Dear Cabinet Office,

Please can you provide a copy of the guidance described on this page https://www.gov.uk/guidance/how-to-publi... provided by the the Cabinet Office Propriety and Ethics team to department on preparing Ministerial transparency publications on ministerial gifts, hospitality, travel and meetings.

I anticipate that this would include:

* Copies of guidance documents or notes on how to prepare data;
* Any CSV (comma-separated values) templates;
* Any guidance documents relating to timing and appropriate approval processes;

With thanks in advance for your help,

Yours faithfully,

Tim Davies

Dear Cabinet Office,

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

I am writing to request an internal review of Cabinet Office's handling of my FOI request 'Guidance for departments on how to publish ministerial gifts, hospitality, travel and meetings'.

The refusal invokes 35(1)(a) and suggests that there is a "public interest in not providing information that may be soon out of date and therefore potentially misleading and inaccurate."

However, without access to the guidance on how data is prepared - that data itself risks being misleading. Access to this guidance is essential to an understanding of the published ministerial gifts, hospitality, travel and meeting registers.

The concern that this information may go out of date could be easily addressed by proactively publishing it on the web page at https://www.gov.uk/guidance/how-to-publi... alongside the other guidance that is given here for departments.

Futhermore, concerns that the information may become out of date or may be misleading are not relevant public interest factors. The ICO says 'information may not be withheld on the basis that it could be misunderstood, or is considered too technical or complex’ (see https://ico.org.uk/media/for-organisatio... at para 40)

Note also that the Information Commissioner's guidance on Section 35 (https://ico.org.uk/media/for-organisatio...) offers a number of potential tests for whether a 'policy development' exemption applies or not, including whether or not the decisions are taken by a minister, or are administrative (which would count as implementation rather than policy formation).
I would suggest that the requested:

* Copies of guidance documents or notes on how to prepare data;
* Any CSV (comma-separated values) templates;
* Any guidance documents relating to timing and appropriate approval processes;

relate solely to implementation of existing policy - and so are not covered by 35(1)(a).

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

Yours faithfully,

Tim Davies

Dear FOI Team Mailbox,

Re: CABINET OFFICE REFERENCE: FOI325618

Please can you advise when an Internal Review of this request will be actioned. It is now over 20 working days since acknowledgement of my request and I have received no further information or updates.

Yours sincerely,

Tim Davies

Dear Cabinet Office,

Re: CABINET OFFICE REFERENCE: FOI325618

I made a request for an internal review of my earlier refused request for 'Guidance for departments on how to publish ministerial gifts, hospitality, travel and meetings' on the 22nd January.

I have not heard any updates since. Please advise on when I can expect to hear the outcome of this internal review.

In the absence of a reply in the next 5 working days, I will be writing to the Information Commissioner to request their intervention in this matter.

Yours faithfully,

Tim Davies

Dear FOI Team,

Thank you for sharing this information. I am glad this issue has been resolved.

To address the concern that this information may become outdated over time, I would encourage you to consider adding it to your Publication Scheme, and proactively publishing this guidance whenever it changes. It assists citizens in interpreting the published data, and clearly falls within the category of 'policies and procedures' covered by the ICO's Model Publication Scheme: https://ico.org.uk/media/for-organisatio...

Yours sincerely,

Tim Davies