22nd Old Boys
The Club recognises the importance of the Freedom of Information Act 2000 and to assist organisational compliance with the Act the football club will endeavour to ensure that:
· The majority of information is made available through the club’s official website
· Other information is readily available on request
· If the information requested is subject to an exemption, the club will implement the public interest test to determine whether the information can be released
This policy is intended to cover all records created in the course of the business of the club, i.e., minutes of committee meetings which are also public records under the terms of the Public Records Acts 1958 and 1967. This includes email messages and other electronic records.
The policy outlines good practice and identifies the responsibilities of club staff in terms of Freedom of Information and should be read alongside the club’s codes of conduct.
3. Responsibilities for Freedom of Information
Ultimate responsibility for Freedom of Information rests with the chairman of the football club but all committee members who record information, whether on paper or by electronic means, also have responsibilities under the Act and under this policy.
3.1 The Freedom of Information Lead
It is this person’s responsibility to:
· Ensure organisational compliance with the FOI Act
· Maintain the currency of this policy and the Publication Scheme
· Promote FOI awareness throughout the organisation
· Ensure the general public has access to information about their rights under the FOI Act
· Assist with investigations into complaints and appeals
· Liase and work with other club members responsible for information handling activities, e.g. Club welfare Officer, Secretary and Treasurer
4. Specific requests
The Freedom of Information Act confers two general rights on the public, a right:
· To be informed whether a public body holds certain information, and
· To obtain a copy of that information
A request for information not included within the Publication Scheme must be made in writing, this includes via email, and a charge may be made for supply of the information.
Where possible the information will be supplied in the format requested by the applicant. However, requests can be met by providing a copy of the original document, as a summary of the original or even by allowing the applicant to visit the club to read the document(s).
Requests for information will be met within 20 working days of receipt of the request or fee.
Ordinarily the Trust will charge no fee for documents contained within its Publication. However, fees will be charged for information outside the Scheme in accordance with the Fees Regulations published by the Department for Constitutional Affairs
The rights within the Freedom of Information Act may be limited by the applicability of the exemptions. Several sections of the Act confer an absolute exemption on information (see section 2(3)). This has the effect of exempting the Trust from confirming or denying that the information exists, or from disclosing the information at all.
Other sections direct the football club to weigh up whether the public interest in maintaining the bar on confirmation/denial or in maintaining the exemption is greater than the public interest in disclosing whether the public authority holds the information, or in disclosing the information at all.
All original requests for exempted information will be passed to the committee to reconsider whether the information can be supplied.
If the Trust receives a vexatious request or repeated request it is not obliged to comply with the request.
Decisions on whether a request is vexatious will be taken by the committee with the assistance of legal advice where necessary.
Repeated requests from the same person for information that has already been supplied to them will not be met unless there has been a “reasonable interval” between the requests. Reasonableness will be determined by the committee.