Introduction to the S46 Code Self-Assessment

As part of the Information Management Assessment programme, TNA has developed the S46 Code Self-Assessment tool (the Self-Assessment) to assess public sector bodies’ understanding of their responsibilities and overall compliance with the requirements outlined in Part Two of the Freedom of Information Act (FOIA) Section 46 Code of Practice (the Code) (Managing Information and Records).

Please Note: Part three of the Code, ‘Historical Records’, focuses on compliance with the Public Records Act (PRA) and is monitored by TNA through the Information Management Report (IMR) programme and is excluded from the Self-Assessment’s question set.

Self-Assessment Sections

The Self-Assessment tool converts all requirements defined in Part Two (Managing Information and Records) of the Code into measurable questions. There are currently 68 questions organised under the five sections of the Code with additional subsections. Wherever suitable, the Self-Assessment tool asks questions at a system or collection level to gather data for more accurate analysis.

The five sections of the Self-Assessment are:

  1. Governance and Capabilities
    • Governance
    • Organisational capabilities
    • KIM influence
    • Technical capabilities
  2. Keeping, Finding, Using Information
    • Keeping Information
    • Metadata
    • Environment
    • Trusting Information
    • Personal Data
  3. Disposition and Destroying Information
    • Disposition
    • Destroying Information
  4. Responsibilities where Information is shared
  5. Monitoring and Assurance

By structuring the Self-Assessment in this way, participants can assess their organisation’s understanding of and compliance with part 2 of the Code. Public sector bodies, by completing the Self-Assessment, will be able to measure the strengths and weaknesses of their Knowledge and Information Management (KIM) practices, set improvement targets and monitor future progress.

Self-Assessment process and how to access it

The Self-Assessment is conducted as an ‘assisted Self-Assessment’ for public sector bodies. Data is gathered via a third party (ISO 27001 accredited) online survey tool and analysed by the TNA Cross-Government Engagement team, who then create an assessment report.

If you are interested in undertaking the assisted Self-Assessment or would like further information, please email Further guidance is also available on completing the assisted Self-Assessment.

A static version of the Self-Assessment questions can be accessed here.

S46 Practice Study Group

To support the development of the Self-Assessment, a S46 Practice Study Group has been created with the participation of GKIM practitioners representing various sizes and forms of public sector bodies. The aim of the group was to study the interpretation of the Code’s requirements and to identify ‘what good looks like’ in certain areas. These discussions were captured and summarised in the form of ‘ good practice’ statements which are reflected within throughout the module’s question set. For more information on how the Module was developed, please consult the IMA S46 Practice Study output and guidance.

How we use the data

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 best practices at well achieving bodies to be promoted through the programme.

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.