JFS School
The Mall Kenton Harrow Middlesex HA3 9TE
Reviewed in the Summer Term 2017
Next due for review in the Spring Term 2019, subject to intervening legislative changes
FREEDOM OF INFORMATION POLICY
1 INTRODUCTION
1.1 The School is subject to the Freedom of Information Act 2000 (FOI) as a public authority, and as
such, must comply with any requests for information in accordance with the principles laid out in
the Act.
2 WHAT IS A REQUEST UNDER FOI
2.1 Any request for any information from the School is technically a request under the FOI, whether
or not the individual making the request mentions the FOI. However, the ICO has stated that
routine requests for information (such as a parent requesting a copy of a policy) can be dealt with
outside of the provisions of the Act.
2.2 All FOI requests should be referred in the first instance to the Headteacher, who may allocate
another individual to deal with the request. This must be done promptly, and in any event within 3
working days of receiving the request.
2.3 When considering a request under FOI, you must bear in mind that release under FOI is treated as
release to the general public, and so once it has been released to an individual, anyone can then
access it, and you cannot restrict access when releasing by marking the information “confidential”
or “restricted”.
3 TIME LIMIT FOR COMPLIANCE
3.1 The School must respond as soon as possible, and in any event, within 20 working days of the date
of receipt of the request. For a School, a “working day” is one in which pupils are in attendance,
subject to an absolute maximum of 60 calendar days to respond.
4 PROCEDURE FOR DEALING WITH A REQUEST
4.1 When a request is received that cannot be dealt with by simply providing the information, it
should be referred in the first instance to the Headteacher who may re-allocate to an individual
with responsibility for the type of information requested.
4.2 The first stage in responding is to determine whether or not the School “holds” the information
requested. The School will hold the information if it exists in computer or paper format. Some
requests will require the School to take information from different sources and manipulate it in
some way. Where this would take minimal effort, the School is considered to “hold” that
information, but if the required manipulation would take a significant amount of time, the
requestor should be contacted to explain that the information is not held in the manner requested,
and offered the opportunity to refine their request. For example, if a request required the School to
add up totals in a spread sheet and release the total figures, this would be information “held” by
the School. If the School would have to go through a number of spread sheets and identify
individual figures and provide a total, this is likely not to be information “held” by the School,
depending on the time involved in extracting the information.
4.3 The second stage is to decide whether the information can be released, or whether one of the
exemptions set out in the Act applies to the information. Common exemptions that might apply
include:
4.3.1
Section 40 (1) – the request is for the applicants personal data. This must be dealt with in
accordance with the Data Protection Policy.
4.3.2
Section 40 (2) – compliance with the request would involve releasing third party personal
data, This must be dealt with in accordance with the Data Protection Policy.
4.3.3
Section 41 – information that has been sent to the School (but not the School’s own
information) which is confidential;
4.3.4
Section 21 – information that is already publicly available, even if payment of a fee is
required to access that information;
4.3.5
Section 22 – information that the School intends to publish at a future date;
4.3.6
Section 43 – information that would prejudice the commercial interests of the School
and/or a third party;
4.3.7
Section 38 – information that could prejudice the physical health, mental health or safety
of an individual (this may apply particularly to safeguarding information);
4.3.8
Section 31 – information which may prejudice the effective detection and prevention of
crime – such as the location of CCTV cameras;
4.3.9
Section 36 – information which, in the opinion of the chair of governors of the School,
would prejudice the effective conduct of the School.
4.4 The sections mentioned in italics are qualified exemptions. This means that even if the exemption
applies to the information, you also have to carry out a public interest weighting exercise,
balancing the public interest in the information being released, as against the public interest in
withholding the information.
4.5 We are committed to making as much information as possible available but some necessary
exemptions from disclosure are allowed under Freedom of Information law. These include
information you can get easily by other means, court records, most of the more sensitive personal
information, information that has been provided to us in confidence and where there are legal
prohibitions on disclosure. There are other exemptions including where vexatious or repeated
requests are received, where the information is intended for future publication, where it relates to
legal proceedings or law enforcement, where someone’s health or safety could be harmed, where
information is subject to legal privilege, where commercial interests or the conduct of public
affairs might be prejudiced and for communications with royalty. We may withhold this
information if there is a clear public interest in doing so. In some cases, we may not be able to
release the information until a specific date.
