Introduction and purpose

This information is intended to set out what, how and when information will be made available to the public in relation to our current Strategic Change Programme, known as Zenith, in anticipation of a significant number of requests for information under the Freedom of Information Act (FOIA). The strategy aims to provide a transparent approach to FOI, detailing what information exists and what can and cannot be released. Producing such a strategy will assist the force and the public in ensuring timely and transparent responses to all requests.
The Zenith Programme encompasses a strategic re-focus of the estate strategy following the COVID-19 pandemic. It introduces the concept of ‘smarter working’ and seeks to deliver a more efficient use of our estate. The overall outcome sought will be to enhance the effectiveness of the policing service in Kent by enabling an environment that facilitates more efficient working, recognising that the working environment can effectively extend beyond the traditional bricks and mortar offices.
We are committed to transparency and our obligations in terms of public expenditure. Equally, the Programme will have a very real impact on the structures of the organisation, which will need to be handled fairly, sensitively and directly with any staff affected, thus maintaining an absolute commitment to statutory employee consultation with the appropriate levels of confidentiality. It is also fully anticipated that negotiating positions will need to be developed and commercial discussions undertaken, with all contributors feeling comfortable engaging in the free and frank provision of advice and sharing of views. There are also several commercial considerations around engaging suppliers and other third parties where publication of detail may compromise the pursuit of value for money and stewardship of public finances.
Given the Programme is wide ranging and estimated to take at least two to three years to fully complete, the public interest would be best served if all costs and benefits were accurately presented in the wider context given the natural interdependencies that will inform the relevant decision-making as the Programme progresses. Providing isolated costs and benefits, many of which will only be estimated or anticipated until realised upon maturity of the Programme, risks distorting interpretation, adding administrative burden and risks presenting a wholly inaccurate positive or negative picture. This document therefore seeks to timetable what information will be made available, how and when.

Strategic intention

Estate rationalisation and significant efficiency savings are reasonable and legitimate aims, and our strategic intent is in the public domain and a matter of public record. Our intention, however, is to provide a comprehensive breakdown of the costs and benefits of the Zenith Programme upon completion, for scrutiny and review by the Kent Police and Crime Commissioner, HMICFRS and the wider public. Individual FOI requests will be reviewed at point of receipt in order to consider if there is a clear public interest in responding early. Alternatively, where appropriate, the applicant will be signposted to the relevant intended publication date and no further information will be provided at that stage, unless there is a clear public interest in doing so.

The public interest test

The force recognises that events may change, and the balance of ‘the public interest test’ may well favour earlier disclosure at some point in the future. There may also be other exemptions that apply to the information in question, depending on:

(a) the content of any request, and
(b) the time at which it is submitted.
The below sets out our present view in relation to the public interest, both for and against disclosure.

Public interest factors favouring disclosure

Public interest factors against disclosure

We are publicly funded. The force has a duty to be accountable regarding how those public funds are used.


Disclosures of information under the FOIA must be specific to what has been requested by an applicant. There is no requirement under the Act to provide context, comment or opinion and there is no requirement to consider the rapidly changing nature of disclosed information. In the context of the Zenith Programme, ad hoc and premature disclosures of information via an FOIA application could be taken out of context. This may result in damage to public confidence, which could hinder our work and undermine public confidence.

Disclosures would promote openness and transparency.


Whilst we will ensure our officers and staff are consulted and kept informed of decisions that are being made in relation to the police estate and job roles, we have a duty to ensure the well-being of our officers and staff. The premature disclosure of certain information into the public domain, for example that relating to workplaces and staffing prior to staff being fully consulted, would have a negative impact on staff morale and well-being.

The publication of information will be prepared at some expense to the force (in terms of time); spending additional public funds (in terms of responding to individual FOI requests) would be wasteful.

