Early Help Profiling System

Jack Maxwell made this Freedom of Information request to Thurrock Borough Council

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Dear Thurrock Borough Council,

In relation to the Council's Early Help Profiling System, please provide the following information:

1. The most recent evaluation or review of the System's operation and impact.

2. Any policy, guidance, or training documents regarding the System or how staff are to use the System.

3. The current data protection impact assessment for the System.

4. Any assessment of the System conducted for the purpose of complying with the public sector equality duty under Equality Act s.149.

5. Any reports, studies or other documentation describing possible biases or
unfairness in the System’s results.

6. Any reports about the accuracy or validity of the System’s results.

If you determine that my request exceeds the cost limit under FOIA s.12, please prioritise my questions in the order at which I have presented them.

Yours faithfully,

Jack Maxwell

Information.Matters@thurrock.gov.uk, Thurrock Borough Council

Thank you for your email. 

Your enquiry is important to us and will be recorded and responded to in
line with respective timeframes.  Our team will monitor the progress of
your enquiry to ensure you receive a timely response.

Data Protection Statement

We will use your information to provide the service requested. We may
share your personal data between our services and with partner
organisations, such as government bodies and the police. We will do so
when it is of benefit to you, or required by law, or to prevent or detect
fraud. To find out more, go to [1]thurrock.gov.uk/privacy. Get free
internet access at libraries and community hubs

Regards,

Rachael Steel
Senior Data Protection Officer

 

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The information in this e-mail and any attachment(s) are intended to be
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Council's corporate e-mail system and may be subject to scrutiny by
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compliance. To find out more [2]Click Here.

References

Visible links
1. http://thurrock.gov.uk/privacy
2. http://www.mimecast.com/products/

Information.Matters@thurrock.gov.uk, Thurrock Borough Council

1 Attachment

Dear Mr Maxwell,

Thank you for your recent communication which is being managed in line
with the Freedom of Information Act under the above reference number. The
details of your request are outlined below together with the council’s
response.

Your request and Our Response

1. The most recent evaluation or review of the System's operation and
impact.

The EHPS system is no longer being implemented at Thurrock. Our approach
to identifying families for Early Help is through Troubled Families and
the Brighter Futures Partnership.
2. Any policy, guidance, or training documents regarding the System or how
staff are to use the System.

See above

3. The current data protection impact assessment for the System.

See above

4. Any assessment of the System conducted for the purpose of complying
with the public sector equality duty under Equality Act s.149.

See above

5. Any reports, studies or other documentation describing possible biases
or unfairness in the System’s results.

See above

6. Any reports about the accuracy or validity of the System’s results.

See above

You are free to use any information supplied to you for your own use,
including non-commercial research purposes. However, any other type of
re-use, for example, by publishing the information or issuing copies to
the public will require the permission of the copyright owner.

Where the copyright is owned by Thurrock Council, you must apply to the
Council to re-use the information.  Please email
[1][Thurrock Borough Council request email] if you wish to re-use the
information you have been supplied. For information where the copyright is
owned by another person or organisation, you must apply to the copyright
owner to obtain their permission.

If you are dissatisfied with the way in which the council have managed
your FOI request you can pursue an Internal Review by contacting us using
the above email address. Your request will be considered by the Strategic
Lead for Information Management who will update you with the outcome of
the review. 

If you remain unhappy following the outcome of your Internal Review you
may wish to refer your case to the Information Commissioner’s Office
(ICO), details of this organisation can be found at [2]www.ico.org.uk.
Alternatively they can be contacted on 0303 123 1113. Please be advised
that the ICO will not consider your case until they have confirmation that
you have already been through the Internal Review stage with the council.