5 RESPONDING TO A REQUEST
5.1 When responding to a request where the School has withheld some or all of the information, the
School must explain why the information has been withheld, quoting the appropriate section
number and explaining how the information requested fits within that exemption. If the public
interest test has been applied, this also needs to be explained.
5.2 The letter should end by explaining to the requestor how they can complain – either by reference
to an internal review or by writing to the ICO.
6 COMMUNICATION
6.1 Any FOI requests should be addressed to the Headteacher.
6.2 To access general information about the school please use our website which is regularly updated.
Hard copies of information held on it are available from the school.
6.3 Any comments or complaints about our approach to Freedom of Information should be made
intitially to the School.
6.4 If you are not satisfied with the assistance that you get or if we have not been able to resolve your
complaint and you feel that a formal complaint needs to be made then this should be addressed to
the Information Commissioner’s Office. This is the organisation that ensures compliance with the
Freedom of Information Act 2000 and that deals with formal complaints. They can be contacted
at:
Information Commissioner,Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
Enquiry/Information Line: 01625 545 700
E Mail: xxxxxxxxxxxx@xxxxxx.xxxxx.xx.xx
Website : www.informationcommissioner.gov.uk
7 FEES
7.1 All information on our website can be viewed and used free of charge, subject to any stated
copyright conditions that may apply.
7.2 Where there are significant direct costs involved in providing the information requested, such as
photocopies, photographs, recordings and postage costs, these costs will be passed on. The current
schedule of charges is provided below.
Category
Charges (inclusive of VAT & subject to £25 Waiver for individuals, £10 for
businesses)
Postal Charge – normally first class
Actual cost
Printing or copying Charges
A4 copy (or smaller) Monochrome
15p per sheet of paper
A4 copy (or smaller) Colour
25p per sheet of paper
A3 copy Monochrome
30p per sheet of paper
A3 copy Colour
50p per sheet of paper
Costs for electronic data transfer
Transfer of data CD
£25 per hour ; £1 each
APPENDICES
Appendix 1 – Model Publication Scheme (ICO)
https://ico.org.uk/media/for-organisations/documents/1153/model-publication-scheme.pdf
Appendix 2 - Definition document for the governing bodies of maintained and other state-funded schools
in England (ICO)
https://ico.org.uk/media/for-organisations/documents/1235/definition-document-schools-in-england.pdf

Model publication scheme
Model publication scheme
Freedom of Information Act
This model publication scheme has been prepared and approved by the
Information Commissioner. It may be adopted without modification by any
public authority without further approval and will be valid until further notice.
This publication scheme commits an authority to make information available to
the public as part of its normal business activities. The information covered is
included in the classes of information mentioned below, where this information
is held by the authority. Additional assistance is provided to the definition of
these classes in sector specific guidance manuals issued by the Information
Commissioner.
The scheme commits an authority:
To proactively publish or otherwise make available as a matter of
routine, information, including environmental information, which is held
by
the authority and falls within the classifications below.
To specify the information which is held by the authority and falls within
the classifications below.
To proactively publish or otherwise make available as a matter of
routine, information in line with the statements contained within this
scheme.
To produce and publish the methods by which the specific information is
made routinely available so that it can be easily identified and accessed by
members of the public.
To review and update on a regular basis the information the authority
makes available under this scheme.
To produce a schedule of any fees charged for access to information
which is made proactively available.
To make this publication scheme available to the public.
To publish any dataset held by the authority that has been requested,
and any updated versions it holds, unless the authority is satisfied that
it is not appropriate to do so; to publish the dataset, where reasonably
practicable, in an electronic form that is capable of re-use; and, if any
information in the dataset is a relevant copyright work and the public
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Model publication scheme
authority is the only owner, to make the information available for re-use
under the terms of the Re-use of Public Sector Information Regulations
2015, if they apply, and otherwise under the terms of the Freedom of
Information Act section 19.
