The National Archives (TNA) has developed the S46 Code Self-Assessment tool to enable public sector bodies to assess overall compliance and understanding of the responsibilities and requirements outlined in Part 2 of the FOIA S46 Code of Practice: Managing Information and Records.

Participants in the S46 Code Self-Assessment tool pilot found that committing resources to the initial S46 Code Self-Assessment resulted in the creation of a robust dataset to benchmark future performance and use when building a business case or case for support. They found that the benefits greatly outweighed any demands on resources because the tool can be prioritised section by section based on agreed timeframes and specific organisational needs.

Accessing the S46 Code Self-Assessment tool

The S46 Code Self-Assessment is offered to public sector bodies in the form of an assisted self-assessment. In this context, assisted means the assessment data is completed by the public sector body. The assessment data will be:

• Submitted by participants via Smart Survey in the form of a questionnaire comprising of 68 questions.
• Assessed by participants of the survey and analysed by the Cross Government Engagement team.
• Summarised in a report written and returned to participants, highlighting strengths and areas requiring development; helping to create action plans, set improvement targets and monitor progress within organisations.

Completing the S46 Code Self-Assessment

We recommend participants consult the S46 Practice Study resource and the Information Management Assessment toolkit glossary prior to completing the S46 Code Self-Assessment, to familiarise themselves with key concepts and terminology.

The S46 Practice Study resource can be used to look up examples of the type of good practice participating departments have cited when completing the survey.

All compulsory questions are marked with an asterisk. Throughout the survey each requirement of the S46 Code Part 2 is tested by asking participants to assign the statement ‘Yes’, ‘To some extent’ or ‘No’ to each area of practice: If the answer is ‘Yes’ or ‘To Some Extent’ you will be asked to:

• Briefly describe the practices in place which meet the requirements of the Code; and
• Specify a suitable evidence type to support your answer.

Without the ability to provide examples of practices and /or point out evidence types it is unlikely that the organisations will meet the requirements of the Code.

In terms of evidence types, a pre-populated list will be provided with elements defined in the S46 Practice Study resource to choose from or to add new types.

Please note, submission of evidence will not be required. However, evidence types should be available as it may be requested for further assessment exercises as part of the IMA program.

The survey also includes options to indicate if the questions are ‘Non-applicable’ or ‘Unknown’. During the evaluation ‘Unknown’ answers will be graded equally to ‘No’ responses.

System and collection specific questions

In five sets of questions (22, 26, 28, 30, and 32), the Self-Assessment ask questions at collection type level.

For these questions we use the following grouping of information collection types. The examples under the types are indicative and non-exhaustive.

1. Email (current, held in in-use Email systems)
2. User holdings
   • Local ‘C:’/hard drives/laptops
   • ‘One Drive’ on Microsoft systems
   • ‘My Drive’ on Google system
3. Shared structures (not-EDRM like)
   • E.g. File shares
4. Cloud document systems and EDRMs
   • Formal EDRMs, SharePoint, Google Shared Drive etc.
5. Corporate management systems
   • HR, Finance, Procurement, Business Intelligence, CRM, Case Management systems etc.
6. Collaborative tools / workspaces (corporate)
   • M365 Teams, Loop, Google Spaces etc.
7. Non-reliable data storage
   • Hard Drives, CDs, DVDs, USB sticks
8. Shadow IT and non-corporate communication channels
   • Slack, Trello, WhatsApp etc.
9. Structured data
   • Datasets and databases etc.
10. Paper Records

Using Smart Survey

Can I save and continue later?

Imbedded in the survey is an option to ‘Save and continue later’ button. This is available at the bottom of each page and allows you to save the answers given up to a certain point and to return to complete your response later.

Clicking the button ‘Save and continue later’ will prompt you with a new browser window, where you can provide the name and email address of the person who the saved survey will be sent to. This can be your own details if you would like to return to the survey later or the details of a colleague who would be responsible for filling in the respective part of the survey.

Clicking the ‘Save’ button will send a link to the survey to the email address provided, which will allow the recipient to access the survey – including the answers already provided – to fill in the remaining parts.

Note: If you are filling in the Self-Assessment collaboratively, it is highly recommended to refer the survey to the person who began completing the survey before submitting the response.

S46 Practice Study resource

S46 Practice Study Group

To support the S46 Code Self-Assessment, a S46 Practice Study Group has been created with participation from GKIM practitioners representing various sizes and forms of public sector bodies, with a remit to explore the interpretation of the Code’s requirements, identifying what represents ‘good’ practice in certain areas; discussions were captured and summarised in the form of ‘good practice’ statements.

Good Practice

The good practices detailed in the S46 Practice Study Resource are indicative, based on the input of participants in the practice study and are not exhaustive.

Organisations may engage in good practice not captured here and it will be valuable to share these with other departments too. The IMA programme will continue to engage with government to monitor and promote good practice across the sector.

Using the resource

Organisations participating in the S46 Code Self-Assessment are expected to provide examples about their practices and identify evidence types to support self-evaluated ratings.
Examples in the S46 Practice Study resource highlight approaches taken by organisations.

Summaries of the S46 Code’s of Practice requirements are listed in the ‘Key indicators for an Optimal rating’ box in each section of this document.

How S46 Code Self-Assessment data will be used

Data collected during the Self-Assessment will be used by TNA to help support public sector bodies improve GKIM practices and compliance. Anonymised data may be used to analyse the information management landscape across government and to improve our guidance and engagement offer. Anonymised data may also be used to help identify evidence of good practices and incorporated into the toolkit content to be promoted through the IMA programme.

Submitted ‘other’ practices and forms of evidence types will further enrich further this S46 Practice Study Resource to support knowledge sharing across the Government Knowledge Information Management community.

As set out in The National Archives’ Memorandum of Understanding (MoU) with the Information Commissioner’s Office (ICO), The Keeper may be consulted by the Information Commissioner where the latter is considering issuing a Practice Recommendation to an authority that is subject to the Public Records Act 1958. Data collected as part of the self-assessment may inform the view of the Keeper in these circumstances and he may share data collected through the self-assessment as part of his feedback.

Additional resources

Resources

• FOIA 2000 Section 46 Code of practice
• S46 Practice Study
• IMA Toolkit Glossary
• Section 46 Code Self-Assessment questions