FOI action plan

This page sets out The National Archives’ action plan to improve its Freedom of Information (FOI) performance.

Improving performance

The Freedom of Information Act sets clear deadlines for departments to respond to requests. The National Archives has typically performed well against these expectations, routinely responding to more than 90% of requests on time.

However, since 2020, overall performance levels at The National Archives have dropped below these standards. As a result, the Information Commissioner’s Office has issued a Practice Recommendation to The National Archives. This Practice Recommendation makes several suggestions to The National Archives on how to improve its performance.

The National Archives has responded to this Practice Recommendation through committing to the action plan below.

Explaining performance

There are a number of reasons that explain why The National Archives is responding to fewer information requests on time.  The key reason however is service personnel records.  In February 2021, the Ministry of Defence (MOD) began the transfer of historic service personnel records to The National Archives. This collection consists of over 9.7 million records which will be transferred over a 6-year period. The completion of this transfer will see the number of orderable records at The National Archives almost double in number. So far we have transferred over 4 million records from this collection – more information is available at our project page.

At the moment, the main access route for service personnel records is through making Freedom of Information requests.   As a result, The National Archives has seen requests for service personnel records grow rapidly. To put this into context, The National Archives has traditionally received around 3000 Freedom of Information requests per year – we expect that this year we will receive more than 6000 requests for military service personnel records alone.

The National Archives has put in place a specialised team to manage these requests. Due to the pace at which requests have grown, we have increased the size of this team and will continue to keep its resourcing under review.

In order to provide more transparency around our performance, we will also shortly begin sharing more data on how we are performing in relation to the variety of request types we receive (The National Archives’ Business Records, Archival Records, MOD Service Personnel Records).

Freedom of Information improvement action plan

Download our improvement plan (complete with updates) in table format:

Or view the plan and latest updates below:

1. Resourcing: Improve service capacity to address FOI request demand

Proposed action

Recruiting more staff within the team/s responsible for facilitating FOI responses following Executive Team agreement with resourcing proposal.

Status

Ongoing. Resource levels will be kept under review.

July 2023 update

Status: Ongoing. Resource levels will be kept under review.

Our Executive team has prioritised resourcing our FOI team, agreeing to double the size of the team that manages access to service personnel records. Our Executive Team has also committed to keeping this allocation under active review and will assess whether further resource is required as we see the impact of the first phase of additional staffing. We have significantly increased the resource dedicated to handling FOI requests, particularly in relation to MOD service records.

The dedicated MOD Access Service Team has grown from a headcount of 8 in February to a budgeted headcount of 16. Inevitably, there is a lead time associated with recruitment and training, but 11 of these posts are now filled, 3 have been appointed and will start within the next month and recruitment for the remaining 2 posts is underway.

Our FOI Centre – the team responsible for non-MOD requests – has stabilised and we have put in place expedited approval processes to backfill vacant posts.

We have also increased the resource that supports the MOD access team through producing and copying records.

October 2023 update

Our Executive team has continued to prioritise resourcing our FOI teams and has committed to keeping this allocation under active review – assessing what further resource is required.

Our FOI Centre – the team responsible for non-MOD requests – has stabilised, currently fully staffed.

The MOD Access Service Team has grown to a budgeted headcount of 17, including a new Head of Access service, 12 review staff, 3 managers, 1 support staff. 12 of these posts are now filled, 4 have been appointed and will start within the next month – hoping to be fully staffed by end of October 2023.

There remains a lead time associated with recruitment and training; we hope to see the impact of all this recruitment in Q1 – 2024.

The resource that supports the teams; specifically, the MOD access team through producing and copying records and redacting still needs reviewing – to determine if they can service the growing demand.


2. Resourcing – Implement overtime to address specific blockages in FOI process for the MOD Service Personnel Records

Proposed action

  • a) From December to March 2023 – carry out weekend working to address the release of information from these records (redaction).
  • b) By end of this work, have resolved all pre-October 2022 cases while putting in place resources to sustain a position of having a very limited number of cases that are older than 6-months before eliminating the backlog as our capacity increases.

Status

  • a) Ongoing.
  • b) Completed.

July 2023 update

Status: Ongoing.

  • a) We have successfully used targeted overtime to reduce backlogs and will continue to do so until compliance levels have improved, and the backlog is significantly reduced.
  • b) We have now reviewed all cases received before October 2022. We will continue to balance our resource between new and backlogged cases with a view to eliminating the backlog over time.

October 2023 update

We are continuing to use overtime to reduce backlogs and will continue to do so until compliance levels have improved.

We will continue to balance our resource between new and backlogged cases with a view to eliminating the backlog over time.


3. Handling: Implement prioritisation approach to address both new cases and backlog

Proposed action

Focus resource on triaging cases – to understand more about what is needed to resolve the active cases.

Status

Completed for FOIC.

Ongoing for MOD Service Personnel Records.

July 2023 update

Status: Completed.

Our FOI Centre has an established process for triaging cases. As part of our improvement activity, we have adopted many of the same principles into our handling of MOD service records. Our recent recruitment includes a member of staff who has responsibility for triage, and we will further invest in triage resource.

We have also upskilled the wider team to undertake this function where needed.

We are also dynamically balancing resource between servicing new cases and addressing our case backlog. We consider that this action is completed but will continue to review where new approaches will be of benefit.

October 2023 update

Our FOI Centre has an established process for triaging cases.

We will further invest in triage resource in MOD SP team. The processes/workflows are slightly different for the cases dealt with by this team so we are going to continue to review where innovative approaches will be of benefit.


4. Handling: Review existing FOI processes to identify efficiencies

Proposed action

  • Identify improvements that could be made to the S66 consultation process.
  • Review of MoD team processes to deliver handling efficiencies and to ensure clear escalation routes exist where process issues create late running cases.

