Operational Plan 2021-22 Monitoring Report: Scottish Information Commissioner, Assignments of Operational Research

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Operational Plan 2021-22 Monitoring Report

Scottish Information Commissioner

Introduction

Introduction

This document sets out the Scottish Information Commissioner’s operational plan for the period from 1 April 2021 to 31

March 2022. The plan explains how we will realise the Commissioner’s vision and strategic aims, and provides a tool

for on-going monitoring of outcomes and management of resources, financial and human.

Vision

The impact of Freedom of Information is increased, being recognised and valued as the

key enabler of openness and transparency of public functions in Scotland, enhancing

people’s right to access the information that matters to them

Strategic aims

To realise this vision, the Commissioner’s office will:

(1) increase knowledge and understanding of FOI rights

(2) enable and support high standards of FOI policy and practice

(3) develop Scottish public sector culture and practice where the proactive disclosure of information is routine and

valued

(4) influence and support the development and strengthening of Scottish FOI law and practice

(5) contribute to Scotland being respected as a world-leader in openness and transparency

(6) be recognised as an organisation of independent and trusted experts that is run efficiently, governed effectively and

is open and transparent

Structure of the operational plan

This plan is laid out as a programme of actions listed under types of operational activity, with cross references to which

strategic aim(s) it supports. The actions listed are business as usual (BAU) and one-off projects. This a working

document which forms the basis of on-going monitoring and assessment and may be updated.

In general, BAU will be managed and monitored in line with set targets, performance indicators, established reporting

structures and approved policy.

Projects will be managed according to project management principles and practice. Each project is approved by the

Senior Management Team.

Monitoring and reporting

Progress against the plan will be reviewed every two months by the Senior Management Team and an update of

progress will be published following this review. Achievement and output against individual line items will be also

assessed and reported in line with the organisational targets and indicators and measures set out in our Performance

and Quality Framework.

Resources

The Commissioner’s budget for 2021-22 is £2,030,000:

• Total staff costs: £1,649,
• Total gross revenue costs: £2,007,
• Capital expenditure: £23,

KEY

BAU : Business as Usual

DHOE: Deputy Head of Enforcement

HOCS: Head of Corporate Services

HOE : Head of Enforcement

HOPI : Head of Policy and Information

Priority : Relative priority - Statutory, High, Medium, Low

SIC : Scottish Information Commissioner

SMT: Senior Management Team

Improving Authority Practice

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr

1 Prepare, deliver and report on programme of events andlearning opportunities (on or offline) for FOI practitioners BAU 01/04/2021 31/03/2022 X X X X H OT OT OT OT HOPI

No means to deliver own events at this time, so focused on using external events where possible. No programme as yet, pending more information on website developments.

Public sector FOI practitioner peer support mechanisms and networks - support and develop BAU^ 01/04/2021^ 31/03/2022^ X^ X^ X^ H^ OT^ OT^ OT^ OT^ HOPI

3 Prepare and circulate learning points from decisions andinterventions BAU Monthly 01/04/2021 31/03/2022 X X X X M OT OT OT OT HOE/HOPI

4

Collaborate with/involve authority representatives to inform best practice BAU^ 01/04/2021^ 31/03/2022^ X^ X^ X^ X^ H^ NS^ NS^ OT^ OT^ HOPI^ Session at CFOI conference began this work

5

FOI/EIRs statistics portal data from public authorities - collect, collate and publish BAU^ 01/04/2021^ 31/03/2022^ X^ X^ M^ OT^ OT^ OT^ OT^ HOPI^ Move from website-based portal

6 New public authorities - support to prepare for FOI duties BAU Quarterly 01/04/2021 31/03/2022 X X X S/H OT OT OT OT HOPI

7 Good practice resources, guidance and case studies forauthorities – maintain, develop, promote, and report on use BAU 01/04/2021 31/03/2022 X X X X X H OT OT OT OT HOPI

Coronavirus (Scotland) Act - update authorities on changes to FOI law and promote guidance Project^ 01/04/2021^ 31/03/2022^ X^ X^ X^ H^ OT^ OT^ Comp^ Comp^ HOPI

2 Researching FOI practitioner views and attitudes - developand conduct model, including survey, for repeat use Project 01/07/2021 31/12/2021 X X X X H NS NS OT Comp HOPI

