Hertfordshire County Council Pension Fund Investments

The request was successful.

Dear Hertfordshire County Council,

I would like to request the following information:

1) The full details of what the Hertfordshire County Council Pension Fund currently invests in, including the name and amounts of each asset class or investment being held.

2) The investments broken down into different categories/types of holding, including: Index Linked Securities, Unit trust Property, Cash Instruments, Unit Trust Equities, Infrastructure, Fixed Interest Securities, Equities Segregated Unlisted, Equities Segregated UK, Equities Segregated Foreign as well as any other investments that the Pension Fund holds.

3) The industrial sector of each investment e.g. Aerospace & Defense, Oil & Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks, Mining, Government, Automobiles, Financial Services, Housing and any other sectors that the Pension Fund holds investments in. Examples of Pension Funds which have previously included this data in their publicly released investments include Buckinghamshire and Derbyshire. (i)

4) A full list of all the companies which the Pension Fund currently invests in (this should be covered in the above requests). This list should include the names of each company and the amount invested in each company.

5) Can you clearly specify the total value of all investments that the Pension Fund holds in sterling.

6) I would like to receive this information in an unlocked excel sheet without protected cells (.xls). If you have to password protect the excel sheet, can you also provide the password to the excel sheet. When considering the request for this data in excel format, please refer to Innes v Information Commissioner [2014] EWCA Civ 1086 (ii), which allows a requestor to express a preference for communication by a particular means, specifically: "an applicant's right to choose to have information provided to him in electronic form extends to a right to choose the software format in which it is embodied." (iii)

I would like to receive the information in electronic format. If one part of the request can be answered sooner than others, please send that information first followed by any subsequent data. If you need further clarification, please contact me by email.

Many public authorities release their contracts, minutes and other information of interactions with private vendors in line with the Freedom of Information Act. The exemption for commercial interest under the Act (section 43) is a qualified exemption, which means information can only be withheld if it is in the public's interest. The public have an interest in knowing what the Pension Fund is investing in, the terms of contracts and the minutes of meeting with public authorities, whether or not public money changes hands immediately.

If you are relying on section 41 (the exemption for legal breach of confidence) then I would like to know the following:

* When these confidentiality agreements were agreed
* All correspondence and email in which these confidentiality agreements were discussed
* The precise wording of the confidentiality agreements.

I ask these questions because guidance issued by both the Lord Chancellor (draft guidance on FOI implementation) and the Office of Government Commerce (Model terms and conditions for goods and services) specifically state that public authorities should not enter into these types of agreements; they go directly against the spirit of the laws of disclosure. I would also point to the Information Commissioner's guidance on accepting blanket commercial confidentiality agreements: 'Unless confidentiality clauses are necessary or reasonable, there is a real risk that, in the event of a complaint, the Commissioner would order disclosure in any case.' (iv)

Finally, within the law of confidence there is also a public interest test. Therefore, the information should be disclosed in full. If any parts are redacted they must be for information that can be proven to be a legal breach of confidence in court, and only then where secrecy can be shown to be in the public interest. These are difficult positions to argue when public money is at stake or where a public authority is offering a private company a monopoly to charge its stakeholders.

I reserve the right to appeal your decision to withhold any information or to charge excessive fees, and understand that under the act, I am entitled to a response within 20 working days. I would be grateful if you could confirm in writing that you have received this request.

Yours faithfully,

Edward Jones

(i) Buckinghamshire https://www.whatdotheyknow.com/request/2... Derbyshire https://www.whatdotheyknow.com/request/2...

(ii) Innes v Information Commissioner [2014] EWCA Civ 1086 http://www.bailii.org/ew/cases/EWCA/Civ/...

(iii) Section 11 FOIA and the Form of a Request https://panopticonblog.com/2014/08/01/se...

(iv) 'Freedom of Information Awareness Guidance 5: Commercial Interests' Office of the Information Commissioner, Page 10, https://www.humanrightsinitiative.org/pr...

