Dear South Derbyshire District 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).
*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.
Thank you for your request received 20/7/18 under the Freedom of Information Act 2000 (FOIA) about ‘Data Analytics Usage’.
Unfortunately, the Council is unable to identify the information you have requested from the details in your request.
Please clarify the following, so we can search if we hold the information requested.
It is not clear what information you want. This is because the introduction asks about "...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.", but the first question asks for information about software, hardware, operations and types of data (i.e. characteristics of the system, not its use). Please give examples of the types of system you want information about?
Section 12: Exceeds appropriate limit exemption could apply to the request. This is because it covers several services within the Council and it would take more than 18 hours to search through briefing notes, reports, evaluations etc. Therefore, please refine your request to ensure it can be processed within 18 hours, for example, by asking for information about a specific system only.
Section 43(2) Commercial data and Section 40(2) Personal data third party exemption could apply to contract information ( information about the systems and the names/contact details of employees). The Council is required to carry out a public interest test to determine if the information requested should be released. This would involve consulting any relevant supplies to see if they give consent for the information requested to be disclosed. Please clarify what you mean by the following …
• details about the existence of a system – what do you mean, give examples?
• it's purpose – what do you mean, give examples?
• the tasks being contracted – what do you mean, give examples?
• continued relationships – what do you mean, give examples?
• general descriptions – what do you mean, give examples?
• types of data being used – what do you mean, give examples?
• how this data is shared – what do you mean, give examples?.
We won’t be able to deal with your request until you provide the additional information.
The Freedom of Information Act 2000 says that we must comply with your request for information within 20 working days, from the date following receipt of your request unless we have to ask for clarification, as in this case. The 20 day response deadline clock has stopped from the date of this email, the clock will reset from the date we receive your response clarifying your request and we will advise you of the new 20 working day deadline at this stage.
Unfortunately, if we don’t hear from you by 26 September, we will send you a refusal notice because we have not received all the information we need to deal with your request.
Please contact us if you have any queries or concerns;
Data Protection Officer
South Derbyshire District Council
Telephone 01283 595795 or e-mail [email address]
Secretarial Support to Directors
T: 01283 595868
Please use this email address for all replies to this request:
[FOI #499288 email]
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