3 Statistics Portal – implement recommendations from 2020-21review Project 01/04/2021 31/12/2021 X X M OT OT OT Comp HOPI

Strategic Aim

Information Management

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr

1 Coordinate on-going Information and Records Management (IRM) controls and procedures and ensure they are applied

BAU 01/04/2021 31/03/2022 X X X S/H OT OT OT Comp HOCS

2 IRM assurance report to SMT BAU Annual 01/04/2021 30/09/2022 X X X S/H Comp Comp Comp Comp HOCS

3 Maintenance of secure and reliable IT network BAU 01/04/2021 31/03/2022 X S/H OT OT OT Comp HOCS 4 Manage Key Documents as per the Review Programme BAU 01/04/2021 31/03/2022 X X X X H OT OT OT Comp HOCS

5

Monitor compliance with data protection legislation and the General Data Protection Regulation BAU^ 01/04/2021^ 31/03/2022^ X^ X^ S^ OT^ OT^ OT^ Comp^ HOCS 6 UK GDPR/Data protection – SMT update BAU Quarterly 01/04/2021 31/03/2022 X X S Comp Comp Comp Comp HOCS CR to QSMTM Q4 (April/May)

7 Maintain a compliant publication scheme and guide to information

BAU 01/04/2021 31/03/2022 X X X X H OT OT OT Comp HOCS

8 Commissioner’s Publication Scheme - assurance report to SMT

BAU 01/01/2022 31/03/2022 X S OT OT Comp Comp HOCS

Monitor Commissioner’s compliance in responding to RFIs and reviews – compliance with statutory timescales, policy and procedures and quality assurance (quality assurance report to be provided by HOE to HOCS)

BAU 01/04/2021 31/03/2022 X X S Comp Comp Comp Comp HOCS CR to QSMTM Q4 (April/May)

10 Monitor Commissioner’s compliance in responding to SARs – compliance with statutory timescales, policy and procedures

BAU 01/04/2021 31/03/2022 X S Comp Comp Comp Comp HOCS CR to QSMTM Q4 (April/May)

1 Business continuity arrangements - COVID -19 pandemic – remote working – interim policies

Project 01/04/2021 31/03/2022 X X H OT OT OT OT HOCS

Secure file sharing platform – scope need and resource required Project^ 01/04/2021^ 31/08/2021^ X^ X^ H^ NS^ NS^ NS^ NS^ HOCS

Need detail of what is required - Enforcement Team to confirm requirements and consider implications for public authorities if required to submit documents using this. Further discussions taken place. (MK: happy to discuss whether this is feasible for 21/22.) MK to confirm if project to be deferred

3 Secure file sharing platform – procure Project 31/08/2021 31/03/2022 X X H NS NS NS Disc HOCS

Subject to (2) above being completed (MK: see above) MK to confirm if project to be deferred 4 Residual work to implement/update re: UK GDPR/data protection

Project 01/04/2021 31/03/2022 X X X X S/H OT OT OT OT HOCS On-going

5 Digital and IT Strategy Project 01/04/2021 31/03/2022 X S/H OT OT C/f new C/f new SIC / HOCS

To be carried forward to 2022-

6 Cyber Resilience Action Plan 2021-2022 Project 01/04/2021 30/09/2021 X H OT OT OT OT HOCS

7 Cyber Essentials 2021-22 reaccreditation Project 01/12/2021 31/03/2022 X H NS NS Comp Comp HOCS

8 Cyber Essentials Plus 2021-22 reaccreditation Project 01/12/2021 31/03/2022 X H NS NS OT Comp HOCS Planned for Q

Strategic Aim

Planning & Reporting

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr

1

Annual Report (AR) 2020-21: Statutory reporting and 3Es BAU^ Annual^ 01/04/2021^ 31/10/2021^ X^ S^ OT^ OT^ Comp^ Comp^ HOCS

AR 2020-21:

Accountability Report and Financial Statements - ensure compliance with FReM, SPFM, prepare and obtain approval

BAU Annual 01/04/2021 31/10/2021 X S OT OT Comp Comp HOCS

AR 2020-

Performance Report – ensure compliance with FReM, SPFM prepare and obtain approval

