Committee minutes
Dear Post Office Limited,
Please provide me with a copy of the following information:
1) The minutes of any meetings of the Audit, Risk and Compliance Committee that were held during the 2021/22 financial year.
Yours faithfully,
Helen Cross
Our ref: FOI2022/00383
Dear Helen Cross,
Thank you for your request for information which was received on 6th June.
Your request is being considered under the terms of the Freedom of
Information Act 2000.
The Act requires that a response must be given promptly, and in any event
within 20 working days. We will therefore reply at the latest by 4th July.
Please remember to quote the reference number above in any future
communications.
Yours sincerely,
Jackie Lawrence
Information Rights Team
Finsbury Dials, 20 Finsbury Street
London, EC2Y 9AQ
Dear Helen Cross
Please find an update attached relating to your Freedom of Information
request.
Regards
Jackie Lawrence
Information Rights Team
20 Finsbury Street
London EC2Y 9AQ
Good Morning,
Thank you for providing an update on my request for information.
I was surprised to read that you consider that you will need an additional 40 working days to consider the public interest in withholding some of the information that I have requested, and that you consider the material I have asked for to be both voluminous and complex.
In order to ensure that you have not misinterpreted my request, I want to make it clear that I have only asked for a copy of the minutes of the meetings, and not for any associated papers. Given the format that minutes take, I would not expect these to be particularly long or complex. I do not expect that the committee would have met sufficiently often during a single financial year to have generated the sort of volume of minutes that could justify an extension of this length.
I wish to point you to the ICO guidance on time for compliance with Freedom of Information requests, that states the following about extensions to the time limit to consider the public interest:
"The Act does not define what might constitute a ‘reasonable’ extension of time. However, our view is that an authority should normally take no more than an additional 20 working days to consider the public interest, meaning that the total time spent dealing with the request should not exceed 40 working days."
and
"An extension beyond this should be exceptional. Examples of such circumstances could include extreme pressures placed on the public authority by a major incident or exceptional levels of complexity involving a number of external parties."
https://ico.org.uk/media/for-organisatio...
I would ask you to please reconsider whether an extension of 40 working days is justified in the circumstances, and whether you aims could not be achieved by extending the deadline by 20 working days, as would more usual in this sort of case.
Yours sincerely,
Helen Cross
Dear Helen Cross,
Thank you for your email. Post Office's Audit, Risk and Compliance Committee met on 8 occasions during the 2021/22 financial year, and the minutes of those meetings alone total over 130 pages. The minutes cover a wide range of complex topics and as they are very recent, contain sensitive material which engages the qualified exemptions mentioned in our letter. Applying the public interest test across the different topics that engage those exemptions will require consultation with a number of third parties. Post Office has considered both the ICO guidance and the Freedom of Information Code of Practice and considers a 40 day extension to be reasonable in these circumstances.
Should you wish to submit a revised request, Post Office will consider this afresh.
Kind regards
Information Rights
Data Protection and Information Rights Team
Finsbury Dials, 20 Finsbury Street
London, EC2Y 9AQ
[Post Office request email]
Good afternoon,
Many thanks for providing this additional information. It has helped me to better understand your reasoning for extending the response deadline.
Yours sincerely,
Helen Cross
Dear Helen Cross
Please find an update attached relating to your Freedom of Information
request.
Regards
Information Rights Team
20 Finsbury Street
London EC2Y 9AQ
Dear Helen Cross
Thank you for your patience whilst we have been handling your FOI request.
Further to our previous extension letters, we still require further time
to consider the public interest test in relation to the exemptions under
sections 42 and 43(2) of the FOIA. Post Office considers that a further
extension of 20 working days is appropriate in this instance and therefore
the new target date has changed to 26th October.
Kind Regards
Data Protection and Information Rights Team
Helen Cross left an annotation ()
The ICO have written to the Post Office, and asked them to respond to my request within 10 working days. Ref: IC-194485-N7D4
Dear Helen Cross,
Thank you for your patience whilst we have been handling your request for
information. Please find the attached response and 8 additional documents.
Kind regards,
Information Rights Team
Finsbury Dials
20 Finsbury Street
London
EC2Y 9AQ
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Helen Cross left an annotation ()
With this latest extension, the Post Office have essentially said that they need 100 working days to answer a straightforward request for some minutes. I don't think that such a delay can be justified, so I have written to the ICO. Unfortunately, there is no legal time limit on how long an Authority can take to consider the public interest, however ICO guidance states that a request should not normally take longer than 40 working days to answer.