Dear Maya  Esslemont,

Thank you for submitting a request for information. Your reference number
is 21802877.

Your request will be reviewed and we may send you questions to clarify
your request. We will respond within 20 working days for Freedom of
Information and Environmental Information Regulations requests, and within
1 calendar month for Data Protection and Subject Access requests

[1]Please click this link to view current status of your request

Yours sincerely,
Information Governance Team
Adur & Worthing Councils

For Freedom of Information (FOI) and Environmental Information Regulations
(EIR):
Email: [Adur District Council request email]

For Data Protection (DP) and General Data Protection Regulations (GDPR):
Email: [email address]

Website: [2]www.adur-worthing.gov.uk/about-the-councils/legal/foi/

This message was sent from an email address not monitored. Please do not
respond to this message. To reply, please
email [Adur District Council request email] quoting your reference
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Dear Maya  Esslemont,

Thank you for your request for information (ref 21802877) sent to Adur &
Worthing Councils on 24th November 2023.

Your request has been considered and our response is below. Alternatively,
view your request and response
at: [1]https://adur-worthing-hr.onmats.com/w/we...

This request relates to the training offered to staff on modern slavery.
Please share the details of training on modern slavery delivered to staff,
including:

- The nature of training offered (e.g. e-learning or in-person, shared
with housing staff or adult safeguarding etc) and whether themes of
cultural intelligence, equality, diversity and inclusion are included as
part of this training

Modern day slavery is offered to staff across both councils. This is
primarily in the form of e-learning accessed via our online learning
system, for those staff that do not have access to the learning system we
deliver in person training.

- Where held, please share copies of training materials used to support
council staff in identifying modern slavery (such as PDFs, guidance, or
presentations)

E-learning - We are unable to provide you with a copy of the this training
because it cannot be easily extracted from the system.  However, we have
provided you with copies of the documents used to carry out in-house
training and these can be viewed from the secure link provided.

We hope this assists you.

Review procedure
If you are not satisfied with the response to your request for information
you have the right to an internal review. Details can be found on
[2]www.adur-worthing.gov.uk/foi

Your request for internal review should be submitted to us within three
(3) months of receipt by you of this response. Any such request received
after this time will only be considered at the discretion of the Council.

If having exhausted the review process you are not content that your
request or review has been dealt with correctly, you have a further right
to appeal to the Information commissioner’s Office (ICO), details of which
can be found here: [3]www.ico.org.uk/concerns

Yours sincerely
Information Governance Team
Adur & Worthing Councils

For Freedom of Information (FOI) and Environmental Information Regulations
(EIR):
Email: [Adur District Council request email]

For Data Protection (DP) and General Data Protection Regulations (GDPR):
Email: [email address]

Website: [4]www.adur-worthing.gov.uk/about-the-councils/legal/foi/ 

This message was sent from an email address not monitored. Please do not
respond to this message. To reply, please
email [Adur District Council request email] quoting your reference
number, 21802877, in your message.

References

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Dear Maya Esslemont

Your request for a review of our response to your request for information
(ref 21802877) has been assigned to our Litigation & Regulatory Team team.

Review your request
at: [1]https://adur-worthing-hr.onmats.com/w/we...

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This transfer expires on 2024-01-16

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[2][Adur District Council request email]
sent you FOI 21802877 Modern slavery e-learning
1 item, 41 MB in total ・ Expires on 16 January, 2024
FOI 21802877 Modern slavery e-learning Dear M Esslemont,

Please find attached the information you have requested.

Yours sincerely
Information Officer
Adur & Worthing Councils
Email: [Adur District Council request email]
Website: www.adur-worthing.gov.uk/FOI
[3]Get your files
 
Download link
[4]https://wetransfer.com/downloads/9b0872e...
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FOI 21802877 Modern slavery e-learning.pdf
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Dear Maya  Esslemont,

Please find out response to your request for a review (ref 21802877).
Alternatively, view your request and response
at: [1]https://adur-worthing-hr.onmats.com/w/we...

Dear Maya Esslemont,

Case reference: 21802877

I write further to your request for internal review received by the Adur &
Worthing Councils (‘Council’) on 15 December 2023.

I refer to your email received on 15 December 2023 regarding the reply
sent to you on 15 December 2023. This is regarding your request that you
made a request for data. Your request was received on 24 November 2023
which was logged and a reply sent to you on 15 December 2023. 
I have set this out in chronological order and hope this assists you.
 
Request 24 November 2023

This is a request under the Freedom of Information Act 2000. This request
relates to the training offered to staff on modern slavery. Please share
the details of training on modern slavery delivered to staff, including:
- The nature of training offered (e.g. e-learning or in-person, shared
with housing staff or adult safeguarding etc) and whether themes of
cultural intelligence, equality, diversity and inclusion are included as
part of this training
- Where held, please share copies of training materials used to support
council staff in identifying modern slavery (such as PDFs, guidance, or
presentations)

Reply 15 December 2023

This request relates to the training offered to staff on modern slavery.