BAU Annual 01/04/2021 31/10/2021 X S OT OT Comp Comp HOPI / HOCS

4 AR 2020- Annual Statement of Assurance to SIC

BAU Annual 01/04/2021 31/10/2021 X X X X H NS OT Comp Comp HOCS

AR 2020-

Auditor’s Report – liaise with Auditor and Advisory Audit Board (AAB)

BAU Annual 01/07/2021 31/10/2021 X H NS OT Comp Comp HOCS

AR 2020-

AAB meeting 2021 BAU^ Annual^ 01/08/2021^ 30/09/2021^ X^ H^ NS^ OT^ Comp^ Comp^ HOCS 7 Audit Planning Report – AR 2021-22 liaise with auditor and AAB

BAU Annual 01/10/2021 01/02/2022 X H NS NS OT Comp HOCS

8 Performance and statistical reporting - operational BAU As set out inthe GRA 01/04/2021 31/03/2022 X X X X S Comp Comp Comp Comp HOCS

9 Manage and report on Enquiries Service BAU Six monthly 01/04/2021 31/03/2022 X X X X H OT Comp OT Comp HOCS 6 monthly - CR to QSMTM Q4 (April/May)

Public Service Reform (Scotland) Act 2010 – annual statement of expenditure and annual statement of sustainable growth report

BAU Annual 01/04/2021 31/03/2022 X S OT OT OT Comp HOCS Annual CR to QSMTM Q4 (April/May)

11 Operational Plan 2021-22 – monitor and report progress BAU Two monthly 01/04/2021 31/03/2022 X X X X H Comp Comp Comp Comp SMT Will mark as complete after MSMTM 29/03/

12 Key Documents – reviews due and overdue reviews -monitor BAU Two Monthly 01/04/2021 31/03/2022 X X X X H Comp Comp Comp Comp SMT

13 Operational Plan 2022-23 - coordinate and prepare BAU Annual 01/01/2022 01/06/2022 X X X X H NS NS NS Comp HOCS Draft circulated to SMT

14 Governance Reporting Arrangements (GRA) – reportingagainst cycle BAU 01/04/2021 31/03/2022 X X X X H Comp Comp Comp OT

HOCS/

HOPI/HO

E

To complete - QSMTM Q4 (April/May) HOE QA work on compliance with investigations handbook to be cancelled until start of 2023/24 given recent changes to

15 GRA - compliance report to SMT BAU Annual 01/04/2021 31/03/2022 X X X X H Comp Comp Comp Comp HOCS

16

Case Management System – reporting (manual and automatic) for IPM/end of year Enforcement statistics BAU^ Monthly^ 01/04/2021^ 31/03/2022^ X^ M^ Comp^ Comp^ Comp^ Comp^ HOCS

17

Prescribed Persons (Reports on Disclosure of Information) Regulations 2017

BAU Annual 01/04/2021 31/08/2021 X S OT OT Comp Comp HOE

18 Report on biodiversity (as required by the Nature Conservation (Scotland) Act 2004)

BAU As required 01/04/2021 31/03/2022 X S Comp Comp Comp Comp HOCS

19 Sustainable Development - monitor and report on carbonfootprint BAU Annual 01/04/2021 31/03/2022 X S OT OT OT Comp HOCS

Business continuity arrangements - COVID -19 pandemic –enquiries - interim revised arrangements and reporting procedures

Project 01/04/2021 31/03/2022 X X H OT OT OT C/f new HOCS Ongoing - to be carried forward to 2022-

2 Enquiries procedures – review of outcome codes and assurance reporting

Project 01/04/2021 31/03/2022 X X X X X H OT OT OT C/f new HOCS Ongoing - to be carried forward to 2022-

3 Equalities Monitoring and Reporting – service users - revisedsystem Project 01/04/2021 31/03/2022 X X H NS NS NS C/f new HOCS Ongoing - to be carried forward to 2022-

Strategic Aim

Planning & Reporting

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr

Strategic Aim

4 CMS – review of in-house reporting Project 01/04/2021 31/03/2022 X X H NS NS NS C/f new HOCS Ongoing - to be carried forward to 2022-

UN Convention on the Rights of the Child (Incorporation) (Scotland) Act - Research and prepare to implement any changes required