Information Governance, Hertfordshire County Council

4 Attachments

Dear Edward Jones

 

Reference number: FOI/RAP/06/20/19333

 

Thank you for your correspondence of the 24^th June 2020 requesting the
following information:

 

1) The full details of what the Hertfordshire County Council Pension Fund
currently invests in, including the name and amounts of each asset class
or investment being held.

 

2) The investments broken down into different categories/types of holding,
including: Index Linked Securities, Unit trust Property, Cash Instruments,
Unit Trust Equities, Infrastructure, Fixed Interest Securities, Equities
Segregated Unlisted, Equities Segregated UK, Equities Segregated Foreign
as well as any other investments that the Pension Fund holds.

 

3) The industrial sector of each investment e.g. Aerospace & Defense, Oil
& Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks, Mining,
Government, Automobiles, Financial Services, Housing and any other sectors
that the Pension Fund holds investments in. Examples of Pension Funds
which have previously included this data in their publicly released
investments include Buckinghamshire and Derbyshire. (i)

 

4) A full list of all the companies which the Pension Fund currently
invests in (this should be covered in the above requests). This list
should include the names of each company and the amount invested in each
company.

 

5) Can you clearly specify the total value of all investments that the
Pension Fund holds in sterling.

 

 

Your request for information is being considered under the Freedom of
Information Act 2000. We will respond to your request as quickly as
possible, and by close of 22^nd July 2020 at the latest.

 

If you have any questions, please do not hesitate to contact me, quoting
the reference number above.

                              

Yours sincerely,

 

Information Access Team

Legal Services| Resources
Hertfordshire County Council  
Room 223  Postal Point: CHN 320
[1][IMG]
T: 01992 555848 (Internal:25848)

E: [2][Hertfordshire County Council request email]

[3]Hertfordshire County Council Facebook[4]Hertfordshire County
Council Twitter[5]Hertfordshire County Council email updates

 

References

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Information Governance, Hertfordshire County Council

5 Attachments

Dear Edward Jones

 

Reference number: FOI/RAP/06/20/19333

 

On 24^th June 2020 Hertfordshire County Council received the following
request for information from you:

 

1) The full details of what the Hertfordshire County Council Pension Fund
currently invests in, including the name and amounts of each asset class
or investment being held.

 

2) The investments broken down into different categories/types of holding,
including: Index Linked Securities, Unit trust Property, Cash Instruments,
Unit Trust Equities, Infrastructure, Fixed Interest Securities, Equities
Segregated Unlisted, Equities Segregated UK, Equities Segregated Foreign
as well as any other investments that the Pension Fund holds.

 

3) The industrial sector of each investment e.g. Aerospace & Defense, Oil
& Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks, Mining,
Government, Automobiles, Financial Services, Housing and any other sectors
that the Pension Fund holds investments in. Examples of Pension Funds
which have previously included this data in their publicly released
investments include Buckinghamshire and Derbyshire. (i)

 

4) A full list of all the companies which the Pension Fund currently
invests in (this should be covered in the above requests). This list
should include the names of each company and the amount invested in each
company.

 

5) Can you clearly specify the total value of all investments that the
Pension Fund holds in sterling.

 

 

Your request for information has been considered under the Freedom of
Information Act 2000. I can confirm that Hertfordshire County Council does
hold the information you have requested. Our response is as follows.

 

Please see the attached spreadsheet. Please note that this spreadsheet
provides data for the financial year 18/19. Information for the latest
year (19/20) is currently being audited and is subject to change, this
data will be available in the coming weeks if you would like to re-submit
your request.

 

If you have any questions, please do not hesitate to contact me, quoting
the reference number on this correspondence. To find out more about
Freedom of Information, please visit
[1]http://www.hertfordshire.gov.uk/your-cou...

 

If you are unhappy with the way the County Council has handled your
request for information you may request an internal review of the request.
This will be carried out by a member of the County Council Legal Services
Team, who has had no prior involvement with the request. Requests for an
internal review should be sent to the Information Governance Unit at the
address above (within 2 months of this correspondence) and should detail
in writing your grounds of appeal.

