Information regarding conflict of interest
Dear Equality and Human Rights Commission,
Please provide the following information, for the time period Jan 2020 - August 2021, in relation to any discussions & decisions on potential conflict of interests within the EHRC
1) Details of the conflict of interest
2) The name & position of the person with the conflict of interest
3) The date the conflict of interest was raised with the EHRC
4) What activity the Conflict of Interest impacted
5) The name & position of the person who made the decision as to applicability of the conflict of interest, and whether the person named in 2) was allowed to continue with activity in 4)
6) The date the decision from 5) was made
7) Any and all documentation / communications detailing the above.
Yours faithfully,
C Prosho
Information request
Our reference: 3785676
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Dear C Prosho
Your Freedom of Information Request
Thank you for your request, detailed below, which we received on 2
September 2021.
"Please provide the following information, for the time period Jan 2020 -
August 2021, in relation to any discussions & decisions on potential
conflict of interests within the EHRC
1) Details of the conflict of interest
2) The name & position of the person with the conflict of interest
3) The date the conflict of interest was raised with the EHRC
4) What activity the Conflict of Interest impacted
5) The name & position of the person who made the decision as to
applicability of the conflict of interest, and whether the person named in
2) was allowed to continue with activity in 4)
6) The date the decision from 5) was made
7) Any and all documentation / communications detailing the above."
We are dealing with your request under the Freedom of Information Act
2000. We aim to respond promptly and in any event no later than 20 working
days following the date of receipt of the request; a response should
therefore be with you no later than 30 September 2021. However please be
advised that this may not be possible, owing to the disruption caused
during this pandemic period. If for any reason we are not able to meet
this deadline, we will notify you and give you an indication of when we
will send you a full response.
If you have any queries please contact us using the details below.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. http://www.equalityhumanrights.com/
Information request
Our reference: 3785676
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Dear C Prosho
Your Freedom of Information Request
Thank you for your Freedom of Information request dated 2 September 2021
in which you made the following request:
"Please provide the following information, for the time period Jan 2020 -
August 2021, in relation to any discussions & decisions on potential
conflict of interests within the EHRC
1) Details of the conflict of interest
2) The name & position of the person with the conflict of interest
3) The date the conflict of interest was raised with the EHRC
4) What activity the Conflict of Interest impacted
5) The name & position of the person who made the decision as to
applicability of the conflict of interest, and whether the person named in
2) was allowed to continue with activity in 4)
6) The date the decision from 5) was made
7) Any and all documentation / communications detailing the above."
Response
We have considered your requests and determined that the cost of complying
would exceed the appropriate limit set out in the Freedom of Information
and Data Protection (Appropriate Limit and Fees) Regulations 2004.
Section 12 (1) of the Freedom of Information Act states:
'Section 1(1) does not oblige a public authority to comply with a request
for information if the authority estimates that the cost of complying with
the request would exceed the appropriate limit.'
As noted above, the appropriate limit is currently set out in the Freedom
of Information and Data Protection (Appropriate Limit and Fees)
Regulations 2004 ('the Regulations'). The Regulations set a limit of £450
for public authorities such as the Commission.
Regulation 4(3) of the Fees Regulations states that a public authority can
only take into account the costs it reasonably expects to incur in
carrying out the following permitted activities in complying with the
request:
* determining whether the information is held;
* locating the information, or a document containing it;
* retrieving the information, or a document containing it; and
* extracting the information from a document containing it.
When determining the cost of compliance all public authorities should
calculate the time spent on the permitted activities at the flat rate of
£25 per person, per hour.
ICO guidance also advises that a public authority is not obliged to search
for, or compile some of the requested information before refusing a
request that it estimates will exceed the appropriate limit. Instead, it
can rely on having cogent arguments and / or evidence in support of the
reasonableness of its estimate.
Following consideration of your request we have determined that the
Commission will hold information relevant to your request, but the cost of
complying with your request would exceed the £450 / 18 hour limit.
We have determined that it will take well in excess of 18 hours to locate,
retrieve and extract the requested information. This is due to the
extensive nature of the searches required.
Section 12 search strategy
We have outlined below, how we have calculated this estimate:
To capture all relevant communications we asked our ICT team to conduct a
backend search to identify any communications between 1 January 2020 - 31
August 2021 which contained the terms 'Conflict of Interest' OR 'COI' OR
'Conflicts' OR OR 'Conflicted'. This searched yielded 21,000 results.
Each of these results would need to be looked at to determine the
relevance to your request. At an estimate of 1 minute per item this would
take 350 hours and would therefore far exceed the appropriate limit of 18
hours.
Advice and Assistance
You may wish to amend / refine your request to bring it within the
appropriate limit. To assist you with this we have provided comments
below:
1. We hold a register of Commissioner Interests which is readily
available.
2. 'Declarations of interest' are recorded in the Board Minutes and could
be easily extracted.
