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Training your staff about FOI

ICO comment: what this case study means 

Providing FOI training for your staff ensures that your organisation has high levels of FOI awareness and knowledge. This not only improves the performance of your core FOI staff but also helps other staff to provide them with timely and effective support and assistance. 

This study draws together five authorities nominated at the eCase FOI24 awards, and highlights how they do things well in the training space. 

Skills-based recruitment and on-the-job training (Hampshire County Council) 

Organisations can struggle to find staff with pre-existing knowledge of FOI legislation. To combat this, Hampshire County Council adopts a skills-based approach to recruitment. It looks for enquiring minds, good communicators and people capable of applying a set of principles within a legal context rather than concentrating on education and prior experience. 

New staff learn on the job from a mentor, shadowing one of the team and gradually taking over simpler cases. As their confidence builds, they handle more complex cases, asking for guidance as needed. Team members discuss cases with each other and share experiences. They build in time to discuss the principles behind the application of individual exemptions, using ICO guidance. Staff build up a knowledge base that they can apply to different requests. 

In-house legal colleagues help by delivering face-to-face training to the team, including presenting case studies of previous requests and applying particular exemptions. 

The council’s approach has raised competence and confidence. The team produce better quality initial responses and internal review outcomes. 

Broad content (The National Audit Office) 

The National Audit Office design their FOI training to raise awareness and improve understanding of the legislation across the whole organisation. This ensures staff respond to requests appropriately. The focus is on the customer and delivering excellence. 

Through workshops and other sessions, training includes: 

  • the structure and core provisions of FOIA;
  • the organisation’s role, impact and the importance of transparency;
  • handling requests;  
  • the exemptions and refusal notices;
  • internal reviews and ICO complaints; and  
  • case studies exercises including considering requests. 

Mandatory e-learning (The Office of Rail and Road) 

This authority devised an e-learning FOI module in October 2022. It is mandatory for all staff, not just the FOI team. It’s included in the onboarding and welcome pack for all new joiners.  

The module takes about 35 minutes and is split into three parts: 

  • What is the Freedom of Information Act? 
  • Do we have to release all the information requested?
  • What happens if the applicant disagrees with our response? 

It includes multiple choice questions and a summary of learnings in each part.  

The module has addressed knowledge gaps around the organisation’s FOI responsibilities and understanding of exemptions. It’s helped staff to understand the importance of FOI and has improved communication between the FOI team and the rest of the organisation. 

Flexible training (National Police Freedom of Information and Data Protection Unit) 

The National Police Freedom of Information and Data Protection Unit provides training, support and guidance to all FOI teams within the police sector. The unit offers sector-focused FOI training at both fundamental and intermediate level, which it can deliver online or in-person. 

The fundamental training is completed in modules and is therefore flexible. It can be delivered in full as a one-day course, or adapted to the needs of the audience. It includes: 

  • the principles of FOI;
  • recognising and handling requests;  
  • searching for information;
  • appropriate cost limit;
  • common exemptions;
  • identifying harm;
  • the public interest test; and
  • advice and assistance. 

The intermediate training covers further exemptions, as well as providing detail on when a request could be vexatious. The training considers ICO decision notices and tribunal decisions. Staff can deliver it in full as a two-day course. 

Continually promoting awareness (HM Land Registry) 

The disclosure team at HM Land Registry produced a new FOI policy in 2023. They educate and train staff at all levels about their roles and responsibilities, and work continually to promote FOI awareness.   

Initially, the team delivered training to frontline staff, explaining their responsibilities under FOIA and how to recognise requests. The team recorded the training and all staff can access it, along with other training materials, through an internal training platform. Staff also receive refresher training, and can access a simple guidance document with links to ICO guidance and information. 

More informally, the team provide ongoing dialogue and support to those colleagues most frequently dealing with requests.