                    

If you are unhappy with the outcome of the internal review you are
entitled to ask the Information Commissioner to investigate your
complaint. You should write to: FOI/EIR Complaints Resolution, Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.

 

Yours sincerely,

 

Information Access Team

Legal Services| Resources
Hertfordshire County Council  
Room 216a  Postal Point: CHN 320
[2][IMG]
T: 01992 555848 (Internal:25848)

E: [3][Hertfordshire County Council request email]

[4]Hertfordshire County Council Facebook[5]Hertfordshire County
Council Twitter[6]Hertfordshire County Council email updates

 

References

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2. https://www.hertfordshire.gov.uk/home.aspx
3. mailto:[Hertfordshire County Council request email]
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5. http://www.twitter.com/hertscc
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Dear Information Governance,

Thank you for your response. In it you said:

"Please see the attached spreadsheet. Please note that this spreadsheet
provides data for the financial year 18/19. Information for the latest
year (19/20) is currently being audited and is subject to change, this
data will be available in the coming weeks if you would like to re-submit
your request."

It has been over three weeks since your response. Can you now provide the same information I requested in the original FOI request, but for the latest financial year (19/20)?

Many thanks.

Yours sincerely,

Edward Jones

Information Governance, Hertfordshire County Council

Dear Edward Jones

 

Reference number: FOI/RAP/08/20/19489

 

Thank you for your correspondence of the requesting the following
information:

 

 

Thank you for your response. In it you said:

 

"Please see the attached spreadsheet. Please note that this spreadsheet
provides data for the financial year 18/19. Information for the latest
year (19/20) is currently being audited and is subject to change, this
data will be available in the coming weeks if you would like to re-submit
your request."

 

It has been over three weeks since your response. Can you now provide the
same information I requested in the original FOI request, but for the
latest financial year (19/20)?

 

Previous request.

 

I would like to request the following information:

 

1) The full details of what the Hertfordshire County Council Pension Fund
currently invests in, including the name and amounts of each asset class
or investment being held.

 

2) The investments broken down into different categories/types of holding,
including: Index Linked Securities, Unit trust Property, Cash Instruments,
Unit Trust Equities, Infrastructure, Fixed Interest Securities, Equities
Segregated Unlisted, Equities Segregated UK, Equities Segregated Foreign
as well as any other investments that the Pension Fund holds.

 

3) The industrial sector of each investment e.g. Aerospace & Defense, Oil
& Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks, Mining,
Government, Automobiles, Financial Services, Housing and any other sectors
that the Pension Fund holds investments in. Examples of Pension Funds
which have previously included this data in their publicly released
investments include Buckinghamshire and Derbyshire. (i)

 

4) A full list of all the companies which the Pension Fund currently
invests in (this should be covered in the above requests). This list
should include the names of each company and the amount invested in each
company.

 

5) Can you clearly specify the total value of all investments that the
Pension Fund holds in sterling.

 

 

 

 

Your request for information is being considered under the Freedom of
Information Act 2000.  We will respond to your request as quickly as
possible, and by close of 07/09/ 2020 at the latest.

 

If you have any questions, please do not hesitate to contact us, quoting
the reference number above.

 

Yours sincerely,

 

 

Information Access Team
Hertfordshire County Council  
County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH 320
T: 01992 555848 (Internal 25848) 
E: [1][Hertfordshire County Council request email]

 

References

Visible links
1. mailto:[Hertfordshire County Council request email]

Information Governance, Hertfordshire County Council

Dear Edward Jones

 

Reference number: FOI/RAP/08/20/19489

 

Further to our email below acknowledging your request, I must advise you
that unfortunately we still do not hold the information.  I am informed
that the we were expecting to have this by now, but due to the
international emergency surrounding the current pandemic, many audit firms
are delaying finalising accounts. For this reason our auditor has been
unable to sign off our accounts. We now expect the finalised accounts will
go to the Audit Committee on 15^th October and will be available after
that date.

