Information on your dealings with Stonewall (01-01-2021 to date)

Laura Ko made this Freedom of Information request to The Financial Conduct Authority Automatic anti-spam measures are in place for this older request. Please let us know if a further response is expected or if you are having trouble responding.

The request was partially successful.

Dear The Financial Conduct Authority,

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 (or intend to make) from 01-01- 2021 or in 2022 (to date) 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 2021, or to date, from Stonewall in relation to either application or programme.

3. Any other communication you have received from Stonewall in 2021 or 2022 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 2021; (ii) in 2022 to date, 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,

L Ko

Freedom of Information, The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

3 Attachments

Our ref:        FOI9102

 

Dear Ms Ko

 

Freedom of Information: Right to know request

 

Thank you for your email of 7 March 2021, in which you asked for
Information on our dealings with Stonewall (01-01-2021 to date). Please
see Annex A for full details of your request.

 

We have processed your email in line with the provisions of the Freedom of
Information Act 2000 (FOIA) and our response is below.

 

Having reviewed your request, we estimate that responding to question 3
would exceed the cost limit allowed under FOIA and therefore the exemption
under section 12 (Cost of compliance exceeds appropriate limit) applies.
For more information on why this exemption applies, please see Annex B
below.

 

When we refuse a request because it exceeds the cost limit, we generally
seek to advise on how you can refine or limit your request so that it is
more likely to fall within the cost limit. In this instance, we could
consider a revised request for questions 1, 2, 4, 5 and 6 of your current
request. However, in relation to question 3, due to the volume of
potentially relevant information we hold in respect of this question, we
are unable to suggest a way in which to refine this part of your request.

 

Should you wish to proceed with a refined request, please confirm this in
writing and we will process it as a new request in line with the
provisions of FOIA.

 

Please note that, in offering to consider such a refined request, we have
not considered whether any other exemptions apply

 

Your right to complain under FOIA

 

If you are unhappy with this response, you have the right to request an
internal review.  To do so, please contact us within 40 working days of
the date of this response at [1][email address].

 

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner by phone or on
their website at:

Telephone: 0303 123 1113

Website: [2]www.ico.org.uk

Yours sincerely

 

 

Information Disclosure Team / Operations Division

[3]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

[4]www.fca.org.uk

 

Follow us:

 

[5]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

 

 

 

 

Annex A

 

Request received on 7 March 2022:

 

“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 (or intend to make) from 01-01- 2021 or in
2022 (to date) 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 2021, or to date, from Stonewall in
relation to either application or programme.

 

3. Any other communication you have received from Stonewall in 2021 or
2022 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 2021;
(ii) in 2022 to date, 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.”

 

 

Annex B

 

•       Section 12 (Cost of compliance exceeds appropriate limit)

 

FOIA requires us to comply with a request, unless it would be too
expensive to do so, as estimated in line with the Freedom of Information
and Data Protection (Appropriate Limit and Fees) Regulations 2004. 

 

Under these regulations, the cost limit for the FCA is £450, i.e. 18 hours
at the rate of £25 per person hour.  The regulations allow us to take into
account when estimating the cost of complying with a request, the time
spent determining whether we hold the information requested, locating and
retrieving it, and extracting the information from the relevant
document(s).

 

To establish all the information that falls within scope of your request
would exceed the cost limit. Given the broad nature of question 3 of your
request, we would need to conduct a search of the email accounts of all
current FCA employees who may have engaged with Stonewall in those years.
We would also need to consider if any FCA staff who have left could might
have engaged with Stonewall in that period and, where still available,
conduct searches for their email records too. We estimate this exercise
would significantly exceed the cost limit.

 

We do not divert our resources from our regulatory functions to meet
requests under FOIA above the cost limit.  While we know this may
disappoint you, we are sorry we cannot carry out an exercise to identify
the information you have requested.

 

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. file:///C:/Users/sali3/AppData/Roaming/OTLocal/PRODRM/Workbin/3E7676D.0/[email address]
2. http://www.ico.org.uk/
4. http://www.fca.org.uk/
5. https://twitter.com/TheFCA
6. https://www.linkedin.com/company/financi...