 

Kind regards,

 

Fatma Mohamed l Information Governance apprentice l HR, OD &
Transformation

[3]thurrock.gov.uk l l t +44 (0) 1375 652649 l Ext 52342

Thurrock Council, Civic Offices, New Road, Grays, Essex RM17 6SL

 

An ambitious and collaborative community which is proud of its heritage
and excited by its diverse opportunities and future

 

[4]cid:image001.png@01CECE72.3F5FA730

 

Save time, do it online

[5]facebook.com/thurrockcouncil | [6]twitter.com/thurrockcouncil |
[7]https://www.thurrock.gov.uk/access-to-in...
|
[8]https://www.thurrock.gov.uk/information-...

 

Disclaimer

The information in this e-mail and any attachment(s) are intended to be
confidential and may be legally privileged. Access to and use of its
content by anyone else other than the addressee(s) may be unlawful and
will not be recognised by Thurrock Council for business purposes. If you
have received this message by mistake, please notify the sender
immediately, delete it and do not copy it to anyone else. Thurrock Council
cannot accept any responsibility for the accuracy or completeness of this
message as it has been transmitted over a public network.

Any opinions expressed in this document are those of the author and do not
necessarily reflect the opinions of Thurrock Council.

Any attachment(s) to this message has been checked for viruses, but please
rely on your own virus checker and procedures.

Senders and recipients of e-mail should be aware that under the UK Data
Protection and Freedom of Information legislation these contents may have
to be disclosed in response to a request.

All e-mail sent to or from this address will be processed by Thurrock
Council's corporate e-mail system and may be subject to scrutiny by
someone other than the addressee.

This email has been scanned for viruses and malware, and may have been
automatically archived by Mimecast Ltd, an innovator in Software as a
Service (SaaS) for business. Providing a safer and more useful place for
your human generated data. Specializing in; Security, archiving and
compliance. To find out more [9]Click Here.

References

Visible links
1. mailto:[Thurrock Borough Council request email]
2. http://www.lgo.org.uk/
3. http://www.thurrock.gov.uk/
5. http://facebook.com/thurrockcouncil
6. http://www.twitter.com/thurrockcouncil
7. https://www.thurrock.gov.uk/access-to-in...
8. https://www.thurrock.gov.uk/information-...
9. http://www.mimecast.com/products/

Dear Thurrock Borough Council,

Please pass this on to the person who conducts Freedom of Information reviews.

I am writing to request an internal review of Thurrock Borough Council's handling of my FOI request 'Early Help Profiling System'.

I requested copies of various documents regarding the Council's Early Help Profiling System (EHPS). Your response simply stated that you are no longer using the EHPS.

This is not an adequate response to my request. Even if the Council is no longer using the EHPS, it is presumably still in possession of some or all of the documents requested. Please disclose those documents as originally requested.

A full history of my FOI request and all correspondence is available on the Internet at this address: https://www.whatdotheyknow.com/request/e...

Yours faithfully,

Jack Maxwell

Information.Matters@thurrock.gov.uk, Thurrock Borough Council

1 Attachment

Dear Mr Maxwell,

 

I am writing further to your request below.  I would like to offer our
sincere apologies as unfortunately there will be a delay in providing a
response to your Internal Review in view of the Christmas break.  Please
be assured your request is being reviewed and you will be provided with a
response as soon as possible.

 

Thank you for your patience in this matter.

 

Many thanks

 

Tina Barrell

 

Tina Barrell l Complaints & Information Governance Assistant I HR, OD &
Transformation

[1]thurrock.gov.uk l ext: 64882

Thurrock Council, Civic Offices, New Road, Grays, Essex RM17 6SL

 

Please copy in [2][Thurrock Borough Council request email] in relation to all
FOI matters.

 

Thurrock: an ambitious and collaborative community which is proud of its
heritage and excited by its diverse opportunities and future

[3]cid:image002.png@01D542FF.BD4CAC30

Save time, do it online

[4]facebook.com/thurrockcouncil | [5]twitter.com/thurrockcouncil |
[6]https://www.thurrock.gov.uk/access-to-in...