 

We are sorry for the inconvenience this may cause but would suggest that
you send in a further request after 15^th October this year when we should
hold the information.

 

If you have any questions, please do not hesitate to contact us, quoting
the reference above. To find out more about Freedom of Information, please
visit [1]http://www.hertfordshire.gov.uk/your-cou...

 

If you are unhappy with the way the County Council has handled your
request for information you may request an internal review of the request.
This will be carried out by a member of the County Council Legal Services
Team, who has had no prior involvement with the request. Requests for an
internal review should be sent to the Information Governance Unit at the
address above.

 

If you are unhappy with the outcome of the internal review you are
entitled to ask the Information Commissioner to investigate your
complaint. You should write to: FOI/EIR Complaints Resolution, Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.

 

 

 

Yours sincerely

 

Information Access Team
Hertfordshire County Council  
County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH 320
T: 01992 555848 (Internal 25848) 
E: [2][Hertfordshire County Council request email]

 

From: Sue Mitchell On Behalf Of Information Governance
Sent: 07 August 2020 14:20
To: [FOI #672366 email]
Subject: Request for information FOI/RAP/08/20/19489

 

Dear Edward Jones

 

Reference number: FOI/RAP/08/20/19489

 

Thank you for your correspondence of the requesting the following
information:

 

 

Thank you for your response. In it you said:

 

"Please see the attached spreadsheet. Please note that this spreadsheet
provides data for the financial year 18/19. Information for the latest
year (19/20) is currently being audited and is subject to change, this
data will be available in the coming weeks if you would like to re-submit
your request."

 

It has been over three weeks since your response. Can you now provide the
same information I requested in the original FOI request, but for the
latest financial year (19/20)?

 

Previous request.

 

I would like to request the following information:

 

1) The full details of what the Hertfordshire County Council Pension Fund
currently invests in, including the name and amounts of each asset class
or investment being held.

 

2) The investments broken down into different categories/types of holding,
including: Index Linked Securities, Unit trust Property, Cash Instruments,
Unit Trust Equities, Infrastructure, Fixed Interest Securities, Equities
Segregated Unlisted, Equities Segregated UK, Equities Segregated Foreign
as well as any other investments that the Pension Fund holds.

 

3) The industrial sector of each investment e.g. Aerospace & Defense, Oil
& Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks, Mining,
Government, Automobiles, Financial Services, Housing and any other sectors
that the Pension Fund holds investments in. Examples of Pension Funds
which have previously included this data in their publicly released
investments include Buckinghamshire and Derbyshire. (i)

 

4) A full list of all the companies which the Pension Fund currently
invests in (this should be covered in the above requests). This list
should include the names of each company and the amount invested in each
company.

 

5) Can you clearly specify the total value of all investments that the
Pension Fund holds in sterling.

 

 

 

 

Your request for information is being considered under the Freedom of
Information Act 2000.  We will respond to your request as quickly as
possible, and by close of 07/09/ 2020 at the latest.

 

If you have any questions, please do not hesitate to contact us, quoting
the reference number above.

 

Yours sincerely,

 

 

Information Access Team
Hertfordshire County Council  
County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH 320
T: 01992 555848 (Internal 25848) 
E: [3][Hertfordshire County Council request email]

 

References

Visible links
1. http://www.hertfordshire.gov.uk/your-cou...
2. mailto:[Hertfordshire County Council request email]
3. mailto:[Hertfordshire County Council request email]

Dear Information Governance,

Many thanks for your response.

You say:

"Further to our email below acknowledging your request, I must advise you that unfortunately we still do not hold the information. I am informed that the we were expecting to have this by now, but due to the international emergency surrounding the current pandemic, many audit firms are delaying finalising accounts. For this reason our auditor has been unable to sign off our accounts. We now expect the finalised accounts will
go to the Audit Committee on 15^th October and will be available after that date.

