Compliance with the Freedom of Information Act 2000 James Newman (Legal Compliance Manager)

Archives & Corporate Records Services Part of the Information Services & Systems Directorate 2 new teams created in the summer of 2003 consisting of: Legal Compliance Manager – James Newman Legal Compliance Assistant – Sandra Atabo Records Manager – Clare Cowling Records Assistant – Joshua McKim Providing support to colleagues within all Schools and Departments of King’s College London

Archives & Corporate Records Services Key areas of activity for the new Legal Compliance and Records Management teams: Data Protection Freedom of Information Records Management Communications systems Intellectual Property Rights E:Commerce Information Security

Part 1 – Development of Publication Scheme

Pilot of JISC Model Scheme May 2003 - King’s invited by JISC to take part in pilot project to trial the draft Model Publication Scheme for HE institutions May/June 2003 - College wide information survey undertaken and the draft Model Scheme adapted to reflect the findings June 2003 - Members of the College community invited to participate in a consultation exercise on the adapted version of the Scheme (format, structure, content, etc.) July 2003 - Results of the project then submitted to JISC and several recommendations incorporated into the model September 2003 – JISC Model Publication Scheme published

Adoption of Model Scheme September 2003 - Decision made that King’s would adopt the Model Publication Scheme produced by JISC September/October 2003 – Model Scheme tailored by Legal Compliance Team to meet institutions requirements (input obtained from other colleagues as necessary) November 2003 – Consultation exercise undertaken involving key stakeholders and their colleagues December 2003 – Final amendments incorporated, Scheme submitted to College Council for formal approval and OIC notified of decision to adopt Model Scheme

Key Stakeholders Section 1 Governance College Secretary & Registrar Financial Resources Director of Resources Section 3 Human Resources Director of Personnel & Training Section 4 Physical Resources Section 5 Student Admin & Support Academic Registrar Section 6 Information Services Director of Info Services & Systems Section 7 Teaching & Learning Section 8 Research & Development Assistant Registrar Section 9 External Relations Director of External Relations

Part 2 – Implementation of Publication Scheme

Publicising the Scheme November 2003/ongoing – Reference to the Scheme to be incorporated into Records Management/Information Compliance training sessions January 2004/ongoing – Articles on the Publication Scheme (and Freedom of Information generally) appearing in College publications February 2004 – Publication Scheme and supporting information will be made available on the King’s Website (the College Community will be emailed a link to it and invited to view it)

Publicising the Scheme (2) February 2004 – Publication Scheme produced in hard copy and distributed to main reception of each campus and College Central Enquiry Unit February 2004 – Guidance notes and Q&A style information on the Scheme (including detailed information on permitted charges) made available to employees via the staff section of the College Website February/ongoing 2004 – Short briefing sessions covering the purpose and application of the Scheme offered to ‘front-line’ staff involved in supplying published material to enquirers

Part 3 – Preparations for January 2005

Practical measures Publicise the Publication Scheme, Records Disposition Schedule, Records Management Toolkit Develop “enquiry flowcharts” Enable FoI publication scheme on-line Confirm editorial guidelines on lower tier schools and department sites Establish public and inward-facing websites from Sept 2004 Continue and expand the current programme of staff training on information compliance and records management and guidance for staff on handling requests for access to published information. Provide advice for potential enquirers both online and as a hard copy leaflet (to be distributed to main reception of each campus and College Central Enquiry Unit).

Practical measures (2) Undertake audits of records in all departments Develop local records disposition schedules Produce guidance notes and Q&A style information on the new right of access and how requests for access to information should be processed (to be made available to employees via dedicated FoI pages of the staff section of the College Website) Develop the role of (and where necessary recruit) Compliance Co-ordinators in each academic and administrative department to encourage local ownership of information compliance and records management issues Promote the availability of Legal Compliance and Records Management teams ‘helplines’ providing information and advice

Policy/procedural steps Develop and implement a corporate Freedom of Information Policy Clarify the approach to be adopted on the charging of fees for the provision of information in response to a Freedom of Information request (including VAT issues) Formulate internal guidance on the application of the various exemptions provided by the Act (and how to apply the public interest test in this context) Develop the internal appeal process for enquirers wishing to contest a decision not to release information to which they have requested access