An interesting post from the ever-good FOI Man today looking at the mountain of guidance communications staff in the NHS get hit with, including those dealing with FOIs.
It would appears FOI officers are expected to second-guess when an FOI request may be a ’round robin’ in the sense that it has been submitted to more than one body.
To quote the NHS Information Toolkit:
“Staff that manage FOI requests should be alert to the possibility that a request may have been sent to a number of organisations – ’round robin requests’ – and there should be a documented procedure for alerting Strategic Health Authority (SHA) FOI leads so that they can provide coordination and support. SHA FOI Leads should in turn alert the Department of Health.”
As FOI Man points out, how to spot a round robin email is anyone’s guess – but it certainly appears to conflict with the notion of all FOI requests being treated equally. The motives of an FOI requester shouldn’t be a consideration so why should the fact that the FOI may have gone to other authorities as well?
If, for example, an FOI officer saw the email address was that of, say the BBC, and then concluded it could be a round-robin email, that certainly wouldn’t be ‘applicant blind’.
Perhaps most worrying is the sheer scale of the chain of command ready to come in and ‘co-ordinate’ FOI responses – starting with having to inform the Strategic Health Authority. This is particularly odd in the North West of England, where NHS North West, the strategic health authority for the region, is currently being monitored by the Information Commissioner because it struggles to answer its own FOIs on time, so quite where it finds the time to meddle in other ones remains to be seen.
I’m sure there’s a carefully-constructed argument around sharing best practice and ensuring the information released by multiple locations is in similar formats to benefit the requester, but I can’t help but think this is more about managing the information being released – especially where a journalist might be concerned.
Call me a suspicious journalist if you like, but there are ways to reduce the possibility of an email being marked up as a ’round robin.’
The first would be to make sure you send one email at a time – don’t put multiple addresses in the ‘to’ box.
Secondly, tweak the body of each FOI request so that it is local to the authority you are writing to.
And third, much as I like Whatdotheyknow, if FOI officers in the health service are expected to seek out ’round robin’ emails then there may be occasions where you feel you can’t use Whatdotheyknow. Sad, I know.
But at least we have proof of something the SHA actually does.
David Higgerson 
David,
Interesting that NHS North West which, as you highlight, was on the ICO’s Oct 2010 monitoring list for delays, seems to have had a Level 2 rating approved for FOI compliance in the IG Toolkit last year. The required attainment levels for Level 2 state:
“Level 2
The SHA has publicly available, documented procedures for FOI Act compliance with clear responsibility for responding to information requests by effectively informed and resourced staff. The SHA ensures all staff are effectively informed of the need to support requests for information and are aware of where in the SHA such requests should be directed. The procedures are implemented effectively to meet the statutory deadlines.”
So, as FOIMan said, what’s the point of it? Surely it would be less burdensome for NHS trusts to simply publish FOI statistics on their websites so the public can see whether they’re complying with the Act’s time limits.
Perhaps it would be worth finding out more about this by asking NHS North West what they do when an FOI officer refers a suspected round-robin request to them?