Information about your dealings with Stonewall [Extraneous material removed]

The request was partially successful.

Dear Historic Buildings and Monuments Commission for England,

This is a request under the Freedom of Information Act 2000 (FOIA). Please provide any information that you hold answering to any of the following descriptions:

1. Any application you made in 2019 or 2020 to be a “Stonewall Diversity Champion” or to be included on Stonewall’s “Workplace Equality Index,” including any attachments or appendices to those applications. Please redact personal details if necessary.

2. Any feedback you received in 2019 or 2020 from Stonewall in relation to either application or programme.

3. Any other communication you have received from Stonewall in 2019 or 2020 unless privileged or otherwise exempt from disclosure (but if you claim privilege or exemption in relation to any material, please say in broad terms what the material is and the basis on which you claim to be entitled to withhold it).

4. Full details of any equality impact assessment you carried out connected with any of these applications (including any equality impact assessment carried out prior to an earlier application of the same kind, if no further assessment was done).

5. Details of the total amount of money you paid to Stonewall (i) in 2019; (ii) in 2020, whether or not as payment for goods or services.

6. Whether you intend to continue your membership of any Stonewall scheme in the future, and if so which.

Yours faithfully,

Ermine Amies

FOI, Historic Buildings and Monuments Commission for England

Our Reference:21/01529

Dear Mr Amies,

Re: Information Request – Stonewall #DontSubmitToStonewall

Thank you for your email on 8 February in which you requested the
following information:
 
Please provide any information that you hold answering to any of the
following descriptions:1. Any application you made in 2019 or 2020 to be a
“Stonewall Diversity Champion” or to be included on Stonewall’s “Workplace
Equality Index,” including any attachments or appendices to those
applications. Please redact personal details if necessary.2. Any feedback
you received in 2019 or 2020 from Stonewall in relation to either
application or programme.3. Any other communication you have received from
Stonewall in 2019 or 2020 unless privileged or otherwise exempt from
disclosure (but if you claim privilege or exemption in relation to any
material, please say in broad terms what the material is and the basis on
which you claim to be entitled to withhold it).4. Full details of any
equality impact assessment you carried out connected with any of these
applications (including any equality impact assessment carried out prior
to an earlier application of the same kind, if no further assessment was
done).5. Details of the total amount of money you paid to Stonewall (i) in
2019; (ii) in 2020, whether or not as payment for goods or services.6.
Whether you intend to continue your membership of any Stonewall scheme in
the future, and if so which.

Your request will be considered under the Freedom of Information Act
(2000). We will be writing to you within the statutory 20 working day
timeframe with a response to your request.  You will be informed if this
is not possible.

Yours sincerely, 

Information Rights Team

Historic England
The Engine House
Swindon
SN2 2EH

Telephone: 01793 414567

We will keep a record of contact details provided by you and details of
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Dear FOI,

Your response is overdue. I look forward to hearing from you.

Yours sincerely,

Ermine Amies

Gibbons, Frances, Historic Buildings and Monuments Commission for England

47 Attachments

REF: 21/ 01529

 

Dear Ermine Amies

 

Thank you for your email dated 8 February in which you have requested the
following:

 

1. Any application you made in 2019 or 2020 to be a “Stonewall Diversity
Champion” or to be included on Stonewall’s “Workplace Equality Index,”
including any attachments or appendices to those applications. Please
redact personal details if necessary.

 

2. Any feedback you received in 2019 or 2020 from Stonewall in relation to
either application or programme.

 

3. Any other communication you have received from Stonewall in 2019 or
2020 unless privileged or otherwise exempt from disclosure (but if you
claim privilege or exemption in relation to any material, please say in
broad terms what the material is and the basis on which you claim to be
entitled to withhold it).

 

4. Full details of any equality impact assessment you carried out
connected with any of these applications (including any equality impact
assessment carried out prior to an earlier application of the same kind,
if no further assessment was done).

 

5. Details of the total amount of money you paid to Stonewall (i) in 2019;
(ii) in 2020, whether or not as payment for goods or services.

 

6. Whether you intend to continue your membership of any Stonewall scheme
in the future, and if so which.

 

Your request has been processed under the Freedom of Information Act 2000
(FOIA).

 

Firstly, I would like to apologise for the delay in my response.