Project 01/05/2021 30/12/2021 X X S NS NS Disc Disc (^) HOCSHOPI/^ 03/02/22 - Agreed to be discontinued andwatching brief in place instead

Comms, Engage. & Policy (Ext)

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ update

1 2 3 4 5 6 Mgr

Strategic Aim

Social media – launch LinkedIn channel use to target FOI practitioners and specialists (including relevant updates to social media and other procedures)

Project 01/04/2021 30/06/2022 X X X X M NS Slip Disc C/f new HOPI

New channesl to be investigated 2022- 23

6 Website – consideration of website discovery findings Project 01/04/2021 31/07/2022 X X X X X X H OT Slip OT OT SMT / HOPI

Delayed as result of website issues - being undertaken in Q3/Q4 as part of web development

7 Website – development and build of potential new website Project 01/07/202131/03/2022 TBD X X X X X X H NS NS OT OT

HOPI

/HOC

S

Development and build phase now started

Active membership of International Conference of Information Commissioners’ Executive Committee Project^ 01/04/

End of tenure or 31/06/

X X M OT OT Comp Disc SIC

Engage as appropriate with Scottish Open Government Partnership Project^ 01/04/2021^ 31/03/2022^ X^ X^ X^ X^ X^ X^ M^ OT^ OT^ OT^ OT^ SIC

10 British Sign Language translation of two resources Project 01/10/2021 30/02/2022 X X S NS NS Slip C/f new HOPI To be carried forward to 2022/

Quality Assurance

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ update

1 2 3 4 5 6 Mgr

1 Compliments and complaints – record, analyse and report BAU Six monthly 01/04/2021 31/03/2022 X S Comp Comp Comp Comp HOCS CR QSMTM Q4 (April/May)

Information Requests to SIC: (a) record, analyse and monitor performance in accordance with the Section 60 Code of Practice (b) upload details to the FOI/EIRs statistics portal

BAU Quarterly 01/04/2021 31/03/2022 X X X X S Comp Comp Comp Comp HOCS CR QSMTM Q4 (April/May)

Information Requests to SIC – provide assurance to HOCS that responses to information requests comply with relevant legislation and related guidance

BAU Annual 01/01/2022 31/03/2022 X X X X S OT OT OT OT HOE Due in Q

Investigation targets and Key Performance Indicators - monitor and review to ensure appropriate and fit for purpose BAU^ Monthly^ 01/04/2021^ 31/03/2022^ X^ X^ H^ OT^ OT^ OT^ OT^ HOE

Performance and Quality Framework – managers to report on performance for their areas of responsibility (including carrying out appropriate quality assurance reviews) and to review Key Performance Indicators and other targets and standards annually

BAU 01/04/2021 31/03/2022 X X X X X S/H OT OT OT OT SMT

HOE QA work on compliance with investigations handbook to be cancelled until start of 2023/24 given recent changes to Enforcement Team.

6 Communication targets and key performance indicators -monitor and review to ensure appropriate and fit for purpose BAU 01/04/2021 31/03/2022 X X X X X X H OT OT OT OT HOPI

Comunications framework approval delayed but reviewing and monitoring ongoing

1 Complaints Policy and Handbook – review to take account of revised Model complaints Scheme issued 31/01/

Project 01/04/2021 31/07/2022 X H OT Slip OT C/f new HOCS Ongoing - to be carried forward to 2022-

Unacceptable Actions Policy - review to take account of revised Model complaints Scheme issued 31/01/2020 Project^ 01/04/2021^ 31/07/2022^ X^ H^ OT^ Slip^ OT^ C/f new^ HOCS^ Ongoing - to be carried forward to 2022-

3 Interventions – develop monitoring and quality assurance mechanism

Project 01/10/2021 01/03/2022 X X X H NS NS NS C/f new HOPI To be carried forward to 2022/

4 Review of procedures for handling requests for information Project 01/04/2021 31/03/2022 X X X X H OT OT OT C/f new HOE/H OCS

May have to be carried forward to 2022- given recent changes in Enforcement Team. To be carried forward to 2022-

5 Review of procedures for handling subject access requests Project 01/04/2021 31/03/2022 X X X X H OT OT OT C/f new

HOE/H

OCS

May have to be carried forward to 2022- given recent changes in Enforcement Team. To be carried forward to 2022 23