 

 

From: Jack Maxwell <[FOI #705637 email]>
Sent: 03 December 2020 17:39
To: [email address]
Subject: Internal review of Freedom of Information request - Early Help
Profiling System

 

Dear Thurrock Borough Council,

Please pass this on to the person who conducts Freedom of Information
reviews.

I am writing to request an internal review of Thurrock Borough Council's
handling of my FOI request 'Early Help Profiling System'.

I requested copies of various documents regarding the Council's Early Help
Profiling System (EHPS). Your response simply stated that you are no
longer using the EHPS.

This is not an adequate response to my request. Even if the Council is no
longer using the EHPS, it is presumably still in possession of some or all
of the documents requested. Please disclose those documents as originally
requested.

A full history of my FOI request and all correspondence is available on
the Internet at this address:
[7]https://www.whatdotheyknow.com/request/e...

Yours faithfully,

Jack Maxwell

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[8][FOI #705637 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[9]https://www.whatdotheyknow.com/help/offi...

For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
[10]https://www.whatdotheyknow.com/help/ico-...

Please note that in some cases publication of requests and responses will
be delayed.

If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.

show quoted sections

Information.Matters@thurrock.gov.uk, Thurrock Borough Council

1 Attachment

Dear Mr Maxwell,

 

Please accept our apologies for the further delay in respect of the above
Internal Review.  We are still awaiting a response from the service and
will continue to chase for a response. 

 

Thank you for your continued patience in this matter.

 

Many thanks

 

Tina Barrell

 

Tina Barrell l Complaints & Information Governance Assistant I HR, OD &
Transformation

[1]thurrock.gov.uk l ext: 64882

Thurrock Council, Civic Offices, New Road, Grays, Essex RM17 6SL

 

Please copy in [2][Thurrock Borough Council request email] in relation to all
FOI matters.

 

Thurrock: an ambitious and collaborative community which is proud of its
heritage and excited by its diverse opportunities and future

[3]cid:image002.png@01D542FF.BD4CAC30

Save time, do it online

[4]facebook.com/thurrockcouncil | [5]twitter.com/thurrockcouncil |
[6]https://www.thurrock.gov.uk/access-to-in...

 

 

From: Barrell, Tina On Behalf Of [email address]
Sent: 04 January 2021 10:32
To: '[FOI #705637 email]'
<[FOI #705637 email]>
Subject: FOI 10437 - Internal Review of Freedom of Information request -
Early Help Profiling System

 

Dear Mr Maxwell,

 

I am writing further to your request below.  I would like to offer our
sincere apologies as unfortunately there will be a delay in providing a
response to your Internal Review in view of the Christmas break.  Please
be assured your request is being reviewed and you will be provided with a
response as soon as possible.

 

Thank you for your patience in this matter.

 

Many thanks

 

Tina Barrell

 

Tina Barrell l Complaints & Information Governance Assistant I HR, OD &
Transformation

[7]thurrock.gov.uk l ext: 64882

Thurrock Council, Civic Offices, New Road, Grays, Essex RM17 6SL

 

Please copy in [8][Thurrock Borough Council request email] in relation to all
FOI matters.

 

Thurrock: an ambitious and collaborative community which is proud of its
heritage and excited by its diverse opportunities and future

[9]cid:image002.png@01D542FF.BD4CAC30

Save time, do it online

[10]facebook.com/thurrockcouncil | [11]twitter.com/thurrockcouncil |
[12]https://www.thurrock.gov.uk/access-to-in...

 

 

From: Jack Maxwell <[13][FOI #705637 email]>
Sent: 03 December 2020 17:39
To: [14][email address]
Subject: Internal review of Freedom of Information request - Early Help
Profiling System

 

Dear Thurrock Borough Council,

Please pass this on to the person who conducts Freedom of Information
reviews.

I am writing to request an internal review of Thurrock Borough Council's
handling of my FOI request 'Early Help Profiling System'.