Dear Financial Conduct Authority,

Further to your response to my FOI regarding dealings with Stonewall from January 2021 until the present day.

You specify that 'In this instance, we could consider a revised request for questions 1, 2, 4, 5 and 6 of your current request.'

Please can you therefore respond to questions 1,2,4,5 & 6 as detailed below. If possible, and if it falls within the time frames allowed, please can you simply clarify whether you have received further correspondence or communication from Stonewall and what it pertains to. Please limit your responses accordingly by attaching the WEI application only, or simply giving the fees. I trust that you will be able to respond within your 18 hour window by simplifying any responses to the key information only.

1. Any application you made (or intend to make) in 2021 or 2022 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 2021, or to date, from Stonewall in relation to either application or programme.
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 2021; (ii) in 2022, 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 sincerely

L Ko

Freedom of Information, The Financial Conduct Authority

Thank you for e-mailing the Financial Conduct Authority's Information
Disclosure Team.

This is an automatic acknowledgement to tell you that we have received
your email safely.

Please do not reply to this email.

We will be in touch in due course.

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

Freedom of Information, The Financial Conduct Authority

3 Attachments

Our ref: FOI9188

 

Dear Ms Ko

 

We are sorry to inform you that we are still processing your request
concerning any applications by the FCA’s dealing with Stonewall from 1
January 2021 and 7 March 2022 and will not be able to respond by today’s
deadline.  We are experiencing a high volume of requests and are currently
focused on working through the cases.

 

We will continue to process your request and will provide you with a
further update on our progress by no later than 20 May 2022.  If we are
able to respond sooner, we will of course do so.

 

Please accept our apologies for the delay and any inconvenience this may
cause and thank you for your understanding and patience.

 

Yours sincerely

 

Information Disclosure Team / Operations Division

[1]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

[2]www.fca.org.uk

 

Follow us:

 

[3]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
2. http://www.fca.org.uk/
3. https://twitter.com/TheFCA
4. https://www.linkedin.com/company/financi...

Freedom of Information, The Financial Conduct Authority

5 Attachments

Our ref:        FOI9188

 

Dear Ms Ko

 

Freedom of Information: Right to know request

 

Thank you for your email of 5 April 2022, in which you asked:

 

Please can you therefore respond to questions 1,2,4,5 & 6 as detailed
below. If possible, and if it falls within the time frames allowed, please
can you simply clarify whether you have received further correspondence or
communication from Stonewall and what it pertains to.  Please limit your
responses accordingly by attaching the WEI application only, or simply
giving the fees.  I trust that you will be able to respond within your 18
hour window by simplifying any responses to the key information only.

 

1. Any application you made (or intend to make) in 2021 or 2022 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 2021, or to date, from Stonewall in
relation to either application or programme.

 

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 2021;
(ii) in 2022, 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.

 

Please accept our apologies for the delay in responding to you. We have
processed your email in line with the provisions of the Freedom of
Information Act 2000 (FOIA) and our response is below.

 

Our decision on your request

 

For question 1, we made a submission in October 2021 to be included in the
Stonewall Workplace Equality Index (WEI) 2022. Please see Annex A below
for a copy of this submission. We are unable to disclose some of
information to you under section 40 (personal data) of FOIA. This is
because disclosing this information would reveal personal information
about the individuals concerned. For more information on why we are
applying this exemption please see Annex B below.

 

We have not made any submissions to Stonewall during 2022 to date.

 

For question 2, we can confirm no feedback was received in 2021, as there
was no WEI undertaken in that year. Please see Annex C below for the
feedback received on the submission made in 2021 for the 2022 WEI.

 

For question 4, we do not hold any information as we do not carry out such
assessments for any of our Diversity & Inclusion benchmark submissions.

 

For question 5, we can confirm that in 2021 we paid £6,000 for renewal of
membership for the Stonewall Diversity Champions Programme. For 2022 we
can confirm we paid £840 for 2 tickets to the Stonewall Workplace
Conference.