3. We hold staff year-end Declaration of Interest forms for March 2021
and forms for new starters after this date.
4. We will hold Conflict of Interest forms completed at the outset of
Commission investigations during this period.
Please note that, even if a new request were to fall below the £450 limit,
the information that you request might be withheld under the terms of a
number of substantive exemptions contained in Part II of the Freedom of
Information Act 2000. For example, it is likely that the information
identified in 3 and 4 above would engage the Section 40(2) Personal
information exemption. We should also note that some exemptions can make
it necessary for us to extend the period for responding beyond the 20
working days target if they involve having to consider the public interest
balancing test.
We hope that the above information will prove helpful to you should you
choose to refine your request.
Internal Review
If you are unhappy with our response and wish to request an internal
review please write to the Information Governance Team at:
Email: [EHRC request email]
During the independent review the handling of your request will be
reassessed by Commission staff afresh.
If following the review you are not content with the outcome you may apply
directly to the Information Commissioner's Office (ICO) at:
The Information Commissioner's Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF
Generally the ICO will not provide a decision until you have exhausted the
review process within the Equality and Human Rights Commission.
If the Commission can be of any further assistance please contact us using
the details provided below.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. http://www.equalityhumanrights.com/
Dear Information Governance team,
I already have any CoI information that has been publicly provided, so please refine my request as follows:
The details specified as above, but in relation to any CoIs for the following EHRC bard members:
David Goodhart
Kishwar Falkner
Alasdair Henderson
Yours sincerely,
C Prosho
Information request
Our reference: 4101209
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Dear C Prosho
Your Freedom of Information Request
Thank you for your refined request which we received on 29 September 2021.
We understand your request to be as follows:
Please provide the following information, for the time period Jan 2020 -
August 2021, in relation to any discussions & decisions on potential
conflict of interests for the following board members:
David Goodhart
Kishwar Falkner
Alasdair Henderson
1) Details of the conflict of interest
2) The name & position of the person with the conflict of interest
3) The date the conflict of interest was raised with the EHRC
4) What activity the Conflict of Interest impacted
5) The name & position of the person who made the decision as to
applicability of the conflict of interest, and whether the person named in
2) was allowed to continue with activity in 4)
6) The date the decision from 5) was made
7) Any and all documentation / communications detailing the above.
We are dealing with your request under the Freedom of Information Act
2000. We aim to respond promptly and in any event no later than 20 working
days following the date of receipt of the request; a response should
therefore be with you no later than 27 October 2021. However please be
advised that this may not be possible, owing to the disruption caused
during this pandemic period. If for any reason we are not able to meet
this deadline, we will notify you and give you an indication of when we
will send you a full response.
If you have any queries please contact us using the details below.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. http://www.equalityhumanrights.com/
Information request
Our reference: 4101209
--------------------------------------------------------------------------
Dear C Prosho
Please find attached our response to your recent Freedom of Information
request.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
References
Visible links
1. http://www.equalityhumanrights.com/
Dear Information Governance team,
Thanks for your response.
Given the difficulties youre having at this time, please further narrow my request as follows to the following (same info required as originally):
1) Alasdair Henderson
2) Timeframe : August 2020 - June 2021
Yours sincerely,
C Prosho
Information request
Our reference: 4368509
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Dear C Prosho
Your Freedom of Information Request
Thank you for your further refined request, detailed below, which we
received on 20 October 2021.
"Please provide the following information, for the time period August
2020 - June 2021, in relation to any discussions & decisions on potential
conflict of interests for Alasdair Henderson
1) Details of the conflict of interest
2) The name & position of the person with the conflict of interest
3) The date the conflict of interest was raised with the EHRC
4) What activity the Conflict of Interest impacted
5) The name & position of the person who made the decision as to
applicability of the conflict of interest, and whether the person named in
2) was allowed to continue with activity in 4)
6) The date the decision from 5) was made
7) Any and all documentation / communications detailing the above."
We are dealing with your request under the Freedom of Information Act
2000. We aim to respond promptly and in any event no later than 20 working
days following the date of receipt of the request; a response should
therefore be with you no later than 17 November 2021. However please be
advised that this may not be possible, owing to the disruption caused
during this pandemic period. If for any reason we are not able to meet
this deadline, we will notify you and give you an indication of when we
will send you a full response.
If you have any queries please contact us using the details below.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. http://www.equalityhumanrights.com/
Information request
Our reference: 4368509
--------------------------------------------------------------------------
Dear C Prosho
Thank you for your request for information received on 20 October 2021.
Please find attached our response to your request.
Yours sincerely
Information Governance team
Equality and Human Rights Commission
[EHRC request email]
Arndale House, The Arndale Centre
Manchester, M4 3AQ
[1]www.equalityhumanrights.com
[2]EHRC GB logo
NOTE: Please do not edit the subject line when replying to this email.
References
Visible links
1. http://www.equalityhumanrights.com/
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