Information can change over time, particularly where updates are frequent. Zenith is an ongoing strategic programme where costs, staffing and other key information are likely to evolve as decisions are made. Repeated requests for information under the FOIA will undermine our strategy, which is designed to ensure the public are informed with complete and accurate data.

Information in relation to commercial interests and legal privilege

Section 43(2) of the Freedom of Information Act (where disclosure would, or would be likely to, prejudice the commercial interests of any person, including the public authority holding the information) and/or s.42(1) (information which is subject to legal professional privilege) may need to be considered in certain circumstances. In such instances, requested information will be assessed on its merits and the prevailing circumstances at the time; the outcome being the information may not be released under the above exemptions.
The changing nature of financial planning, procurement and commercial activities could be compromised by piecemeal disclosure that fails to address the whole vision. As a result, this could undermine public confidence where the lack of context creates an inaccurate picture. All procurement will be compliant, irrespective of any decision to disclose or not, however early scrutiny of decisions yet to be made could have an adverse effect on companies wishing to bid, and on decision-makers awarding bids. Such an effect may well impact on the force’s ability to achieve the best outcomes in terms of value for money and open and frank exchanges with suppliers. Alternatively, publishing details of providers or commercial interests would demonstrate our commitment to openness and transparency and encourage public scrutiny of those relationships. 
It should be noted that any information exempt by virtue of the above is unlikely to be subject to the exemption at s.22(1). This means it is unlikely the data will be published in the future, unless any necessary public interest factors for consideration change.
Each request will be assessed on its own merits, however, the above is provided to give members of the public an idea of what information is and is not likely to be shared publicly upon completion of the Programme.
The below publication schedule will inform decision-making, where appropriate, to apply the exemption relating to information intended for future publication (section 22 FOIA).
Item Rationale Release date

Business case and rationale for change

Settled and agreed approach

Winter 2020

Programme structure, resources and governance

Settled and agreed approach

Winter 2020

Breakdown of capital receipts under programme

It is anticipated that several buildings will be sold. The headquarters site will not be cleared until at least summer 2022. It is therefore highly unlikely that all capital receipts will be realised until at least 12 to 18 months thereafter

Summer 2024

Capital expenditure directly related to the Programme

Until the headquarters site has been sold the total costs will not be known

Summer 2024

Specific details of any associated costs in relation to external consultancy/specialist advice

Until the headquarters site has been sold the total costs will not be known

Summer 2024

Details of any revenue savings realised by the Programme

Will not be available until all the HR changes have been implemented

Summer 2024

Details of any new revenue costs created by the Programme

Will not be available until all the HR changes have been implemented

Summer 2024

Staff profile information:

  • number of business cases undertaken
  • number of redundancies as a result of organisational change under the Zenith Programme
  • number of officers and staff formally designated as 'home-based workers'.
  • Additional financial benefits, if any, provided to both officers and staff under the Programme

Many officers and staff will be relocated from the Sutton Road site, plus a number of other teams and departments will be relocated in order to maximise estate utilisation. That work, including appropriate consultation, will not be completed until the date shown

Summer 2023

Overview of force performance during the lifetime of the Programme (June 2020 to Summer 2023 currently)


Will only be known once time period is concluded

Winter 2023

Post implementation review of Zenith Programme

Will be conducted upon conclusion of the Programme

Winter 2024

Delivery Mechanism

This Publication Strategy and the relevant information, as scheduled, has been published on the force website to allow wider public access and scrutiny.
This strategy will be reviewed and amended if necessary, every six months or earlier, in order to consider if the wider public interest has moved in favour of earlier disclosure. This will also provide the opportunity to provide greater certainty around publication dates as the Programme develops the relevant level of detail.


The Zenith Programme Senior Sponsor is Deputy Chief Officer Drysdale, who will provide strategic direction and oversight. This document will be reviewed and approved by Chief Officers and then revised and amended in favour of earlier disclosure, where possible, as set out above.
Jon Sutton
Programme Director
November 2020