Dear E. Thomas

I write with reference to your Freedom of Information request which was
sent via WhatDoTheyKnow.com.

Section 8(1)(b) of the Freedom of Information Act requires that the
request for information must include the applicant’s real name. To enable
us to respond to your request for information I kindly ask you to confirm
this.

Please be aware that correspondence sent via WhatDoTheyKnow.com is
automatically published on the website. Therefore you can also send this
information directly to us at [1][Avon and Somerset Police request email]
should you wish to do so.

Many thanks for your understanding and cooperation.

Information and Disclosure Manager – Freedom of Information

Legal Services Directorate.  |  Avon and Somerset Police

[2]www.avonandsomerset.police.uk  |  Follow us on [3]Twitter and
[4]Facebook

[5]cid:image001.png@01D496C3.436D9070

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Legal Services Directorate

Force Headquarters, PO Box 37, Valley Road,

Portishead, Bristol, BS20 8QJ

Facsimile 01275 814667

E. Thomas Our 866-22
Reference
[FOI #883112 email] Date 01
September
2022

Dear E. Thomas

I write in connection with your request for information dated 29 July 2022
concerning Stonewall.

I regret to inform you that Avon and Somerset Police have not been able to
complete its response to your request by the date originally stated. 

I now advise you that the amended date for a response is no later than 3
October 2022.  This is due to consideration being given to the application
of a qualified exemption, and as such will require further consideration
regarding the public interest test.  I can assure you that every effort
will be made to ensure an appropriate response will be made within this
new timescale.

May I apologise for any inconvenience caused and thank you for your
request.

Yours sincerely,

Catherine Westwood

Information and Disclosure Officer

Legal Services Directorate

Please note;

1.     Requests and responses may be published on the Avon and Somerset
Police website (within 24 hours), some of which may contain a link to
additional information, which may provide you with further clarification.

2.     Avon and Somerset Police provides you with the right to request a
re-examination of your case under its review procedure.

show quoted sections

                                                                           
Legal Services Directorate

Force Headquarters, PO Box 37, Valley Road,

Portishead, Bristol, BS20 8QJ

Facsimile 01275 814667

  Our 866-22
Reference
  Date
13/6/23

Good Morning E Thomas,

RE Freedom of Information Request 866-22

Due to various resaons the Freedom of Information Team have experienced a
period of high demand, which has unfortunately resulted in a back log of
requests.

Your request for information has been identified as being outstanding for
a considerable amount of time, for which I extend my apologies.

We appreciate the motives for requesting information can vary, and it may
be the case that the information is no longer required by you.

As such please can you confirm if you still wish to receive the
information you have previously sought.

If we do not hear from you within 10 working days we will close your
request.

Yours sincerely,

James Small

Information and Disclosure Manager

Please contact me via email or teams

Legal Services Directorate  |  Avon and Somerset Police

[1]www.avonandsomerset.police.uk  |  Follow us on [2]Twitter and
[3]Facebook

[4]cid:image001.png@01D4B6ED.F158A590

show quoted sections

Legal Services Directorate

Force Headquarters,

PO Box 37, Valley Road,

Portishead,

Bristol,

BS20 8QJ

Email [email address]    

E. Thomas Our Reference 866-22

[1][FOI #883112 email] Date 16 November
2023
 

Dear E. Thomas

I write in connection with your request for information dated 29 July 2022
under the Freedom of Information Act.

Please accept my sincere apologies for the lengthy delay in providing this
response.  This is in part due to turnover of staff who had been working
on the request at different times, however I fully appreciate that a
response should have been with you much sooner. 

Specifically you asked:

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).

Our Response

1

 A. Yes
 B. Yes
 C. Yes

2

Senior Leader Training - £1050 + VAT

Master Class - £200.00 + VAT

No membership fee was paid in 2021

The above information is contrary to what we have previously published in
the public domain, apologies for any confusion caused.  We have
established the above is correct.

3

Our membership of the Stonewall Diversity Champions Scheme ceased in
October 2021.  This will be reviewed going forward and consideration will
also be given to submitting an entry to the Workplace Equality Index for
2023.  However, we have not identified any recorded information confirming
an intention to renew membership. 