The term ‘dataset’ is defined in section 11(5) of the Freedom of
Information Act. The term ‘relevant copyright work’ is defined in section
19(8) of that Act.
Classes of information
Who we are and what we do.
Organisational information, locations and contacts, constitutional and
legal governance.
What we spend and how we spend it.
Financial information relating to projected and actual income and
expenditure, tendering, procurement and contracts.
What our priorities are and how we are doing.
Strategy and performance information, plans, assessments, inspections
and reviews.
How we make decisions.
Policy proposals and decisions. Decision making processes, internal
criteria and procedures, consultations.
Our policies and procedures.
Current written protocols for delivering our functions and responsibilities.
Lists and registers.
Information held in registers required by law and other lists and registers
relating to the functions of the authority.
The services we offer.
Advice and guidance, booklets and leaflets, transactions and media
releases. A description of the services offered.
The classes of information will not generally include:
Information the disclosure of which is prevented by law, or exempt
under the Freedom of Information Act, or is otherwise properly
considered to be protected from disclosure.
Information in draft form.
Information that is no longer readily available as it is contained in files
that have been placed in archive storage, or is difficult to access for
similar reasons.
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The method by which information published under this
scheme will be made available
The authority will indicate clearly to the public what information is covered by
this scheme and how it can be obtained.
Where it is within the capability of a public authority, information will be
provided on a website. Where it is impracticable to make information available
on a website or when an individual does not wish to access the information by
the website, a public authority will indicate how information can be obtained by
other means and provide it by those means.
In exceptional circumstances some information may be available only by
viewing in person. Where this manner is specified, contact details will be
provided. An appointment to view the information will be arranged within a
reasonable timescale.
Information will be provided in the language in which it is held or in such other
language that is legally required. Where an authority is legally required to
translate any information, it will do so.
Obligations under disability and discrimination legislation and any other
legislation to provide information in other forms and formats will be adhered to
when providing information in accordance with this scheme.
Charges which may be made for information published
under this scheme
The purpose of this scheme is to make the maximum amount of information
readily available at minimum inconvenience and cost to the public. Charges
made by the authority for routinely published material will be justified and
transparent and kept to a minimum.
Material which is published and accessed on a website will be provided free of
charge.
Charges may be made for information subject to a charging regime specified
by Parliament.
Charges may be made for actual disbursements incurred such as:
photocopying
postage and packaging
the costs directly incurred as a result of viewing information
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Charges may also be made for information provided under this scheme where
they are legally authorised, they are in all the circumstances, including the
general principles of the right of access to information held by public
authorities, justified and are in accordance with a published schedule or
schedules of fees which is readily available to the public.
Charges may also be made for making datasets (or parts of datasets) that are
relevant copyright works available for re-use. These charges will be in
accordance with the terms of the Re-use of Public Sector Information
Regulations 2015, where they apply, or with regulations made under section
11B of the Freedom of Information Act, or with other statutory powers of the
public authority.
If a charge is to be made, confirmation of the payment due will be given before
the information is provided. Payment may be requested prior to provision of
the information.
Written requests
Information held by a public authority that is not published under this scheme
can be requested in writing, when its provision will be considered in
accordance with the provisions of the Freedom of Information Act.
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Schools – England
Freedom of Information Act 2000
Definition document for the governing bodies of
maintained and other state-funded schools in
England
For the avoidance of doubt, this document covers all schools in
England that are subject to the Freedom of Information Act 2000
(FOIA), including academies and free schools. Sixth form colleges
may opt to use either this definition document or the one for colleges
of further education, as appropriate to their constitution, and must
make clear which document they are using.
This guidance will be of most use to schools developing their own
guide to information. Smaller schools may alternatively use the
template Guide to Information for the schools sector.
The guidance is intended to assist schools by giving examples of the
kinds of information that we would expect them to provide in order to
meet their commitments under the FOIA model publication scheme.
Schools should note that they are not expected to routinely publish all
information; for example, where they do not hold it or where it is
publicly available elsewhere or is exempt. We list such circumstances
below.
