The consultation is quite open-ended, seeking views on experiences with the information law regime. The consultation does not put forward precise changes to current legislation, which meant it was not possible to fully comment on the exact scope of any changes (should these ever be proposed). Most importantly, the consultation is clear that any actual legislative changes would require further public consultation.
Within our response SFHA highlights the importance of retaining the need for Scottish Government to conduct a full and robust consultation should it ever be proposed that FOI be further extended to other authorities or functions. SFHA supported retaining the current scope of FOI within our sector, highlighting that access to information has not been hampered by any necessary outsourcing of services.
In additon, the response supports the principle of changing the way in which costs are calculated (when determining if an FOI request would represent "excessive costs") to take staff hours into consideration. SFHA also comments on the Model Publication Scheme; possible amendments to the definition of "vexatious"; and the use of confidentiality clauses.
The full response can be viewed in the downloads section to the right of this article (please note that you will have to login to access).
If you have any queries regarding the response please contact Alan Stokes, Policy Lead astokes@sfha.co.uk