Please share the details of training on modern slavery delivered to staff,
including:

- The nature of training offered (e.g. e-learning or in-person, shared
with housing staff or adult safeguarding etc) and whether themes of
cultural intelligence, equality, diversity and inclusion are included as
part of this training
Modern day slavery is offered to staff across both councils. This is
primarily in the form of e-learning accessed via our online learning
system, for those staff that do not have access to the learning system we
deliver in person training.

- Where held, please share copies of training materials used to support
council staff in identifying modern slavery (such as PDFs, guidance, or
presentations)
E-learning - We are unable to provide you with a copy of this training
because it cannot be easily extracted from the system.  However, we have
provided you with copies of the documents used to carry out in-house
training and these can be viewed from the secure link provided.

We hope this assists you.

Request for Internal Review 15 December 2023

Please pass this on to the person who conducts Freedom of Information
reviews. I am writing to request an internal review of Adur District
Council's handling of my FOI request 'Modern slavery training provision'.

- As initially requested, did the outlined training include any of the
following themes: cultural intelligence, equality, diversity and
inclusion? This includes confirmation on the contents of the modern
slavery elearning provided

- Is there a reason why supporting materials from the Modern Slavery and
Human Trafficking eLearning  was not provided, beyond it not being easily
extractable? The contents of the elearning are disclosable under the FOI
Act 2000, so information can only be witheld under an exemption recognised
under the Act. If it is useful, other local authorities have provided the
contents of elearning by screenshotting and saving as image files,
exporting via powerpoint, or copy-pasting the text from elearning into a
Word document.

All of these formats are acceptable for the purposes of this request. I am
sorry to hear that extraction is not intuitive - however, this is not an
accepted exemption under the FOI Act. I would appreciate if this content
could be shared as a way of resolving this request at internal review
stage.
Yours faithfully,
M Esslemont

Internal Review

Thank you for your request for an internal review.

The review has been carried out by myself, I am Senior Information
Governance Officer and Data Protection Officer, I report to the Assistant
Director of Legal and Democratic Services on behalf of the Councils. I
have not been involved with this request and therefore my view is
impartial and I have investigated this objectively.

This matter has escalated to an Internal Review since your dissatisfaction
is noted and you are entitled to exercise your right to request an
internal review. You are entitled to tell us if you believe that something
has been missed. 

I confirm that I have spoken to Officers in Learning and Development to
gain an understanding of the position and what data is held for the
purposes of your request which was considered under the Freedom of
Information Act 2000.

I have reviewed your complaint and viewed this objectively and I do not
feel that the reply provided to you dated 15 December 2023 answered your
request under the provisions of S.1 (1) (a) and (b) of the Freedom of
Information Act 2000, which reads as follows:-

General right of access to information held by public authorities.
(1)Any person making a request for information to a public authority is
entitled—
(a)to be informed in writing by the public authority whether it holds
information of the description specified in the request, and
(b)if that is the case, to have that information communicated to him.

Conclusion

Given my investigation as detailed above, I am upholding your internal
review.

I have asked that screenshots of the e-learning modern slavery be sent to
you and I note that this has been carried out by one of my colleagues.
This was sent securely by WeTransfer today 9 January 2024 at 11.07 am.

This is available for 7 days so please let me know if you have not
received this.

I trust this data assists you and satisfies your request, I am sorry that
the screenshots of the e-learning where not provided to you originally
within the reply sent to you on 15 December 2023.

Please note that this internal review is only concerned with how your
request for information was dealt with by the Council in compliance with
the FOIA. There may appear to be concerns with the Council’s internal
decision-making processes and procedures. However, these could not be
addressed as part of this review. Should you wish to submit a service
complaint, please visit: [2]https://www.adur-worthing.gov.uk/complai....

If having exhausted the review process you are still not content that your
request or review has been dealt with correctly, you have a further right
to appeal to the Information commissioner’s Office (ICO), details of which
can be found on their website here: [3]https://ico.org.uk/concerns/ or by
calling 0303 123 1113.

Yours sincerely,

Michaela Wood

Data Protection Officer | Adur & Worthing Councils 
Email: [email address] |
Website: www.adur-worthing.gov.uk/data-protection 

Senior Information Governance Officer | Adur & Worthing Councils 
Email: [Adur District Council request email] | Website:
[4]https://www.adur-worthing.gov.uk/foi/

Our Privacy Notices can be viewed [5]here.

This message was sent from an email address not monitored. Please do not
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