Kent Police has an established process for all information requests. A Single Point of Contact (SPoC) is a necessity. To manage potential risks to current and future commercial sensitivities, it is recommended that there is a SPoC from the Project Team, the Office of the Police and Crime Commissioner (OPCC), and the Public Disclosure Team (PDT).
- Each North Kent Programme related Freedom of Information (FOI) will be logged in the usual way and checked against the publication strategy.
- Those that fall within the publication strategy will be noted. The FOI SPoC will provide a daily/twice weekly/weekly (to be arranged) update to the North Kent Programme, and Media SPoCs outlining:
a. FOI reference number
b. Date received and due date
c. Whether the applicant is considered to be media
d. Questions that fall within the publication strategy, if any
e. Questions outside of the publication strategy
f. Other parties that may need to be consulted
- The North Kent Programme SPoC will confirm if the information is held.
- Liaison with SPoCs will agree who the questions outside the publication strategy will be tasked to.
- Where a request contains both types of questions, a response will only be issued once those questions outside have also been answered.
- Where a request only contains questions inside, an immediate response will be issued confirming the data is held, but is exempt. If there is an identified risk of confirming the data is held, a Neither Confirm, Nor Deny (NCND) response will be issued. The FOI SPoC will be able to advise.
- Section 22 is a qualified exemption, and the public interest must be considered in each case. There could be instances when it is reasonable to withhold the information under Section 22, but the public interest in disclosure outweighs the public interest in withholding it. This is more likely to be true when no date for publication has been set. As such the publication strategy must be kept under review.
- Incoming requests must inform the continued development of the publication strategy. Where themes are spotted, the strategy should be updated to reflect those themes. It must be remembered that S.22 is not retrospective. Where changes are implemented, they will only apply to future FOIs.
- Once the material is provided for an outside request, the completed response will be provided to the Deputy Chief Officer (DCO) for final sign off.