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Information about Stonewall Workplace Equality Index (WEI)

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Dear City of London Corporation,

Please can you

1. Confirm whether your organisation applied to be part of the Stonewall Workplace Equality Index in A) 2018 (for 2019), B) 2019 (for 2020) or C) 2021 (for 2022) (NB the index was suspended in 2020/21 because of Covid)

2. Give details of the total amount of money you paid to Stonewall in 2021 whether or not as payment for goods or services.

3. State whether you intend to continue your membership of any Stonewall scheme in the future, and if so which.

If the answer to any part of 1 is yes please supply:

4. Any application you made in 2021 to be included on Stonewall’s Workplace Equality Index, including any attachments or appendices to those applications. Please redact personal details if necessary.

5. Any feedback you received in 2018/19 or 2019/20 or 2021/22 from Stonewall in relation to either application or programme. This must include the priorities or objectives written by your organisation’s representative at the end of the feedback form (under the heading ‘Priorities for the year ahead’ in 2019; ‘Your priorities’ in 2020).

EXEMPTIONS?

If your organisation is considering refusing to disclose feedback received as part of the Stonewall scheme by relying on section 41 (confidential information) and/or section 43 (commercial interest) of FOI, please note the recent ICO decisions IC-129040-Y4T2 and IC-125081-Q8J6 which rejected these reasons. Sex Matters has written a short briefing on these two ICO decisions – please see www.sex-matters.org/wp-content/uploads/2...

Yours faithfully,

C Oriordon

COL-EB-InformationOfficer, City of London Corporation

Dear C Oriordon,

FREEDOM OF INFORMATION ACT 2000 (FOIA) - REQUEST FOR INFORMATION

The City of London (CoL) acknowledges receipt of your request for information of 31 July 2022.

Public authorities are required to respond to requests within the statutory timescale of 20 working days beginning from the first working day after they receive a request. The Act does not always require public authorities to disclose the information which they hold.

The FOIA applies to the CoL as a local authority, police authority and port health authority. The CoL is the local and police authority for the "Square Mile", ie the historic City of London, and not for London as a whole. Please see the following page containing a link to a map (City of London - Interactive Mapping), which shows the local authority area covered by the CoL:
https://www.mapping.cityoflondon.gov.uk/...

The CoL does have some functions, including Port Health Authority functions, which extend beyond the City boundary. For further information please see: www.cityoflondon.gov.uk.

Yours sincerely,

Information Officer
Comptroller & City Solicitor's Department
City of London
Tel: 020-7332 1243
www.cityoflondon.gov.uk

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COL-EB-InformationOfficer, City of London Corporation

2 Attachments

Dear C Oriordon

FREEDOM OF INFORMATION ACT 2000 (FOIA) - REQUEST FOR INFORMATION

Following your request of 31 July 2022, and our acknowledgement of 1 August 2022, the City of London (CoL) responds as follows.

1. Confirm whether your organisation applied to be part of the Stonewall Workplace Equality Index in A) 2018 (for 2019), B) 2019 (for 2020) or C) 2021 (for 2022) (NB the index was suspended in 2020/21 because of Covid)

The City of London can confirm that we applied to be part of the Stonewall Workplace equality index in 2019 for the 2020 calendar year.

2. Give details of the total amount of money you paid to Stonewall in 2021 whether or not as payment for goods or services.

We can confirm that £3,000 was paid to Stonewall in relation to - Diversity Champions Membership, for the period from 25 March 2021-24 March2022.

3. State whether you intend to continue your membership of any Stonewall scheme in the future, and if so which.

The City of London can confirm that this decision has not yet been undertaken and therefore this information is not currently held.

If the answer to any part of 1 is yes please supply:

4. Any application you made in 2021 to be included on Stonewall's Workplace Equality Index, including any attachments or appendices to those applications. Please redact personal details if necessary.

The City of London can confirm that no application was made to Stonewall's Equality Index in 2021 and therefore this information is not held.

5. Any feedback you received in 2018/19 or 2019/20 or 2021/22 from Stonewall in relation to either application or programme. This must include the priorities or objectives written by your organisation's representative at the end of the feedback form (under the heading 'Priorities for the year ahead' in 2019; 'Your priorities' in 2020).

