Structure chart request

Jordan Groves made this Rhyddid Gwybodaeth request to Achieving for Children

Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

Mae'r ymateb i'r cais hwn yn hwyr iawn. Yn ôl y gyfraith, ym mhob amgylchiad, dylai Achieving for Children fod wedi ymateb erbyn hyn. (manylion). Gallwch gwyno drwy yn gofyn am adolygiad mewnol.

Dear Achieving for Children,

Please provide the organisational structure charts (including names, job title and contact details) for the Children's, Adult's Social care and Education directorates covering the following job titles:

Director, assistant director, Head of Service, Service Manager.

I look forward to your response.

Yours faithfully,

Jordan Groves

AfC Freedom of Information and Subject Access Requests, Achieving for Children

Dear Mr Groves,
Your Freedom of Information request has been considered.
Your Request
Please provide the organisational structure charts (including names, job
title and contact details) for the Children's, Adult's Social care and
Education directorates covering the following job titles:

Director, assistant director, Head of Service, Service Manager.
The Achieving for Children Senior Management Structure is publicly
here: [1]
This provides the names of Directors, Associate Directors, and Heads of
Service within Children's Services across Achieving for Children,
including our staff in the Royal Borough of Windsor and Maidenhead.
Please note that your request for an organisational structure chart for
Children’s Social Care and Education directorates would include details of
individual employees below Head of Service level who have not explicitly
consented to the disclosure of this information, therefore, it
is refused on the grounds that the release of this information would
constitute the disclosure of personal data about the individuals that
could be used to identify them. 
We appreciate that there are positions within Achieving for Children which
could justify the disclosure of personal information, for example, if the
role was public facing or the level of seniority would imply a degree of
public scrutiny. As a result, we publish the names and contact details of
our Chief Executive, Directors, Assistant Directors and Heads of Service
on our website as linked above, however, we do not believe that employees
below this level would expect their personal information to be disclosed
in this way, therefore, we believe it would breach the General Data
Protection Regulation (GDPR).

Specifically, in terms of the provisions of the Freedom of Information Act
2000, it is exempt under Section 40(2) as “personal data other than that
of the requestor”. The definition of personal data is set out in section 1
of the Act and provides:

• "personal data” means data which relate to a living individual who can
be identified —

(a) from those data, or
(b) from those data and other information which is in the possession of,
or is likely to come into the possession of the data controller and
includes any expression of opinion about the individual and any indication
of the intentions of the data controller or any other person in respect of
the individual;

In coming to this decision, we have taken into consideration
the GDPR principles. The second principle of Article 5 of the GDPR states
that any personal data must only be collected for specified, legitimate
and explicit purposes and not further processed in a manner that is
incompatible with those purposes and we do not consider this to be a
compatible purpose. Furthermore, such information should be processed in
accordance with the rights of the data subjects who would have a
legitimate expectation that the information would not be disclosed to
members of the public, as stated in Principle 6 of Article 6. We consider
that the disclosure of this information to members of the public could
cause damage or distress to the data subjects. 
In reaching a view, we have taken account of the individual’s reasonable
expectations of what would happen to their personal data and whether
disclosure would be incompatible with the purposes for which it was
obtained and whether disclosure would cause any unnecessary or unjustified
damage to the individual. In this particular case the data subjects would
not have any reasonable expectation that the details would be made public.

We have concluded that it is neither in accordance with
the GDPR principles nor in the public interest to release the names and
job titles of employees below Assistant Director Level where this
information is not already on our website.

In accordance with the Freedom of Information Act 2000 this letter acts as
a partial Refusal Notice.

You have the right of appeal against the decision. If you wish to appeal
please set out in writing your grounds of appeal and send to:

Associate Director for Strategy and Transformation
2nd Floor
42 York Street

E-mail: [2][Achieving for Children request email]
If you are dissatisfied with the outcome of the internal appeal you may
appeal further to the information Commissioner’s Office at:

Wycliffe House  
Water Lane  

Yours sincerely,
Chantelle Elliott  
Information Governance Support 
Business Services and Transformation
Email: [4][Achieving for Children request email]
Achieving for Children
42 York Street, Twickenham, TW1 3BW


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