Dear Kent Community Health NHS Foundation Trust,

I am a father of five children aged 5-16yrs and have become aware of a questionnaire put to children at school entry, year 6 and year 9 called The Lancaster Model. The website (thelancastermodel.co.uk) says that the questions typically take 20 minutes to complete, but fails to give anything but the most rudimentary details about the nature of the questions themselves. This lack of transparency is concerning. If parents are to give informed consent for their children to complete this questionnaire, they should know its contents - especially if they themselves are not sent copies of their children's responses.

I am therefore making this FOI request to find out (in full) what my children aged 5-16 will be asked in this questionnaire(s).

Yours faithfully,
Dr Daniel Harper BMBCh (Oxon).

Dear Kent Community Health NHS Foundation Trust,

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

I am writing to request an internal review of Kent Community Health NHS Foundation Trust's handling of my FOI request 'Full Contents of The Lancaster Model Health Questionnaire'.

You replied to my Freedom of Information request saying the following: 'We can confirm that the Trust does hold the information you have requested however, we are unable to provide a list of the questions contained in the Lancaster Model Health Questionnaire as this is commercially sensitive information and is therefore exempt from disclosure under Section 43(2) of the Freedom of Information Act.'

You have provided evidence of harm in disclosure and conducted a public interest test. I am not at all convinced by the validity of these tests and the reasons given for your conclusions and am therefore requesting that they are internally reviewed. However commercially sensitive any party may feel the questionnaire is, these questions are being put to children across Kent. It is my understanding that the aim is to have all children in years 6, 10 and 12 complete the questionnaire. Four of my children attend Brabourne Primary School and one attends Highworth Grammar School. The headmaster of the former has very appropriately sought consent from parents. Consent is meaningless unless it is informed. The Trust has chosen not to inform me concerning the content of these questionnaires. Without informed consent, this questionnaire should not be rolled out.

I should like to remind the trust that there are four principles of clinical ethics, namely: beneficence, nonmaleficence, autonomy and justice.

These ethical principles are especially sensitive in that they relate to children. In this case this Lancaster Model intervention is being targetted at potentially vulnerable children. The trust should bear in mind that in normal circumstances responsibility for children rests with the parents and not with the state. Parental responsibility cannot be exercised if the parent is deliberately kept in the dark about what information (about not just themselves but also about their families) their children will be submitting to a public body. It breaches the ethical principle of autonomy and informed consent. I believe the ethical principle of justice is also breached in that NHS services are funded from public finances and therefore the interests of the public should be placed above the commercial interests of any third parties. This is not an examination, but a questionnaire. Since the questions will be seen by tens of thousands of children across Kent, I would think it safe to assume that 'competitors' would not have a difficult time discovering its contents. With respect to the ethical principles of beneficence and nonmaleficence, these are precisely why I have made my Freedom of Information request. I wish to ascertain whether the questionnaire is truly beneficent and whether it is in my children's best interests to complete it. I cannot do this if I do not know what the specific questions will be. A few sample questions do not suffice.

I would also like the Trust to note that in Dec 2019 the North West Boroughs Healthcare NHS Foundation Trust released the list of questions asked to Year 6 pupils (https://www.whatdotheyknow.com/request/t...). This was with the author's consent. Your refusal is therefore contrary to precedent.

This is clearly a massive data collation exercise. Whilst Kent Community Health NHS Trust has a better than average track record at preventing data breaches, they have still occasionally occurred. The data being collected in this questionnaire is I believe potentially far more sensitive than that of the recent Census. Parents have a right to know what information about their families is being collated, passed between health authorities and potentially liable to data breaches.

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

Yours faithfully,

Daniel Harper