Data Justice Lab

Dear Luton Borough Council,

We are submitting the following Freedom of Information Request for documents relating to uses of data analytics, predictive analytics, or algorithmic automated systems used for risk assessment, scoring systems or automated decision making within the jurisdiction of your authority. This could include the use of these data systems in order to draw insights from large and integrated datasets, or to influence decisions about resources, funding or service delivery. This could include, but may not be limited to, uses of predictive analytics in child welfare, health care, adult social care, fraud detection, or policing.

Specifically, we are requesting:

· Any briefing notes, reports, evaluations, or summaries concerning uses of algorithmically driven data systems. Ideally this would include information about software, hardware, operations and types of data

· Any overviews about how system outputs are produced.

· Any training manuals or materials (e.g. slides, etc.) for staff about data collection, analysis, assessment and reporting as related to the use of the systems.

. Any impact assessments

· Any data visualisation outputs connected to the systems.

· Any promotional material, presentation material, or staff educational material related to the systems.

. Any contracts relating to the systems. We argue that the release of contracts does not compromise commercial sensitivity. The full argument is provided below.*

Also, please note we are not requesting datasets or any data about individuals.

Please let us know if any information requires clarifying.

We would like to receive electronic copies of this information.

All the very best,

Data Justice Lab

Please note that we are following the Information Commissioner’s guidance on the Freedom of Information Act which specifies that requests can be made by organisations and there is no need for a named individual (pages 9-10, sections 38-39).
Source: https://ico.org.uk/media/for-organisatio...

*Addressing the commercial sensitivity question:
a) Section 20 of the Department for Communities and Local Government’s ‘Local Government Transparency Code 2015’, which encourages greater transparency in the public interest, notes:

‘The Government has not seen any evidence that publishing details about contracts entered into by local authorities would prejudice procurement exercises or the interests of commercial organisations, or breach commercial confidentiality unless specific confidentiality clauses are included in contracts. Local authorities should expect to publish details of contracts newly entered into – commercial confidentiality should not, in itself, be a reason for local authorities to not follow the provisions of this Code’.

Source: https://assets.publishing.service.gov.uk... (page 9, section 20)

b) There is always the potential for a company in any area to act in bad faith, but this should not be a reason to deny access to information about how public money is spent.

c) Contract and tendering details are provided regularly by a range of government bodies in the public interest. For example, many police and fire services release contractual information through the Bluelight database ( https://www.blpd.gov.uk/foi/foi.aspx ).

d) There may be core aspects of the systems contracted that have competitive commercial value and we appreciate that such details will be redacted from any documents released. We argue that commercial interests will not be compromised by revealing other details that may be provided in contracts or related communications with contracted companies. Details that could be released include details about the existence of a system, it's purpose, the tasks being contracted, continued relationships, general descriptions, types of data being used, how this data is shared.

LBC Feedback, Luton Borough Council

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Dear sir or madam,

Further to your request for information we confirm we do hold the information requested. Please see our response below.

The Council uses two tools for automated assessment. One FACE tool is used by Social Care to produce a Resource Allocation Score (RAS) and the other in Revenues & Benefits, which is a solution provided by Capita.

This information is being provided as a statutory obligation under the Freedom of Information Act 2000.

Please note that under the Privacy and Electronic Communications (EC Directive) Regulations 2003 Luton Council ask not to receive unsolicited marketing communications.

You are free to use the information provided for your own purposes, including any non-commercial research you are doing and for the purposes of news reporting. Any other re-use, for example commercial publication, requires the permission of the copyright holder. You may apply for permission to re-use this information by submitting a request to [email address]  .

Detailed advice about the Reuse of Public Sector Information Regulations (PSI) 2005 is available from the Office of Public Sector Information at: Office of Public Sector information.

If you are not satisfied with our response to your request(s), you can ask for a review of how we have handled it, by contacting us at the address above or by contacting emailing us at [email address]  . Please set out any specific concerns you have. If you have any other queries or concerns then please contact us using the above details. Please quote the reference number provided above when contacting us.

Should you remain unhappy with our response after we have reviewed it, you can refer your concerns to the Information Commissioner Further information on the Freedom of Information Act is available through the Information Commissioner at:

Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Telephone: 01625 545 700
Internet: www.ico.gov.uk

Yours sincerely,

Information Governance Team
Luton Borough Council
Town Hall, George Street, Luton LU1 2BQ
Email: [email address]

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