 

Having consulted with a number of colleagues in regards to your request I
can confirm that Historic England did not apply to be a Diversity Champion
in 2019 or 2020, although we are already members of the scheme. Further to
this I can confirm that we did not take part in the Workplace Equality
Index. Historic England will continue with our membership of the Diversity
Champion programme as part of our commitment to inclusion, diversity and
equality. I can confirm that for the year April 2019- April 2020 Historic
England paid Stonewall a Diversity Champions membership fee of £3000 which
included VAT.

 

Finally in regards to communications from Stonewall, please find attached
copies of the documentation held by Historic England.

 

You should be aware that I have removed personal data from the attached.
In making this decision I have relied upon Section 40 of the FOIA 2000-
third party personal data, the disclosure of which would breach one or
more of the data protection principles in the Data Protection Legislation
2018.

 

I have also withheld a number of documents in full. In making this
decision I have relied upon Section 43 of the FOIA.

 

Section 43- Commercial Interest (FOIA).

 

Under Section 43(2) of the FOIA information is exempt if its disclosure
would, or would be likely to, prejudice the commercial interests of any
person (including the public authority holding it). I believe that the
information in question falls within the remit of this exemption because
it consists of guidance produced by both Stonewall and Historic England
under the membership scheme. The release of which could prejudice both
parties commercial interests if it was placed in the public domain at this
time. The exemption contained within section 43 of the FOIA is subject to
a public interest test which means that I have to consider whether the
public interest in maintaining the exemption outweighs the public interest
in disclosing the information.

In favour of disclosure I have considered the public interest in
transparency and the importance of Historic England’s accountability and
openness in regards to its processes concerning work place equality.

 

In favour of maintaining the exemption I have considered the importance of
ensuring that both Historic England and Stonewall have the ability to
operate and run their businesses in a competitive commercial environment,
and that they are not put at a disadvantage by the release of information
that may be of potential use to others in similar fields. It is important
to note that any information that is released under the FOIA is considered
to be in the public domain, so to release information that companies are
only privy to via paid membership, or to release pieces of guidance which
have been developed and built upon by Historic England staff via the
resources available via the Stonewall membership, would be inappropriate.

 

Having considered the above arguments I have concluded that the public
interest is currently best served by maintaining the exception.

 

Finally, I have removed information on the basis of relevance.

 

I hope the information I have been able to provide is useful to you.
Details of our review procedure are attached.

 

Yours sincerely

 

Frances Gibbons

 

Mrs Frances Gibbons
Senior Information Rights Officer

Information and Records Management

Historic England | Room 2/20 | The Engine House | Fire Fly Avenue |
Swindon | Wiltshire | SN2 2EH

I am currently working from home Monday- Friday 8-2.

 

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References

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Dear Frances,

Thank you.

Yours sincerely,

Ermine Amies

Ermine Amies left an annotation ()

Request partially answered. Section 43- Commercial Interest (FOIA) exemption.

Documents have been withheld in full include WEI application, Stonewall feedback, comment on HR policies and advice on toilets for the transgender policy.

“Under Section 43(2) of the FOIA information is exempt if its disclosure would, or would be likely to, prejudice the commercial interests of any person (including the public authority holding it). I believe that the information in question falls within the remit of this exemption because it consists of guidance produced by both Stonewall and Historic England under the membership scheme. The release of which could prejudice both parties commercial interests if it was placed in the public domain at this time. The exemption contained within section 43 of the FOIA is subject to a public interest test which means that I have to consider whether the public interest in maintaining the exemption outweighs the public interest in disclosing the information.
In favour of disclosure I have considered the public interest in transparency and the importance of Historic England’s accountability and openness in regards to its processes concerning work place equality.

In favour of maintaining the exemption I have considered the importance of ensuring that both Historic England and Stonewall have the ability to operate and run their businesses in a competitive commercial environment, and that they are not put at a disadvantage by the release of information that may be of potential use to others in similar fields. It is important to note that any information that is released under the FOIA is considered to be in the public domain, so to release information that companies are only privy to via paid membership, or to release pieces of guidance which have been developed and built upon by Historic England staff via the resources available via the Stonewall membership, would be inappropriate.

Having considered the above arguments I have concluded that the public interest is currently best served by maintaining the exception.”