I requested copies of various documents regarding the Council's Early Help
Profiling System (EHPS). Your response simply stated that you are no
longer using the EHPS.

This is not an adequate response to my request. Even if the Council is no
longer using the EHPS, it is presumably still in possession of some or all
of the documents requested. Please disclose those documents as originally
requested.

A full history of my FOI request and all correspondence is available on
the Internet at this address:
[15]https://www.whatdotheyknow.com/request/e...

Yours faithfully,

Jack Maxwell

-------------------------------------------------------------------
Please use this email address for all replies to this request:
[16][FOI #705637 email]

Disclaimer: This message and any reply that you make will be published on
the internet. Our privacy and copyright policies:
[17]https://www.whatdotheyknow.com/help/offi...

For more detailed guidance on safely disclosing information, read the
latest advice from the ICO:
[18]https://www.whatdotheyknow.com/help/ico-...

Please note that in some cases publication of requests and responses will
be delayed.

If you find this service useful as an FOI officer, please ask your web
manager to link to us from your organisation's FOI page.

show quoted sections

Dear Ms Barrell,

Thank you for providing those updates. I note that the Council is now significantly overdue in its response to my request for internal review. I look forward to receiving the Council's response as soon as possible.

Yours sincerely,

Jack Maxwell

Information.Matters@thurrock.gov.uk, Thurrock Borough Council

2 Attachments

 

Dear Mr Maxwell,

 

I am writing to advise that the investigation of your Internal Review
received on 03 December 2020 has now been concluded.  Please accept my
apologies for the long delay, the officer required to provide the answer
is heavily involved in other current pressing issues which took priority.

 

Your request:

 

1. The most recent evaluation or review of the System's operation and
impact.
2. Any policy, guidance, or training documents regarding the System or how
staff are to use the System.
3. The current data protection impact assessment for the System.
4. Any assessment of the System conducted for the purpose of complying
with the public sector equality duty under Equality Act s.149.
5. Any reports, studies or other documentation describing possible biases
or unfairness in the System’s results.
6. Any reports about the accuracy or validity of the System’s results.

 

 

The Council’s original reply:

 

1. The most recent evaluation or review of the System's operation and
impact.

The EHPS system is no longer being implemented at Thurrock. Our approach
to identifying families for Early Help is through Troubled Families and
the Brighter Futures Partnership.
2. Any policy, guidance, or training documents regarding the System or how
staff are to use the System.

See above

3. The current data protection impact assessment for the System.

See above

4. Any assessment of the System conducted for the purpose of complying
with the public sector equality duty under Equality Act s.149.
See above

5. Any reports, studies or other documentation describing possible biases
or unfairness in the System’s results.

See above

6. Any reports about the accuracy or validity of the System’s results.
See above

 

 

Request for Internal review:

 

I requested copies of various documents regarding the Council's Early Help
Profiling System (EHPS). Your response simply stated that you are no
longer using the EHPS.

This is not an adequate response to my request. Even if the Council is no
longer using the EHPS, it is presumably still in possession of some or all
of the documents requested. Please disclose those documents as originally
requested.

 

 

Outcome of Internal Review:

 

I have reviewed the council’s original reply to your FOI request and taken
into consideration the points you raised in your email dated 03/12/2020. 
It is my view that the council approached the reply incorrectly and could
have supplied more information. Please see details below:

 

1.    The most recent evaluation or review of the System's operation and
impact.

There is no recent review as the EHPS has been superseded as mentioned
previously. A report was taken to cabinet on 11.07.2018 that discusses
Phase 3 data modelling – see link –
[1]https://thurrockintranet.moderngov.co.uk...

Face to face presentations would have been given by Xantura. Example
attached.

Currently, impact, performance and bias analysis are integrated into the
Xantura system and available as on-line dashboards to authorised users
only.

