner, Wycliffe House, Water Lane, Wilmslow,
Cheshire, SK9 5AF. Telephone: (01625) 545700. Website: [1]www.ico.org.uk

 

Yours sincerely,

 

Information Officer

Comptroller & City Solicitor’s Department

Tel: 020-7332 1243

[2]www.cityoflondon.gov.uk

 

To mitigate the risk posed by Covid-19 please send all correspondence and
related documentation to the Comptroller and City Solicitor’s department
by email only, unless hard copies are requested or are required due to the
terms of other documents or statutory requirements. Service of documents
is only accepted by email or fax where express written authority is
provided. Where hard copies are sent please advise the relevant staff
member to ensure receipt can be monitored

 

 

 

 

THIS E-MAIL AND ANY ATTACHED FILES ARE CONFIDENTIAL AND MAY BE LEGALLY
PRIVILEGED. If you are not the addressee, any disclosure, reproduction,
copying, distribution or other dissemination or use of this communication
is strictly prohibited. If you have received this transmission in error
please notify the sender immediately and then delete this e-mail.
Opinions, advice or facts included in this message are given without any
warranties or intention to enter into a contractual relationship with the
City of London unless specifically indicated otherwise by agreement,
letter or facsimile signed by a City of London authorised signatory. Any
part of this e-mail which is purely personal in nature is not authorised
by the City of London. All e-mail through the City of London's gateway is
potentially the subject of monitoring. All liability for errors and
viruses is excluded. Please note that in so far as the City of London
falls within the scope of the Freedom of Information Act 2000 or the
Environmental Information Regulations 2004, it may need to disclose this
e-mail. Website: http://www.cityoflondon.gov.uk

References

Visible links
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2. http://www.cityoflondon.gov.uk/