Status

Completed.

We will adopt a continuous improvement approach and where further improvements can be made, we will take this forward.

October 2023 update

As reported in Q1 – implemented several process improvements in both the FOIC and MOD Access Service Team. Further process improvements for Q2 in the FOIC include:

  • Identified a new extension process for the 10-day extensions for transferred records – should save administration time.
  • Change proposed for the CAB Stat collation – to save FOIC staff time.
  • Increased the number of FOI Panels for S66 cases – throughput of cases increased and helps resolution turnaround.

5. Handling: Review approach to consultation with departments

Proposed action

Review processes in place with those public bodies that we are required to consult with most often following the receipt of information requests.

Status

Completed and will be kept under review.


6. Handling: Consider whether the provisions of section 10(4), which allow a longer response time, of FOIA might be appropriate

Proposed action

In line with the ICO recommendation, explore with other parts of government whether there is benefit in seeking ministerial authority to apply section 10(4) provisions to requests for service personnel records.

Status

To be reviewed January 2024.

July 2023 update

We intend to imminently begin exploration of this option (Q3 2023), and the potential benefit it would bring to The National Archives. In light of sustained pressures, we intend to explore this option before the original target date of January 2024.

October 2023 update

We have begun exploration of this option (Q3 2023) and drafted a proposal to be discussed internally before submission to Ministers.

We intend to finalise this option by January 2024.


7. Governance: Improved data capture

Proposed action

  • To align data reports from the MOD project and the FOI Centre – specifically to monitor on a month-to-month basis if the active caseload is increasing, i.e., does the volume of cases received exceed the volume of cases resolved monthly (evidence for assessing capacity vs demand and resource needs).
  • More work around forecasting – FOI demand and the resource level we require to match this.
  • Providing these reports to those that govern the project and FOI Compliance (Steering Committees and Executive Team)

Status

Completed – MOD Service Personnel Team.
Ongoing for FOIC.

July 2023 update

Status: Completed

We have developed a regular internal performance report. This will continue to iterate and improve as we develop the workflow systems that sit behind it.

Our Strategic Insights Team has also built the first version of a forecasting and resource tool. As our trend data matures, we will increasingly use this tool to plan resource requirements

October 2023 update

We are starting to use this tool to plan resource requirements. This will be extremely useful in our upcoming budget/resource planning.

We don’t yet have the same tool for FOIC. Exploring forecasting/performance models within FOIC – ie D365. Need to re-engage with Strategic Insights for this work.


8. Governance: FOI Compliance remains part of the Corporate Risk Register

Proposed action

Organisational focus on the risk – continue to receive senior support and collaboration to address FOI compliance.

Proposed action

Ongoing.

July 2023 update

Status: Ongoing.
FOI compliance remains on our corporate risk register and we are reporting progress and performance on a quarterly basis to our corporate Audit and Risk Committee and to our Chief Operating Officer.

FOI compliance remains a high priority for The National Archives. This is demonstrated in part by having achieved 100% compliance on ‘corporate’ FOIs, the requests that require cross-organisational input.

October 2023 update

FOI compliance remains on our corporate risk register and it was agreed at Executive level that governance would remain with the Board – and the new Independent Audit and Risk Committee member will also to be briefed on the matter. This reporting will be done on a quarterly basis.

FOI compliance remains a high priority for The National Archives. This is demonstrated in part by the new reporting process at a senior and independent level. And as in Q1 by continuing to achieve 100% compliance on ‘corporate’ FOIs, the requests that require cross-organisational input.


9. Transparency: Dedicated web page on MOD Service Personnel Collection Transfer Project

Proposed action

  • To manage expectations on 1. what records are held and 2. the timeframe for responses (active FOI requests – service level details)
  • To provide clear and web searchable information on how to make requests (web forms & FAQs)
  • To provide a place to include information on the transfer plan – high level details on when records might be held.
  • Use FAQs to manage common BAU enquiries – reducing FOI handling.

Status

Completed – but consideration is being given to improvements in this area – ie:

    • updated FAQS
    • links to MOD web pages
    • navigation and explanation around the three main web forms.

July 2023 update

We have created a dedicated project page on our website to better explain our management of service personnel records. This includes a revised set of FAQs, clearer guidance to requestors plus clearer web form links. This will continue to iterate and develop.

We are also providing additional detail on timelines to all requestors when they submit an information request.

October 2023 update

As per Q1 update.


10. Transparency: Publication of the breakdown FOI Statistics by FOI request type

Proposed action

To provide on our website insight into how we are performing in relation to the variety of request types we receive:

  • The National Archives’ Business Records
  • Archival Records
  • MOD Service Personnel Records

Status

Completed.

July 2023 update

We have published a breakdown of our performance information on our website. We will update this data on a quarterly basis and publish on the FOI pages of our public-facing website.

October 2023 update

We continue to update this data on a quarterly basis and publish on the FOI pages of our public-facing website.


11. Transparency: Publication of the initial Action Plan

Proposed action

Adding the FOI Improvement Action Plan to our website.

Status

Completed.

July 2023 update

We have published this improvement plan on our website.

October 2023 update

We have published this improvement plan on our website – to be updated for Q2.


12. Transparency: Publication of lessons learned & revised action plan

Proposed action

Once we have more data on the impact of initial actions – i.e., Q4 2022 & Q1 2023 FOI statistics results – issue a revised action plan and produced lessons learned report.

Status

Summer 2023.

July 2023 update

We will review our action plan at the end of Q2.

October 2023 update

For Q3 – we will update the action plan to include on-going actions and additional and required actions.


This action plan will be updated quarterly.