Please find attached a copy of the feedback for received in relation to our 2019/2020 submission.

Please note that the City of London can do not hold a copy of the priorities or objectives written by the organisation at the end of the feedback form.

However, we have attached a copy of the Action Plan for the Workplace Equality Index which was created following the feedback received our 2019/2020 submission.

We note that a Workplace Equality Index Task and Finish Group which was made up of all relevant contributors from across the City Corporation created project plan to look at the priorities arising from the WEI feedback and the following years draft submission.

Please note we have reviewed both documents and where applicable have redacted some information in accordance with Section 40(2) of the Freedom of Information Act 2000, where the information relates to personal data. Please see the following s40(2) statement.

Section 40(2)

Please note that the CoL does not, under the FOIA, disclose the names of staff below senior management level, or the direct contact details of any staff, except in so far as such names and contact details may be already routinely disclosed on its website.

The CoL considers its position of non-disclosure is supported by the appeal decisions of the Information Tribunal. For example, Appeal Decision EA/2006/0027 concluded that contact details of staff other than those contact details already routinely in the public domain should not be disclosed. The Information Commissioner followed this lead, for example in decision notices FS50184497 and FS50344341. In Decision Notice FS50184497, the Commissioner stated that he could see no public interest arguments in support of wholesale disclosure of names and direct contact details of public sector staff.

The Information Tribunal has also stated that "to release the name of an individual's employer would be to release significant personal data" (Appeal decision EA/2007/0058), and hence could be a breach of the Data Protection Act. Such disclosure would inevitably take place should the CoL release the names of staff and/or personalised email addresses, although of course top managers accept that their names (but not direct contact details) are already routinely in the public domain.

Please note, too, that a public authority has to consider a disclosure under the FOIA as a disclosure to the world. We note the Information Tribunal's statement that "Disclosure under [the] FOIA is effectively an unlimited disclosure to the public as a whole, without conditions" (Information Tribunal Appeal Decision EA/2006/0011 & 0013).

The abovementioned decisions by the Commissioner and Tribunal have never been overturned.

The relevant exemption being applied above by the CoL is the FOIA section 40(2) (personal information) exemption. In conclusion, with regard to this exemption, the CoL does not see any legitimate interests in the public having access to the information and considers that disclosure would not pay due respect to the rights and freedoms of the data subjects, ie in this instance members of staff. We do not see any conditions under Article 6 (which concerns conditions for processing personal data) of the General Data Protection Regulation (GDPR) which would permit disclosure. The CoL also does not consider that there are any conditions under Section 1(2) of the Data Protection Act 2018 (DPA, which refers to the GDPR, and in this instance the relevant Article of which would be Article 6, concerning conditions under Principle 1 for processing personal information) which would permit disclosure.

We hope that this response is of assistance.

If you wish to make a complaint about the way the CoL has managed your enquiry, please make your complaint in writing to email address: [email address] For a link to the CoL's FOI complaints procedure, please visit the following page: www.cityoflondon.gov.uk/Feedback, at the end of which is located the FOI complaints procedure. If, having used the CoL's FOI Complaints Procedure, you are still dissatisfied, you may request the Information Commissioner to investigate. Please contact: Information Commissioner, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF. Telephone: (01625) 545700. Website: http://www.ico.org.uk/.

The FOIA applies to the CoL as a local authority, police authority and port health authority; and to the Guildhall School of Music and Drama (GSMD), which it manages. Subject to any other statutory provisions requiring the CoL to disclose information, release of information outside the scope of the Act is subject to the discretion of the CoL.

The CoL holds the copyright in this communication. Its supply does not give a right to re-use in a way that would infringe that copyright, for example, by making copies, publishing and issuing copies to the public or to any other person. Brief extracts of any of the material may be reproduced under the fair dealing provisions of the Copyright, Designs and Patents Act 1988 (sections 29 and 30) for the purposes of research for non-commercial purposes, private study, criticism, review and news reporting, subject to an acknowledgement of the copyright owner.

Yours sincerely,

Information Officer
Comptroller & City Solicitor's Department
City of London
Tel: 020-7332 1243

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We don't know whether the most recent response to this request contains information or not – if you are C Oriordon please sign in and let everyone know.