Dear Her Majesty's Treasury,

Please may I have

* a copy of the Combined Online Information System (COINS) database in an appropriate electronic format.

* the absolute size of the COINS database were it to be backed up and released in the form of portable media such as hard disks or DVDs.

I understand a similar request to mine has been turned down recently,[1] but I am unclear about what exemptions were applied or whether any further action has been taken.

[1] http://www.bbc.co.uk/blogs/opensecrets/2...

Yours faithfully,

Julian Todd

Dear Paul Morgan,

Thank you for your interim response to my request for the COINS database, where you stated that it occupies a modest 11GB of storage.

Whilst this database may contain some sensitive data concerning the formulation or development of government policy, a good deal of the historical data in the database can be disclosed under section 35(2)(a) owing to the decisions already having been taken on the basis of this factual statistical information.

Assuming that the COINS database is "statistical data" (and therefore does not require the reasonable opinion of a qualified person to make it exempt), your consideration of section 36(2)(c) could actually weigh in favour of the public interest in disclosure -- depending on exactly what sort of misinterpretation and follow-up requests you are anticipating from a disclosure.

In any case, a partial, limited disclosure of the database that fell clearly outside of section 35(1)(a), and whose measured proportion resulted in such a low volume of follow-up requests that it was not disruptive to the Treasury is certainly desirable.

Accordingly, a partial disclosure of at least a million lines from the database relating to some time interval in the past (large enough to test the concerns about the potential disruption), would be more acceptable than a blanket refusal.

Yours sincerely,

Julian Todd

Dear Paul Morran,

Thank you for your letter on 29 March 2010 concerning my request for the COINS data set. (Ref 10/160)

The particular combination of section 36(2)(c), that public disclosure of the database would cause significant cost and difficulty owing to its raw, unvalidated, impenetrable, and not necessarily accurate state, with section 35(1)(a) (formulation of government policy) raises many questions of public concern.

How much of government policy is based on analysis derived from this database? To what extent are the records in this database unreliable, and is it known and accounted for in the policy-making? What are the processes for improving the effectiveness of the data, and why does it not include publication in an on-line framework where the work of Treasury is improved rather than disrupted by multiple inquiries about inaccurate contents?

Regarding the main 6 exemptions described in the letter, these can only prevent disclosure of some of the 23 million records in the data set.

However, as I am persuaded that Treasury's position is unlikely to change, I am reserving my right to an internal review. Instead I am varying my request for information:

Please send me 23 complete records from the COINS database. These 23 records should:

* Be listed with all their eight dimensions

* Not include anything to do with the Security Services, anything defence related, or related to trading funds or public funded entities such as the BBC;

* Not include any future year data subject to Government and Parliamentary revision;

* Be drawn from at least 5 different years;

* Be selected from at least 5 different departments;

* Include at least 5 records each with value below £5,000, and 5 records each with value above £50,000.

If disclosure of the data identifiers or variable names associated to these records are considered exempt under section 43(1) (trade secrets) or section 43(3) (commercial confidentiality), please provide:

* equivalent names and/or descriptors for these fields,

* the length (numbers of characters) of the original redacted identifiers

* a statement from the commercial supplier of this software (Descisys) proclaiming that these identifiers actually are commercially sensitive.

Please contact me if these selection criteria need to be varied slightly for convenience. I would be surprised if it was difficult to disclose one millionth of this data set.

Yours sincerely,

Julian Todd

Dear Paul Morran,

*Request for internal review of my FOI request for 23 records from the COINS database*

Thank you for your 21 April 2010 reply to my amended FOI request for information held in the COINS database.

My original 19 February request was for the complete data set, and I was informed of its refusal on 29 March owing to "the likelihood of harm from disclosure arising from misinterpretation of the 23 million lines of raw and unvalidated data and/or a high volume of follow-up requests and enquiries" -- among other exemptions which could only apply to certain subsets of the data.

Accordingly, I revised my request for only 23 complete records or lines of your choice, and this was refused because "it is possible to define the term 'complete record' in a number of different ways" -- followed by a repeat of the same 5 exemptions that would not apply to such a small subset of records if they were fairly selected for the purpose of disclosure.

The exemptions on a hand-selected set of 23 records (one millionth of the data set) require no further comment, so I will focus on the definition of a line or a record. A concept of such must be known to you, otherwise the number 23 million could not have been counted.

I understand that each data record has dimensions that can be opened out onto other data tables into an endlessly recursive scheme. As with any FOI request, "complete record" is to be understood as "...so far as it would be reasonable to expect the authority to do so" (Section 16(1)). It is up to you to interpret my lack of precision, which is unavoidable owing to the lack of disclosure of numerous details relating the system in earlier requests.

For an idea of how to interpret my request for 23 complete records, I refer to this redacted copy of the COINS training manual:

http://www.whatdotheyknow.com/request/28...

Page 33 of this document explains how to load data into COINS, adding that "The Data file Columns section at the top of the screen shows the 15 columns expected." The 15 columns are the 12 months of the year, the organisation, SCOA and Programme Object. Each line in the upload file probably corresponds to 12 records in the data set.

Page 16 outlines a second way to make changes to the COINS database through an Adjustment. A record in the data set to an outsider who does not have technical detailed knowledge of the exact configuration of the data set probably means a page of that which is shown in a single view for the purposes of making an Adjustment. It would be acceptable to disclose copies of 23 of these views. If they happen to contain data for future years in one of the columns, then redact them! I am not going to complain if data that strictly exceeds the quantity of records requested is disclosed, so please err on the side of generosity.

Thank you for reviewing this FOI request. I am sure that a satisfactory result could be provided without too much work.

Yours faithfully,
Julian Todd

Dear Peter Jennings,

Thank you for your letter of 4 June 2010 reminding me that the COINS database has been published within days of a new administration taking power. Clearly the events are related.

My original request on 19 February 2010 for the COINS database was turned down by virtue of the application of at least 6 different exemptions. My revised request for a fraction of the database (one millionth) was also turned down for the same reasons.

It is possible that these exemptions told to me were wholly without merit.

Can you comment on:

1) whether the exemptions were incorrectly applied to my requests

2) the reasons for this incorrect application of the exemptions to my requests (eg political interference)

3) if steps have been taken to rectify the situation so that FOI requests to the Treasury are properly handled in the future.

Many thanks to all the team who have arranged for this public interest information to be disclosed. I only hope that this change in culture remains permanent.

Yours sincerely,

Julian Todd

Dear Kate Jenkins,

Thank you for your reply of 30 June 2010 concerning my FOI request. Reference to Sections 35 and 36 do clarify the extent of the political involvement in preventing disclosure at the time of my request.

Your explanation of Section 36(5)(a) indicated that the "qualified person" has to be a minister.

Can you disclose the name of the minister in question?

Yours sincerely,

Julian Todd