FOI action plan

The National Archives’ action plan to improve 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 (TNA Business Records, Archival Records, MOD Service Personnel Records).

The National Archives:
Freedom of Information improvement action plan

Identified area of improvement Proposed Action Completion Date
1 Resourcing – Improve service capacity to address FOI request demand Recruiting more staff within the team/s responsible for facilitating FOI responses following Executive Team agreement with resourcing proposal. May 2023
2 Resourcing – Implement overtime to address specific blockages in FOI process for the MOD Service Personnel Records From December to March 2023 – carry out weekend working to address the release of information from these records (redaction).

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.

April 2023
3 Handling – Implement prioritisation approach to address both new cases and back log Focus resource on triaging cases – to understand more about what is needed to resolve the active cases. On-going
4 Handling – Review existing FOI processes to identify efficiencies FOI Centre – Process Review Away Day to determine further improvements for handling processes.

Continue with the process changes I.e., ‘bulk FOI requests’ – increasing triaging and engagement with requesters.

To 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.

March 2023
5 Handling – Review approach to consultation with departments Review processes in place with those public bodies that we are required to consult with most often following the receipt of information requests. May 2023
6 Handling – Consider whether the provisions of section 10(4), which allow a longer response time, of FOIA might be appropriate 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. January 2024
7 Governance – Improved data capture 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., are the cases in exceeding the 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).

March 2023
8 Governance – FOI Compliance is managed as an organisational risk Organisational focus on the risk – continue to receive senior support and collaboration to address FOI compliance. On-going
9 Transparency – Dedicated web page on MOD Service Personnel Collection Transfer Project 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.

May 2023
10 Transparency – Publication of the breakdown FOI Statistics by FOI request type To provide on our website insight into how we are performing in relation to the variety of request types we receive:

  • TNA Business Records
  • Archival Records
  • MOD Service Personnel Records
May 2023
11 Transparency – Publication of the initial Action Plan Adding the FOI Improvement Action Plan to our website. March 2023
12 Transparency – Publication of lessons learned & revised action plan 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. Summer 2023


This action plan will be updated quarterly.