Attachments - the info include newsletters and invoice arrangements and agreeing appointments to talk. No emails #7 and #20.

Extracts from some attachments follows for ease of reference:

Email 6: request to lobby govt re trans inclusion inc CEO to write a private letter to the PM and Women and Equalities Minister, individual letters using Gendered Intelligence format and women to take action on twitter with Mermaids like Nancy Kelley has.

Email 20
Inclusion and Volunteer Development Manager maybe interested in joining discussion on “how Historic England can work with Stonewall to ensure that we are doing all that we can to promote, encourage and champion diversity, equality and inclusion.
Learn all we can from Stonewall re. recent developments in organisational best practice, and discuss how we can build on our existing policies, practices, network and initiatives in this regard.“

Email 21
“It would also be good to hear an update on your trans inclusion policy, especially seeing as you’ll be rolling out guidance on pronouns. It’s important for a number of reasons, such as ensuring you have a zero‐tolerance stance on transphobia (such as intentional misgendering) and also so that there isn’t a contradictory message sent to employees whereby people may be supported to share pronouns on email signatures, but there may not be a policy in place to support employees transitioning.”

Email 22
“At Stonewall, we are embarking on an exciting new project to explore how we can expand our offering to include guidance for volunteer recruitment and management. If your organisation recruits volunteers, we would really appreciate you filling in this survey, which will help us build an accurate picture of the type of support we should be providing.
We are also looking to profile organisations with best practice systems in place. If you are interested in being profiled in a case study, please do leave your email at the end of the survey.
Senior Membership Programmes Manager – Public and Third Sector “

Emails 23
Thanks again for your time last week, it was great to meet with you all and I feel that we had some really useful discussions about the Diversity Champions Membership and how we can make sure Historic England are making the most of the membership. I’ll be on hand to support at any stage, so don’t hesitate to reach out with any questions.
Please see below the key action points from our meeting:
I have attached an ‘ally pledge card’ which Oxford Brookes University are happy to share. If you were able to relaunch / reinvigorate your Staff Network in February for LGBT History Month, it could be a good idea to launch a pledge scheme for allies, whereby they sign up (in person or online) so key actions before joining the network / wearing a rainbow lanyard etc… I’d be happy to support , go through ideas and review any content for this.

Emails 33 includes
16 December 2019 10:10
To:
@stonewall.org.uk)

Firstly, we’re in the process of writing a Transgender policy with a view to launching in the new year, but one section I’m struggling with is the section on Toilets – what is Stonewall’s stance on policies around toilets in the workplace in this context, and is there any best practice example text you could provide?
Secondly, I’d be keen for us to look at a policy review in the new year – please may you confirm which policies you’d like me to send over for review?
Hope you have a great festive break, and I look forward to working with you in 2020!
Warm regards,

HR Advisor/ HR Policy & Projects Senior Specialist
Historic England

Note: response from Stonewall on toilets withheld.

Email 34
18 August 2020

New Stonewall Client Account ManagerIt’s been really great working with you , and I’m really excited to hear about the launch of the Trans Inclusion policy alongside the network relaunch and the inclusion of pronouns in email signatures – it’s all work that will make a real impact and that you should be really proud of.
Best wishes,

Client Account Manager – Public Sector

Email 36 11 May 2020 10:48

RE: Membership Expiry - RE: A couple of questions
Attachments:
Stonewall comments 5.13 Shared Parental Leave Revised - DRAFT.docx; Stonewall comments
Bullying and Harassment.docx

Note:[docs not attached]

Email 38
@HistoricEngland.org.uk>

Thanks for getting in touch. My colleague will be in touch to arrange payment, apologies for the delay.
As a bit of background, we were previously known as English Heritage and I think we’ve been working with Stonewall for around a decade now. Our organisation split into two in 2015, with the formation of the English Heritage Trust, who retained the logo and brand, and we were created as a new organisation. We found that the Top 100 format wasn’t working well for us because we were struggling to compete with other organisations and so it almost felt that we were going backwards, despite doing a lot of work both internally and in areas like our ground breaking Pride
of Place project. We’re really committed to equality and decided to continue to be Stonewall members without competing in the Top 100. We feel that we haven’t seen as much benefit from our membership over the last few years as we used to and we’d really like to work with you this year to look to rekindle the positive relationship that we had.