Freedom of Information (FOI): Lessons learned and improvement plan

In line with our Learning Organisation Framework, this lessons learned review has been undertaken to identify the key factors that have contributed to the council’s recent FOI compliance challenges and to set out the improvements being made in response. 

While increased demand and reduced capacity have contributed to the current position, the review has also identified opportunities to strengthen end-to-end processes, management oversight, reporting arrangements and the use of technology. The actions are intended to support a more consistent, resilient and transparent FOI function that improves statutory compliance, reduces backlog risk and supports better outcomes for residents. 

Delivery of this action plan will be overseen by the Head of Innovation, as the senior officer accountable for implementation. 

Strategic improvement objective 

“To establish a consistent, visible and sustainable Information Rights operating model that enables statutory compliance, prevents future backlog accumulation, provides clear accountability across services, and is supported by robust reporting, governance and technology.” 

This reflects our commitment to being a learning organisation: using evidence, feedback and challenge to improve practice, strengthen accountability and reduce the risk of recurrence.

What we learned 

• FOI demand has increased significantly, rising by 41% compared with previous years, while available staffing capacity has reduced over the last 18 months, with the team operating one post below its planned establishment of three. There are further capacity challenges across the organisation. 
• We are seeing changes in public expectations around transparency, access to information and responsiveness. We are also beginning to see the impacts of emerging technologies, including artificial intelligence, which make it easier for individuals to generate, analyse and pursue information requests at scale.  
• However, the lessons learned exercise identified that capacity alone does not explain the entirety of performance decline. Similar pressures would have been more manageable with stronger processes and oversight.  

Action 

• Complete temporary recruitment and agency support arrangements (October 2026) 
• Monitor demand, capacity and case volumes monthly through senior performance oversight and swifter intervention (ongoing) 

What we learned 

• Although broad arrangements were in place, the lack of a single, consistently applied end-to-end process meant that different officers worked in different ways, leading to inefficiency, duplication and inconsistent use of resources. These issues were less visible while the team was operating at full establishment. 
• The team did not have a consistent, shared approach to prioritising work across new requests, overdue cases and ready-to-issue responses. This meant effort was not always aligned to the areas of greatest regulatory risk. While our internal focus was largely on maintaining headline compliance, the ICO placed equal importance on the size, age and management of the backlog. 

Action 

• Implement a documented end-to-end FOI process. This includes: 
  • strengthen guidance for officers on providing timely advice and assistance to requesters (December 2026) 
  • confirming standard arrangements for receipt, logging and validation of new FOI requests to ensure cases are allocated promptly and consistently from the outset (December 2026) 
• Agree standard workflows that make full use of the case management system (December 2026) 
• Agree escalation points and ownership (December 2026) 
• Develop a clear guidance on exemptions for FOI coordinators (March 2026) 
• Explore appropriate use of AI and automation to enable effective case management, subject to information governance controls (March 2026) 
• Introduce clear prioritisation rules covering (October 2026) 
  • New requests 
  • Stop-clock cases 
  • Ready-to-issue cases 
  • Overdue cases 
  • Responding to service queries  
• Introduce a clear quality assurance and sign-off process for draft FOI responses, including expected turnaround times for review, clearance and issue (December 2026) 

What we learned 

• Although regular chase-up emails were issued and directors and senior managers were copied into escalation correspondence and had access to retrospective performance reports prepared for the Information Governance Board, reporting was not consistently presented in a clear, accessible format. This limited senior leaders’ ability to identify emerging risks, understand where intervention was needed, and support timely resolution at an earlier stage. 

Action 

• Develop director-level regular, accessible reporting showing the info below (interim solution October 2026, improved use of technology January 2027) 
  • Open cases 
  • Cases at risk 
  • Overdue cases 
  • Service-level performance 
• Introduce Red/Amber/Green reporting (December 2026) 
• Consistently copy relevant directors into escalation emails (ongoing) 
• Provide regular progress updates to senior management and the Information Governance Board on delivery of this action plan (ongoing) 
• Use AI to undertake a quarterly learning review of internal reviews, ICO complaints, upheld cases and recurring service issues, with process updates and targeted service feedback where themes emerge (January 2027) 

What we learned 

• The team understandably focused on requests still within statutory timescales because this protected compliance figures. 
• As a result, older overdue cases accumulated over time.  
• The ICO's primary concern became backlog volume and age rather than headline compliance percentage alone.  

Action 

• Create separate performance measures for below (December 2026) 
  • New request compliance 
  • Overdue backlog reduction 
  • Age profile of open cases 
• Protect dedicated capacity for backlog recovery activity, with regular monitoring of progress against the age and volume of overdue cases (Ongoing) 

What we learned 

• FOI compliance depends not only on the Information Rights team, but also on timely and complete responses from services across the council. 
• Where service input is delayed, incomplete or requires repeated clarification, this can significantly affect the council’s ability to issue responses within statutory deadlines. 
• Clear expectations, escalation routes and senior oversight are needed so that FOI responsibilities are understood as a corporate requirement, not solely an Information Rights function. 

Action 

• Provide regular training and ad-hoc support to services as needed. Based on the insight emerging from these engagement sessions, make the necessary process and other improvements (ongoing) 
• Set clear response times for services to provide information and sign-off (ongoing) 
• Introduce earlier escalation where service responses are delayed or incomplete (November 2026) 
• Reinforce expectations with senior managers that FOI compliance is a shared corporate responsibility (ongoing) 
• Include service response performance in director-level reporting (ongoing) 
• Continue to maintain an up to date record of FOI leads within each directorate/service area and provide targeted refresher training on statutory timescales, search expectations, exemptions, sign-off requirements and escalation routes (ongoing) 

• Be Connected - FOI compliance depends on joined-up ownership across services, not just the Information Rights team. Clear service expectations, escalation routes and senior oversight are needed so the whole council responds as one system. 
• Be Confident - Colleagues need clear processes, prioritisation rules, guidance and quality assurance so they can make timely, consistent decisions and manage cases with greater confidence. 
• Be healthy and psychologically safe - Capacity pressures, sickness absence and sustained demand exposed the need for more resilient ways of working, earlier escalation and a culture where risks are managed in a more timely way. 
• Be innovative and creative - Better use of case management data, reporting, AI and automation can support earlier intervention, reduce manual effort and help identify recurring learning themes. 
• Be diverse and inclusive - FOI is part of accessible, transparent public service. Strengthening consistency, timeliness and service engagement helps ensure all requesters receive fair, reliable and equitable access to information. 

This improvement plan is subject to ongoing engagement and review with a view to strengthening it. Progress against it will be monitored through regular senior management oversight and reported to the Information Governance Board. The action plan will be reviewed regularly to ensure improvements are sustained, risks are identified early, and further corrective action is taken where performance risks emerge. 

This will support sustained focus on FOI compliance, backlog reduction and timely responses to new requests. In keeping with the Learning Organisation Framework, progress will be reviewed not only against completion of actions, but also against whether the changes are improving practice, strengthening organisational learning and preventing similar issues from recurring. 

Backlog clearance milestones: 

1. End of October 2026 - 75%  
2. End of November 2026 - 90% 
3. End of December 2026 - 100% 
4. Significantly overdue cases - clear by end of November 2026