4

Please see the attached pdf of the submission from 2021. Due to the size
of this file, it has been split and will be sent over two emails. It
should be noted that this submission contains copies of Avon and Somerset
Police procedural guidance, some of which were draft copies at the time,
and/or have since been reviewed or are due to be reviewed.  For example,
the Transgender, Non-Binary and Gender Reassignment in the Workplace
Procedural Guidance from page 177 has been updated and amended since the
submission.  As such, any such procedural guidance documents contained
within the submission should not be taken to be final or current, approved
versions of that guidance.

Within the document provided, names other than of senior officers, heads
of department or individuals established as being in the public domain
have been redacted.  Also redacted are photos of individuals from internal
intranet pages where these have not been established as being in the
public domain, and certain details that would reveal personal information
about an individual – for example on page 78. Where statistics relating to
gender identity and sexual orientation have been broken down by rank,
redactions have been made in some cases where the low numbers involved
might lead to identification.  The exemption applicable to these
redactions is: 

• Section 40 (2) relating to third party personal information.

This is an absolute exemption so therefore there is no requirement to
conduct a harm or public interest test. Any information is exempt from
disclosure under the Freedom of Information Act if it relates to or is
supplied by another individual and disclosure of that information would
contravene any of the data protection principles set out in:

(a) Article 5(1) of the UK GDPR, and

(b) Section 34(1) of the Data Protection Act 2018.

A Freedom of Information Disclosure is a disclosure to the world.
Therefore information that is provided can be viewed by any member of the
public. Should information be provided from which a living individual
could be identified this would constitute personal data. This would then
become a breach of rights provided under the Data Protection Act 2018. 
Information held on an individual by Avon and Somerset Constabulary is
done so lawfully and is used for a policing purpose in line with the
principles set out in the GDPR. Our privacy policy can be viewed [2]here.

This serves as a partial refusal notice under section 17(1) of the FOI
act.

5

We have not identified any feedback for 2018/19

We are unable to provide you with the Feedback report for 2019/20 or
2021/22 as it is exempt by virtue of:

• Section 41 – information provided in confidence,
• Section 43(2) - commercial interests.

Section 41 is an absolute and class based exemption, consideration should
be given to whether the common law duty of confidentiality can be
overcome.

Section 43(2) is a qualified and prejudice based exemption and as such a
harm or public interest test has been conducted.

Harm in Disclosure

Disclosure would disadvantage the commercial interests to participate in
commercial activity in the future.  

Public Interest Test

Factors favouring disclosure

Disclosure of the requested information may go some way to demonstrate the
decision making process and may contribute to the accuracy of public
debate.

Factors favouring non-disclosure

The Constabulary strives to encourage workplace equality, and this effort
would be disadvantaged if we were no longer able to have consultations and
input from companies such as Stonewall. With regards to the
confidentiality aspect, there is no overwhelming evidence favouring
disclosure.

Balance Test

In considering the arguments for disclosure and non-disclosure, whist the
value of public debate is recognised the ability of the constabulary to
effectively negotiate in the future is in the public’s interests and
outweigh the considerations favouring disclosure.  On balance the decision
is that the required information will not be disclosed on this occasion. 
In accordance with the Act, this represents a refusal Notice for this part
of your request.

Yours sincerely,

James Small

Information and Disclosure Manager - Freedom of Information

[3]www.avonandsomerset.police.uk  | Follow us on [4]Twitter and
[5]Facebook

[6]ASP-Email-Signature-258px-Nov2018

Please note:

 1. Requests and responses may be published on the Avon and Somerset
Police website, some of which may contain a link to additional
information, which may provide you with further clarification.
 2. Avon and Somerset Police provides you with the right to request a
re-examination of your case under its review procedure (copy
attached).

show quoted sections

From: #Freedom of Information Requests
<[Avon and Somerset Police request email]>
Sent: Thursday, November 16, 2023 9:02 AM
To: [FOI #883112 email]
Subject: Freedom of Information Response 866-22 (1 of 2)

Legal Services Directorate

Force Headquarters,

PO Box 37, Valley Road,

Portishead,

Bristol,

BS20 8QJ

Email [email address]    

E. Thomas Our Reference 866-22

[1][FOI #883112 email] Date 16 November
2023
 

Dear E. Thomas

I write in connection with your request for information dated 29 July 2022
under the Freedom of Information Act.

Please accept my sincere apologies for the lengthy delay in providing this
response.  This is in part due to turnover of staff who had been working
on the request at different times, however I fully appreciate that a
response should have been with you much sooner. 