We would expect schools to make the information in this definition
document available unless:
they do not hold the information;
the information is exempt under one of the FOIA exemptions or
Environmental Information Regulations 2004 (EIR) exceptions,
or its release is prohibited under another statute;
the information is readily and publicly available from an
external website; such information may have been provided
either by the school or on its behalf. The school must provide a
direct link to that information;
the information is archived, out of date or otherwise
inaccessible; or
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it would be impractical or resource-intensive to prepare the
material for routine release.
If the information is only held by another public authority, the school
should provide details of where to obtain it.
The guidance is not meant to give an exhaustive or definitive list of
everything that should be covered by a publication scheme. The legal
commitment is to the model publication scheme, and schools should
look to provide as much information as possible on a routine basis.
As a minimum we expect schools to make available information that
is required by statute or by the Department for Education or by virtue
of a funding agreement, for example. For the avoidance of doubt, we
would not expect schools that are subject to a funding agreement to
provide information contrary to its provisions, although we consider
such a conflict to be unlikely to arise.
Publishing datasets for re-use
Public authorities must publish under their publication scheme any
dataset they hold that has been requested, together with any
updated versions, unless they are satisfied that it is not appropriate
to do so. So far as reasonably practicable, they must publish it in an
electronic form that is capable of re-use.
If the dataset or any part of it is a relevant copyright work and the
public authority is the only owner, the public authority must make it
available for re-use under the terms of a specified licence. Datasets in
which the Crown owns the copyright or the database rights are not
relevant copyright works.
The Datasets Code of Practice recommends that public authorities
make datasets available for re-use under the
Open Government
Licence.
The term ‘dataset’ is defined in section 11(5) of FOIA. The terms
‘relevant copyright work’ and ‘specified licence’ are defined in section
19(8) of FOIA. The ICO has published
guidance on the dataset
provisions in FOIA. This explains what is meant by “not appropriate”
and “capable of re-use”.
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Who we are and what we do
Organisational information, structures, locations and contacts.
We would expect information in this class to be current information
only.
Instrument of Government / Articles of Association
The
Instrument of Government is the document which records the
name and category of the school and the name and constitution of
its governing body. Academies and Free Schools have Articles of
Association instead.
School prospectus and curriculum
The contents of the school prospectus (if any).
Once a prospectus has been published and made available to
parents, access to it should be available to anyone.
An outline of the school curriculum.
Governing Body
The names of the governors should be available, and the basis on
which they have been appointed, along with details of how to
contact them via the school.
School session times and term dates
Details of school session times and dates of school terms and
holidays.
Location and contact information
The address, telephone number, email address and website for the
school together with the names of key personnel.
What we spend and how we spend it
Financial information about projected and actual income and
expenditure, procurement, contracts and financial audit.
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The minimum we would expect is that financial information for the
current and previous two financial years should be available.
Annual budget plan and financial statements
Details of the sources of funding and income provided to the school
by a local authority or directly by central government or from
elsewhere, including the private sector, together with the annual
budget plan and the school’s annual income and expenditure
returns.
Details of items of expenditure over £5000, including costs, supplier
and transaction information. This should be published at least
annually but at a more frequent quarterly or six-monthly interval
where it is practical for schools to do so.
Capital funding
Information on major plans for capital expenditure .Details of the
capital funding allocated to or by the school together with
information on related building projects and other capital projects.
This should include any private finance initiative and public-private
partnership contracts.
Financial audit reports
Procurement and contracts
Details of procedures used for the acquisition of goods and services.
Details of contracts that have gone through a formal tendering
process.
Pay policy
The statement of the school’s policy and procedures regarding
teachers’ pay.
Staff allowances and expenses
Details of the allowances and expenses that can be incurred or
claimed. It should include the total of the allowances and expenses
paid to individual senior staff members by reference to categories.
This information should be produced in line with the school’s policies,
practices and procedures and must at least include travel,
subsistence and accommodation. For the purpose of this document,
“senior staff” means staff on the Senior Management or Leadership
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Team or equivalent level, or above, whose basic actual salary is at
least £60,000 per annum.