Strategic Aim

Resource Management

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr 1 Set and profile budget for 2022-23 BAU Annual 01/06/2021 31/10/2021 X X X X H NS Comp Comp Comp HOCS

2 Budget monitoring and control – 2021-22 BAU Quarterly 01/04/2021 31/03/2022 X X X X H Comp Comp Comp Comp HOCS CR QSMTM Q4 (April/May)

3 Monitor and report on payment of invoices BAU Annual 01/04/2021 31/03/2022 X X X X H OT OT OT OT HOCS Annual - CR QSMTM Q4 (April/May)

4 Workforce monitoring and planning BAU Annual 01/04/2021 31/03/2022 X X X X H OT OT OT Comp HOCS

5 Maintenance of premises BAU 01/04/2021 31/03/2022 X H OT OT OT Comp HOCS

6 Maintenance of remote working facilities^ BAU 01/04/2021 31/03/2022 X H OT OT OT Comp HOCS

7 Contracts – procurement and management (as required) – where HOCS/CST indicated as lead

BAU

As agreed in relevant contract

01/04/2021 31/03/2022 X H OT OT OT Comp HOCS

8 External provision of legal services: contract management BAU As agreed in contract

01/04/2021 31/03/2022 X H OT OT OT OT HOE

Contracts relevant to policy and information – procurement and management (as required) where HOPI/P&I indicated as lead

BAU As agreed in contracts

01/04/2021 31/03/2022 X H OT OT OT OT HOPI

10 IT - replacement hardware – as per annual programme BAU 01/04/2021 31/03/2022 X H OT OT OT Comp HOCS

1 Case management system – upgrade Project 01/04/2021 31/03/2022 X H NS Comp Comp Comp HOCS

2 IT Support and Maintenance Contract – review arrangements (dependent on Digital and IT Strategy being put in place)

Project 01/04/2021 31/03/2022 X H NS NS C/f new C/f new HOCS To be carried forward to 2022-

3 Hybrid working – office working and remote working (following on from the impact of the COVID-19 pandemic)

Project 01/04/2021 31/03/2022 X H NS OT OT C/f new HOCS Ongoing - to be carried forward to 2022-

4 Procurement of legal services contract: issue tender Project 01/04/2021 31/03/2022 X H OT OT Comp Comp HOE

5 Website - renewal of current website supported hosting andmaintenance services Project 01/04/2021 31/07/2022 X H OT Slip Comp Comp HOPI /HOCS

6 Cleaning Services Contract – review of arrangements andprocurement of contract Project 01/04/2021 31/03/2022 X H OT OT OT C/f new HOCS Ongoing - to be carried forward to 2022-

7 Office premises – external painting Project 01/06/2021 31/10/2021 X H OT OT OT Comp HOCS

Main work carried out - one small area to be completed following some joinery work

8 Office premises – internal painting Project 01/06/2021 31/10/2021 X H OT C/f new C/f new C/f new HOCS

Procurement exercise undertaken in Q1 - quoted costs significantly in excess of budgeted costs Not sufficient budget avilable - to be C/F to 2022-23 (budget approval received) 9 Website – specification and procurement of development /build for any new website if required/agreed Project 01/05/2021 01/11/2021 X X X X X X H NS NS Comp Comp (^) HOCSHOPI/^ Specification preparation began late Sept 2021Tender issued 15/11/

10 Webinar/online events platform –scope need for securing service and resource required (finance and staff resource)

Project 01/04/2021 01/09/2021 X X X X X X M NS NS Disc Disc HOPI/ HOCS

Delayed due to competing priorities

11 Webinar/online events platform – procurement 01/04/2021 31/12/2021 X X X X X X M NS NS Disc Disc (^) HOCSHOPI/ Delayed due to competing priorities

Strategic Aim

Resource Management

Activity Type Frequency Start Date End Date Priority Q1 Q2 Q3 Q4 Lead Comment/ Update

1 2 3 4 5 6 Mgr

Strategic Aim

12 Policy and parliamentary update service – secure service (inrelation to CEP BAU 16) Project 01/04/2021 01/06/2021 X X X X H NS Slip Slip Comp HOPI Delayed due to competing priorities