 

For question 6, we currently have Stonewall Diversity Champions membership
and this membership runs to 31 October 2022. We review all our corporate
memberships each year and would consider whether to renew this membership
much closer to the time of renewal.

 

Your right to complain under FOIA

 

If you are unhappy with this response, you have the right to request an
internal review.  To do so, please contact us within 40 working days of
the date of this response at [1][email address].

 

If you are not content with the outcome of the internal review, you also
have a right of appeal to the Information Commissioner by phone or on
their website at:

 

Telephone: 0303 123 1113

Website: [2]www.ico.org.uk

 

Yours sincerely

 

 

Information Disclosure Team / Operations Division

[3]Description: cid:image001.png@01D2A7C9.64DDD390

12 Endeavour Square

London

E20 1JN

 

[4]www.fca.org.uk

 

Follow us:

 

[5]Description: https://g.twimg.com/Twitter_logo_blue.pn...
image003

 

 

Annex A

 

See attached the submission made by FCA in 2021 for the 2022 WEI.

 

Annex B

 

• Section 40 (personal information)

 

To the extent that the information that we hold contains personal data
about individuals, section 40(2)(b) of the Act provides that "[a]ny
information to which a request for information relates is also exempt
information if the first, second or third condition listed below is
satisfied."

 

We have applied this exemption because the first condition (as stated in
section 40(3A) of FOIA) is satisfied. Some of the information you have
requested comprises the personal data of individuals other than yourself
which, if disclosed, would contravene any of the data protection
principles.

 

In particular, it would be a breach of the first data protection Principle
as set out in Article 5.1(a) of the UK GDPR, to disclose such information,
as it would not be lawful or fair to do so.

 

This is an “absolute” exemption, and so it is not necessary to balance the
public interest for and against disclosing the information.

 

 

Annex C

 

See attached the feedback received from Stonewall on the submission made
by FCA in 2021 for the 2022 WEI.

 

 

 

This communication and any attachments may contain personal information.
For more information about how and why we use personal information and who
to contact with any queries about this, please see our privacy notices:
FCA Privacy Notice (https://www.fca.org.uk/data-protection) and PSR
Privacy Notice
(https://www.psr.org.uk/cookies-privacy-a...).

This communication and any attachments contain information which is
confidential and may be subject to legal privilege. It is for intended
recipients only. If you are not the intended recipient you must not copy,
distribute, publish, rely on or otherwise use it without our consent. Some
of our communications may contain confidential information which it could
be a criminal offence for you to disclose or use without authority. If you
have received this email in error please notify [email address]
immediately and delete the email from your computer. Further information
on the classification and handling of FCA information can be found on the
FCA website
(http://www.fca.org.uk/site-info/legal/fc...).

The FCA (or, if this email originates from the Payment Systems Regulator
Limited, the FCA on behalf of the Payment Systems Regulator Limited / the
Payment Systems Regulator Limited) reserves the right to monitor all email
communications for compliance with legal, regulatory and professional
standards.

This email is not intended to nor should it be taken to create any legal
relations or contractual relationships. This email has originated from the
Financial Conduct Authority (FCA), or the Payment Systems Regulator
Limited.

The Financial Conduct Authority (FCA) is registered as a limited company
in England and Wales No. 1920623. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

The Payment Systems Regulator Limited is registered as a limited company
in England and Wales No. 8970864. Registered office: 12 Endeavour Square,
Stratford, London, E20 1JN, United Kingdom

Switchboard 020 7066 1000

Web Site http://www.fca.org.uk (FCA); http://www.psr.org.uk (the Payment
Systems Regulator Limited)

References

Visible links
1. file:///C:/Users/sali3/AppData/Roaming/OTLocal/PRODRM/Workbin/3E7676D.0/[email address]
2. http://www.ico.org.uk/
4. http://www.fca.org.uk/
5. https://twitter.com/TheFCA
6. https://www.linkedin.com/company/financi...