Staff pay and grading structures
The names and positions of all staff of the school, and how they may
be contacted via the school. This may be provided as part of the
organisational structure and should include, as a minimum, the
salaries for senior staff as defined above. Those salaries should be
stated in bands of £10,000. For more junior posts, levels of pay
should be identified by salary range.
Governors’ allowances
Details of allowances and expenses that can be incurred or claimed,
and a record of total payments made to individual governors.
What our priorities are and how we are doing
Strategies and plans, performance indicators, audits, inspections and
reviews.
The minimum we would expect in this class is current information.
Below is a list of the type of information that we would expect
schools to have readily available for publication. Any other reports or
recorded information showing the school’s planned or actual
performance should normally be included. If the information is
readily and publicly available via an external website, the school may
instead provide a direct link to that, as stated on page one of this
document.
Performance data supplied to the government
Latest Ofsted report
The school should provide a link to its report on the Ofsted website.
Performance management information
Performance management policy and procedures adopted by the
governing body.
The school’s future plans
Any major proposals for the future of the school involving, for
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example, consultation on a change in school status.
Safeguarding and child protection
The policies and procedures that are in place to ensure that that the
school exercises its functions with a view to safeguarding and
promoting the welfare of children, including child protection, in
compliance with legislation and any guidance issued by the Secretary
of State.
How we make decisions
Decision-making processes and records of decisions.
We would expect information in this class to be available at least for
the current and previous three years.
Admissions policy / decisions
The school’s admission arrangements and procedures, together with
information about the right of appeal. We would not expect
individual admission decisions to be published, but we would expect
information on application numbers/patterns of successful applicants
(including criteria on which applications were successful) to be
published if this information is held by the school. If the school is not
its own admissions authority, it should provide an appropriate link to
the local authority.
Minutes of meetings of the governing body and its
committees
Minutes, agendas and papers considered at such meetings should be
published as soon as practicable, with the exception of information
that is properly considered to be private to the meeting.
Our policies and procedures
Current written protocols, policies and procedures for delivering our
services and responsibilities.
We would expect information in this class to be current only.
School policies and other documents
This must include, as a minimum, policies, procedures and
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documents that the school is required to have by statute or by its
funding agreement or equivalent. We would expect this information
to include the required policies listed on the Department for
Education’s website. It will also include policies and procedures for
handling information requests.
Records management and personal data policies
This will include information security policies, records retention,
destruction and archive policies, and data protection (including data
sharing) policies.
Equality and diversity
This will also include policies, schemes, statements, procedures and
guidelines relating to equal opportunities.
Policies and procedures for the recruitment of staff
If vacancies are advertised as part of recruitment policies, details of
current vacancies will be readily available.
Charging regimes and policies
Details of any statutory charging regimes should be provided.
Charging policies should include charges made for information
routinely published. They should clearly state what costs are to be
recovered, the basis on which they are made, and how they are
calculated.
If the school charges a fee for licensing the re-use of datasets, it
should state in its guide to information how this is calculated and
whether the charge is made under the Re-use Fees Regulations or
under other legislation. It cannot charge a re-use fee if it makes the
datasets available for re-use under the Open Government Licence.
Lists and registers
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We expect this to be information in currently maintained lists and
registers only.
Curriculum circulars and statutory instruments
Statutory Instruments (for example Regulations), departmental
circulars and administrative memoranda sent to the Head
Teacher/Governing Body concerning the curriculum.
Disclosure logs
If a school produces a disclosure log indicating the information
provided in response to requests, it should be readily available.
Disclosure logs are recommended as good practice.
Asset register
We would expect some information from capital asset registers to be
available, if such registers are held.
Any information the school is currently legally required
to hold in publicly available registers
The services we offer
Information about the services the school provides including leaflets,
guidance and newsletters.
Generally this is an extension of part of the first class of information
and may also relate to information covered in other classes.
Examples of services that could be included here are:
Extra-curricular activities
Out of school clubs
School publications
Services for which the school is entitled to recover a fee,
together with those fees
Leaflets, booklets and newsletters
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