 

2.    Any policy, guidance, or training documents regarding the System or
how staff are to use the System.

User guides, training documentation etc. are owned by Xantura and we do
not have permission to release them. These documents are continuously
being improved, updated and overwritten.

The documents in relation to this point are therefore being withheld using
the Section 43 exemption of Commercial Interest.

 

Section 43 of the Freedom of Information Act

Information is exempt information if its disclosure under this Act would,
or would be likely to prejudice the commercial interests of any person
(including the public authority holding it). A commercial interest relates
to a person or organisation’s ability to successfully participate in a
commercial activity, i.e. the purchase and the sale of goods or services.

 

Section 43 (2):

 

The Council are of the view that the release of the information in scope
of your request would prejudice its own commercial interests and the
commercial interests of the other party involved. The reasons for this
have been captured below under the public interest test section.

 

Public Interest Test:

 

The Council have considered the public interest test in relation to
section 43 (2) in releasing the information in scope of your request. The
outcome of this is below.

 

·         Public interest in disclosure:

o   It would inform the public of the activities carried out on their
behalf and to scrutinise public monies spent

 

·         Public interest to maintain the exemption:

o   Public authorities are major purchasers of goods and services and
breaching an agreement with a provider would be detrimental to our ongoing
working relationship and send a poor message to any future organisations
considering doing business with us. We have sought Xantura’s opinion and
they do not wish for the material to be released

o   Companies compete by offering something different from their rivals.
That difference could be price/quality/specification. Information that
identifies how a company has developed that unique element, is
commercially sensitive. For example, where a company competes on price, it
may be that the final price charged is readily available, however
information disclosing how the company is able to offer the product at
that price may not be.

o   Disclosure of information would result in other companies that offer
similar products being able to use or copy the information provided. This
will put other organisations at a commercial advantage and Xantura at a
disadvantage.

 

Based on the above, it is the Council’s view that there is a stronger
public interest to engage the exemption for section 43 (2).

 

3.    The current data protection impact assessment for the System.

At the time the EHPS was introduced there was no legal requirement to
undertake a DPIA. With this in mind a DPIA was not undertaken.

 

4.    Any assessment of the System conducted for the purpose of complying
with the public sector equality duty under Equality Act s.149.

No assessment exists.

 

5.    Any reports, studies or other documentation describing possible
biases or unfairness in the System’s results.

Case studies were carried out with social workers using anonymised data at
the time, these were not kept. Also as mentioned in reply to Q1 a
dashboard is currently available to authorised staff to review.

 

6.    Any reports about the accuracy or validity of the System’s results.

The testing of the EHPS system was carried out over 5 years ago, details
are held by Xantura and are no longer available to us.

 

As your complaint has been dealt with as an Internal Review, should you
remain dissatisfied you can escalate your concerns to the Information
Commissioners Office and I have included their contact details below:

Address - Wycliffe House, Water Lane, Wilmslow. Cheshire, SK9 5AF.

T: 0303 123 1113 (Local rate) 01625 545745 (National rate).

E: [2][email address]

 

Kind regards

 

Rachael Steel l Information Services Manager I HR, OD & Transformation

[3]thurrock.gov.uk Thurrock Council, Civic Offices, New Road, Grays,
Essex RM17 6SL

 

An ambitious and collaborative community which is proud of its heritage
and excited by its diverse opportunities and future

 

 

[4]cid:image001.png@01CECE72.3F5FA730

 

 

 

From: Jack Maxwell <[5][FOI #705637 email]>
Sent: 14 January 2021 10:24
To: [6][email address]
Subject: RE: FOI 10437 - Internal Review of Freedom of Information request
- Early Help Profiling System

 

Dear Ms Barrell,

Thank you for providing those updates. I note that the Council is now
significantly overdue in its response to my request for internal review. I
look forward to receiving the Council's response as soon as possible.

Yours sincerely,

Jack Maxwell

show quoted sections