"We are sorry for the inconvenience this may cause but would suggest that you send in a further request after 15^th October this year when we should hold the information."

Is it possible for you to provide the information as soon as possible, and reply to this message as soon as you get it (via whatdothey) with the investment information attached, rather than requiring me to make a new FOI request after 15 October?

Yours sincerely,

Edward Jones

Information Governance, Hertfordshire County Council

Dear Edward Jones

Thank you for your email. I understand the annoyance that this unavoidable delay may cause, but as stated, at the moment we do not hold this information and under Freedom of Information legislation we are unable to process your request. The legislation does not require us to diary requests until such time as the information is available, and it would not be practical for us to undertake this function.

As I said you would be welcome to resubmit your request in the latter half of October. If you are unhappy with the way the County Council has handled your request for information you may request an internal review of the request.
This will be carried out by a member of the County Council Legal Services Team, who has had no prior involvement with the request. Requests for an internal review should be sent to the Information Governance Unit at the address above.

Yours sincerely

Information Access Team
Hertfordshire County Council  
County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH 320
T: 01992 555848 (Internal 25848) 
E: [Hertfordshire County Council request email]

show quoted sections

Dear Information Governance,

In your previous response you said: ""We are sorry for the inconvenience this may cause but would suggest that you send in a further request after 15th October this year when we should hold the information.""

It is now the 16th October. Can this please count this as a new request for the information I originally asked for ( Reference number: FOI/RAP/06/20/19333 )?

Yours sincerely,

Edward Jones

Information Governance, Hertfordshire County Council

Dear Mr Jones

Thank you for your email of 16th September. My colleague advised you in August to contact us after the 15th October. At this stage as we are still in September and the information you have requested is not yet available, we are still unable to assist you with your request.

Please contact us after 15th October 2020 and preferably after 30th November 2020 when the audit will be officially signed off and when we will be able to advise you further.

If you have any questions, please do not hesitate to contact me, quoting the reference above. To find out more about Freedom of Information, please visit http://www.hertfordshire.gov.uk/your-cou...

If you are unhappy with the way the County Council has handled your request for information you may request an internal review of the request. This will be carried out by a member of the County Council Legal Services Team, who has had no prior involvement with the request. Requests for an internal review should be sent to the Information Governance Unit at the address above.

If you are unhappy with the outcome of the internal review you are entitled to ask the Information Commissioner to investigate your complaint. You should write to: FOI/EIR Complaints Resolution, Information Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF.

Your sincerely

Ingrid Howard
Information Access Practitioner
Information Access Team
Hertfordshire County Council  
223 County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH0320
T: 01992 555848 (Internal 25848) 
E: [Hertfordshire County Council request email]

show quoted sections

Dear Information Governance,

Sorry for my mistake on the date! Thanks for your help.

Yours sincerely,

Edward Jones

Dear Information Governance,

As earlier agreed I am contacting you after the 15th of October. Could you provide me with an update on the status of my FOIA request?

Yours sincerely,

Edward Jones

Information Governance, Hertfordshire County Council

4 Attachments

Dear Mr Jones

 

Reference number: FOI/RAP/10/20/19923

 

On 29^th October Hertfordshire County Council received the following
request for information from you: -

 

Can you now provide the same information I requested in the original FOI
request, but for the latest financial year (19/20)?

 

This is a follow up to the data we provided to you under reference
FOI/RAP/06/20/19333 in June 2020. You also asked for this information in
August/September under reference FOI/RAP/08/20/19489 when unfortunately,
we did not hold the data.