Specifically you asked:

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).

Our Response

1

 A. Yes
 B. Yes
 C. Yes

2

Senior Leader Training - £1050 + VAT

Master Class - £200.00 + VAT

No membership fee was paid in 2021

The above information is contrary to what we have previously published in
the public domain, apologies for any confusion caused.  We have
established the above is correct.

3

Our membership of the Stonewall Diversity Champions Scheme ceased in
October 2021.  This will be reviewed going forward and consideration will
also be given to submitting an entry to the Workplace Equality Index for
2023.  However, we have not identified any recorded information confirming
an intention to renew membership. 

4

Please see the attached pdf of the submission from 2021. Due to the size
of this file, it has been split and will be sent over two emails. It
should be noted that this submission contains copies of Avon and Somerset
Police procedural guidance, some of which were draft copies at the time,
and/or have since been reviewed or are due to be reviewed.  For example,
the Transgender, Non-Binary and Gender Reassignment in the Workplace
Procedural Guidance from page 177 has been updated and amended since the
submission.  As such, any such procedural guidance documents contained
within the submission should not be taken to be final or current, approved
versions of that guidance.

Within the document provided, names other than of senior officers, heads
of department or individuals established as being in the public domain
have been redacted.  Also redacted are photos of individuals from internal
intranet pages where these have not been established as being in the
public domain, and certain details that would reveal personal information
about an individual – for example on page 78. Where statistics relating to
gender identity and sexual orientation have been broken down by rank,
redactions have been made in some cases where the low numbers involved
might lead to identification.  The exemption applicable to these
redactions is: 

• Section 40 (2) relating to third party personal information.

This is an absolute exemption so therefore there is no requirement to
conduct a harm or public interest test. Any information is exempt from
disclosure under the Freedom of Information Act if it relates to or is
supplied by another individual and disclosure of that information would
contravene any of the data protection principles set out in:

(a) Article 5(1) of the UK GDPR, and

(b) Section 34(1) of the Data Protection Act 2018.

A Freedom of Information Disclosure is a disclosure to the world.
Therefore information that is provided can be viewed by any member of the
public. Should information be provided from which a living individual
could be identified this would constitute personal data. This would then
become a breach of rights provided under the Data Protection Act 2018. 
Information held on an individual by Avon and Somerset Constabulary is
done so lawfully and is used for a policing purpose in line with the
principles set out in the GDPR. Our privacy policy can be viewed [2]here.

This serves as a partial refusal notice under section 17(1) of the FOI
act.

5

We have not identified any feedback for 2018/19

We are unable to provide you with the Feedback report for 2019/20 or
2021/22 as it is exempt by virtue of:

• Section 41 – information provided in confidence,
• Section 43(2) - commercial interests.

Section 41 is an absolute and class based exemption, consideration should
be given to whether the common law duty of confidentiality can be
overcome.

Section 43(2) is a qualified and prejudice based exemption and as such a
harm or public interest test has been conducted.

Harm in Disclosure

Disclosure would disadvantage the commercial interests to participate in
commercial activity in the future.  

Public Interest Test

Factors favouring disclosure

Disclosure of the requested information may go some way to demonstrate the
decision making process and may contribute to the accuracy of public
debate.

Factors favouring non-disclosure

The Constabulary strives to encourage workplace equality, and this effort
would be disadvantaged if we were no longer able to have consultations and
input from companies such as Stonewall. With regards to the
confidentiality aspect, there is no overwhelming evidence favouring
disclosure.

Balance Test

In considering the arguments for disclosure and non-disclosure, whist the
value of public debate is recognised the ability of the constabulary to
effectively negotiate in the future is in the public’s interests and
outweigh the considerations favouring disclosure.  On balance the decision
is that the required information will not be disclosed on this occasion. 
In accordance with the Act, this represents a refusal Notice for this part
of your request.

Yours sincerely,

James Small

Information and Disclosure Manager - Freedom of Information

[3]www.avonandsomerset.police.uk  | Follow us on [4]Twitter and
[5]Facebook

[6]ASP-Email-Signature-258px-Nov2018

Please note:

 1. Requests and responses may be published on the Avon and Somerset
Police website, some of which may contain a link to additional
information, which may provide you with further clarification.
 2. Avon and Somerset Police provides you with the right to request a
re-examination of your case under its review procedure (copy
attached).

show quoted sections