Dealing with FOI
Requests
at the BBC
_
A guide for FOI Divisional Reps
Information Policy & Compliance
Contents
Information Policy & Compliance ........................................................................................................... 1
Contents ....................................................................................................................................................... 2
PURPOSE OF THIS DOCUMENT......................................................................................................... 3
IPC TEAM CONTACT DETAILS ...................................................................................................... 3
A SUMMARY OF THE FOI PROCESS .................................................................................................. 4
HOW TO HANDLE FOI REQUESTS................................................................................................... 5
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PURPOSE OF THIS DOCUMENT
This document explains the process that divisional FOI reps should follow when dealing with
Freedom of Information requests.
The Information Policy & Compliance (IPC) team will receive and log requests, send them
out to divisional reps, redact and send out documents when necessary, advise FOI reps on
exemptions, send out final responses etc. The team are also responsible for keeping records
of all requests received and responses sent.
Divisional reps are responsible for gathering together information, considering whether any
exemptions may apply, and drafting responses to requesters. They are also responsible for
passing on information to the IPC team, where necessary, to enable the team to keep full
records.
Details of how divisional and departmental reps should deal with FOI requests are contained
in this document.
IPC TEAM CONTACT DETAILS
FOI Advice (in the Outlook address book)
or xxxxxxxxx@xxx.xx.xx
This is our internal address. Use this email address for: forwarding to the IPC team FOI
requests that have come into your division, sending draft responses, documents for
redaction, advice on exemptions etc.
FOI Enquiries (in the Outlook address book)
Or xxx@xxx.xx.xx
This email address is for external use, i.e. for use by members of the public wishing to make
a request under the Act.
Both inboxes are monitored throughout the day.
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A SUMMARY OF THE FOI PROCESS
This page is an outline of the process used to answer Requests For Information
(RFIs). For more details, please refer to following pages.
x
An
FOI request arrives in writing at the BBC and is sent to the IPC team who log
and acknowledge it, and decide which division it should be sent to.
x
Valid requests are
sent to the divisional rep by email. Other interested parties
may be copied in on RFIs, but do not need to take any action.
x
RFIs should be dealt with
promptly and not put off. The response may require input
from other areas of the BBC, a lot of work recovering information or time redacting
(removing text) from documents.
x
If the RFI has been delegated to the
wrong division, i.e. if the divisional rep does
not hold the information requested, the rep should contact the IPC team
immediately to discuss re-delegating the request.
x
The divisional rep organises the retrieval of the
relevant information within their
division. Divisional reps may delegate the retrieving of the information to others
within their division who are better placed to find it.If the rep needs to arrange a
meeting with the IPC team to discuss the response, this should be done promptly.
x
The rep creates a
draft response. This will usually be in the form of a letter based
on the templates created by the IPC team, and may or may not include disclosure
documents as well. The draft response is sent to the IPC team.
x
If necessary, the IPC team suggest any any appropriate amendments to the response.
x
If
Schedule 1 or any
exemptions apply and text needs to be
redacted from a
document, this can be done by the IPC team. The rep should indicate which text is
to be redacted, and which exemption applies, before sending the document to the
IPC team.
x
Once all parties have agreed on the
final response, the IPC team convert the
Word document to .pdf and send this out from their FOI email address, blind
copying it to the divisional rep.
x
The IPC team use information sent to them by the FOI reps to
log all the details of
each request and response.
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HOW TO HANDLE FOI REQUESTS
These instructions cover: receiving FOI requests, preparing your response and returning it
to the IPC team for checking or advice. To help you manage your FOI requests effectively,
please note the following:
x
FOI emails: to help you store and keep track of any RFIs delegated to you, you may
wish to create an FOI subfolder in your Outlook inbox. See details on page 7 of this
document if you need further advice on how to do this.
x
Out of office message: please ensure that your out of office message includes an
alternative contact name. You do not need to mention FOI but it is important that
the IPC team and requesters can access an alternative contact to send the RFI to.
Receiving requests from the IPC team
1. Please look out for new FOI requests delegated to you. These are most likely to be
sent by the IPC team Advisers – Fern Kersey, Louise Wright, Rachael Ward, Helen
Padley and Rachel Hallett. The email will show the original request; this will be
attached as a scanned document if it came in as a letter. The email may also contain
some advice about responding to the request, eg it will indicate if the IPC team
considers the information to be out of scope.
2. If you need any clarification or help with the RFI, or if you think your division does
not hold the information requested, contact the IPC team member who sent it to
you immediately either by phone or by replying to the email. If you cannot contact
the sender, please get in touch with another member of the IPC team – all members
of the team can access the FOI Advice email inbox.
Gathering the information and redacting exempt information
1. Collect copies of all relevant material required to answer the RFI. You may need to
ask other people in the division to do this for you, as they have the best knowledge
of the records in their department and what is held.
2. If you believe there is information which needs to be withheld but you are not sure
about applying exemptions under the Act, please contact the IPC team for advice.
You should do this as soon as possible, as deciding on the application of exemptions
and considering the public interest can take some time.
3. If the document(s) you intend to send the requester needs redacting, mark the areas
to be redacted on the document, indicating which exemptions apply.
Hard copy: The documents can be sent to the IPC team in the internal post. Please
include a clean copy and a copy with the text to be removed marked up, eg by
underlining or with a marker pen. The section of the Act under which the text is exempt
should also be marked on the document.
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Electronic: Please provide electronic copies if possible as these are easier to redact. Again,
the IPC team need both a marked-up and a clean copy.
If your document is in Word format, you can underline or highlight in Word to mark the
text you intend to redact, and use the comment function to state which exemption.
If you have access to a scanner, you could mark-up a printout and email this across.
Alternatively, if it’s appropriate you could just provide a description of the sections to be
redacted, eg Par 4, first 3 sentences.
Sending your response
1. Once you have finished preparing your response, send it to the IPC team. Send it to
FOI Advice (xxxxxxxxx@xxx.xx.xx).
2. In the subject line of your email, please put the RFI number, the words draft
response and the due date, eg
RFI2005000234 – draft response – due 14th March. Your
email should include a covering note to the IPC team, and the following attachments:
- Your response letter
- Any document(s) that you are intending to send to the requestor as part of the
response. If you are intending to redact any documents, send both marked-up
and clean documents.
3. The IPC team will get back to you, sending confirmation that your draft response is
suitable or suggesting amendments to the draft. The IPC team will also send the
redacted documents if applicable.
4. Once both the IPC team and the reps (and the Press Office if the request is from a
journalist) are happy with the response, the IPC team will convert it to pdf format
and send it from the FOI email address. Sending documents in pdf format makes it
more difficult for requesters to track any changes and to alter the document
themselves. Sending it from our email address means that any response from the
requester, eg if they want an internal review, will come back to the IPC team rather
than the divisional rep.
Keeping documentation about FOI requests
The IPC team are responsible for keeping master copies of the documents for each FOI
request. For simple requests, this will consist of just the request and the response. For more
complex requests, it may be helpful to keep copies of the process by which it was decided
what to release and what to withhold. Please pass on to the IPC team any documentation
which you think it would be useful to keep on file. As the IPC team will keep any necessary
records, it is good practice to delete your records relating to the RFI – these are sometimes
requested in a follow-up request. Some divisional reps do prefer to keep copies of final
responses in order to refer to them quickly if a similar request comes in.
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STORING AND ACCESSING FOI INFORMATION
E-mail
Divisional reps and FOI reps may wish to create a separate folder in the Outlook inbox in
which to store emails about FOI requests. To do this, go to your folder list in Outlook,
right-click on Inbox, and select
New Folder.
Last updated: February 2010
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