 

The request for FOI/RAP/06/20/19333 was: -

 

I would like to request the following information:

 

 1. The full details of what the Hertfordshire County Council Pension Fund
currently invests in, including the name and amounts of each asset
class or investment being held.
 2. The investments broken down into different categories/types of
holding, including: Index Linked Securities, Unit trust Property, Cash
Instruments, Unit Trust Equities, Infrastructure, Fixed Interest
Securities, Equities Segregated Unlisted, Equities Segregated UK,
Equities Segregated Foreign as well as any other investments that the
Pension Fund holds.
 3. The industrial sector of each investment e.g. Aerospace & Defense, Oil
& Gas Producers, Pharmaceuticals & Biotechnology, Media, Banks,
Mining, Government, Automobiles, Financial Services, Housing and any
other sectors that the Pension Fund holds investments in. Examples of
Pension Funds which have previously included this data in their
publicly released investments include Buckinghamshire and Derbyshire.
(i)
 4. A full list of all the companies which the Pension Fund currently
invests in (this should be covered in the above requests). This list
should include the names of each company and the amount invested in
each company.
 5. Can you clearly specify the total value of all investments that the
Pension Fund holds in sterling.
 6. I would like to receive this information in an unlocked excel sheet
without protected cells (.xls). If you have to password protect the
excel sheet, can you also provide the password to the excel sheet.
When considering the request for this data in excel format, please
refer to Innes v Information Commissioner [2014] EWCA Civ 1086 (ii),
which allows a requestor to express a preference for communication by
a particular means, specifically: "an applicant's right to choose to
have information provided to him in electronic form extends to a right
to choose the software format in which it is embodied." (iii)

 

Our Response

 

Your request for information has been considered under the Freedom of
Information Act 2000 I can confirm that Hertfordshire County Council does
hold the information you have requested, and can respond as follows: -

 

Please find attached spreadsheet with the data you requested. For your
information we have highlighted some cells as follow:-

 

Blue cells – We currently don’t hold the information to complete this
element.

Red cells – We are refusing this data as outlined below

 

After careful consideration we are withholding this information under the
exemption contained in section 43(2) of the Freedom of Information Act
2000 which relates to Commercial Interests.  As this exemption is a
qualified exemption, in reaching its decision, the Council has balanced
the public interest test in the disclosure of information against the
public interest in withholding it.

 

The factors we have considered which are in favour of disclosure are:

* There is a public interest in allowing scrutiny of how public money is
invested
* Facilitate the accountability and transparency of public authorities for
decisions taken by them including pensions procurement
* Allow individuals to understand decisions made by public authorities
affecting their lives and, in some cases, assist individuals in
challenging those decisions;

 

The factors we have considered which are against disclosure are:

 3. The information is commercial in nature
 4. The information is not in the public domain
 5. The disclosure of the requested information would potentially cause
detriment to the commercial interests of the organisations concerned
as the information could identify which investment managers are
investing in which companies,
 6. Disclosure may make it more difficult for public bodies to be able to
conduct commercial transactions or have other dealings with investment
companies
 7. The public interest in ensuring companies are able to conduct their
business with the County Council without having their details passed
to any other company or third party.

 

On balance, we consider that the public interest does not favour
disclosing the requested information as it would or would be likely to
prejudice the commercial interests of both the investment managers and
ourselves for current and future dealings

 

If you have any questions, please do not hesitate to contact me, quoting
the reference above. To find out more about Freedom of Information, please
visit [1]http://www.hertfordshire.gov.uk/your-cou...

 

If you are unhappy with the way the County Council has handled your
request for information you may request an internal review of the request.
This will be carried out by a member of the County Council Legal Services
Team, who has had no prior involvement with the request. Requests for an
internal review should be sent to the Information Governance Unit at the
address above.

 

If you are unhappy with the outcome of the internal review you are
entitled to ask the Information Commissioner to investigate your
complaint. You should write to: FOI/EIR Complaints Resolution, Information
Commissioner's Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9
5AF.

 

Yours sincerely

 

 

 

Ingrid Howard
Information Access Practitioner

Information Access Team
Hertfordshire County Council  
223 County Hall, Pegs Lane, Hertford, SG13 8DE, Postal Point: CH0320
T: 01992 555848 (Internal 25848) 
E: [2][Hertfordshire County Council request email]

 

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Twitter[5]Hertfordshire County Council email updates

 

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