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We run TheyWorkForYou to make UK politics more accessible and accountable.
Here’s what we’ve been doing recently to make that happen.
We’re keeping you informed
Our alerts service will send you an email whenever your chosen keyword or phrase is mentioned in Parliament; or you can follow any MP or other representative to receive an email when they speak or vote.
So far in 2026, we’ve sent 2.2 million email alerts and our users have created almost 2,000 new keyword alerts through our new and improved alerts management system.
This service helps people understand what their representatives (across all of the UK’s Parliaments) are saying and doing, and also provides an essential service in providing free parliamentary monitoring to civic groups and organisations who can now have as much access to this intel as those with big pockets.
This doesn’t happen by itself: every day our team pulls together the transcripts from the UK’s Parliaments, fixing formatting issues and broken files to get these loaded into the site and our alerts.
If you don’t have alerts set up, what are you waiting for? You can do it now at TheyWorkForYou.com.

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Help make more of it happen!
We’re counting the votes
Our voting summaries are one of TheyWorkForYou’s distinctive features, providing a quick digest of how MPs have voted, and where they do and don’t differ from similar MPs of their party.
Keeping these up to date takes a lot of care and thought, to fairly describe votes, and adjust to changing trends on how Parliament is working. We’ve now released our summer update to the voting records, adding new votes, adjusting descriptions on old groupings, and improving how we display older votes to make it clear which ones are more recent, while reflecting that old votes might continue to be significant.
Learn more about our process, the new votes added, and our ongoing improvements we made to how votes are displayed — and find out how your MP voted at TheyWorkForYou.com.
We’re working to raise standards
We don’t just want to watch Parliament: we want to make it better. One of the ways we can do this is using our information and analysis to help enforce Parliament’s existing rules.
We’ve started to make complaints through the standards process where we see what we think is a breach of the rules — you can read about our first successful complaint, where an MP needed to apologise for not declaring a relevant interest when asking a parliamentary question.
This is based on the data and analysis we publish: you can see the register of financial interest for all your representatives (and download full datasets) at TheyWorkForYou.com.
We’re always making TheyWorkForYou better
One of the things we want to do with TheyWorkForYou is help explain how UK democracy works in practice.
Last year, we added APPG memberships and EDMs/open letters to TheyWorkForYou, to help explain more about MPs’ views and activities.
With the return of Andy Burnham, we’ve improved some of our descriptions to better represent MPs who return to Parliament after a time away.
Democracy doesn’t stand still, and we’re always thinking about how we can improve our approach.
You can see the groups your MP is a member of, plus the Early Day Motions and any open letters they’ve signed on their TheyWorkForYou.com page.
We need your help
TheyWorkForYou makes a big difference with a small team, but to make a bigger difference we need your support. We don’t want to wait for a better political system to be given to us – we want to work together to make it happen now.
A one-off (or better yet, monthly) donation helps us to both do the daily work, but also think long term about how we can use TheyWorkForYou to make UK democracy better.
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Images: House of Commons (Open Parliament Licence)
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Every year from around April to September, we see an uptick on people sharing links to our Freedom of Information site, WhatDoTheyKnow on Reddit forums. The reason? It’s the peak time for anxieties around university entry.
As we know, universities are generally looking for the brightest of minds. Perhaps that includes those who have enough initiative to source data around things like their entry requirements and shortlisting criteria.
As public bodies, universities are subject to the Freedom of Information Act, so a lot of this data can be requested; and where people have used WhatDoTheyKnow to do so, the responses are publicly available for other potential students to access in years to come.
So what kind of information are these bright sparks asking for? In a brief analysis, we came across requests which address seven distinct questions for university applicants.
What A-Level subjects should I take to get into the university course of my choice?
Forward planning never hurts, and for some smart kids this comes into play as early as Year 11.
“Does a fourth A-level help you get into the Computer Science course at a top-level university?”, asked a student who was about to pick their sixth form subjects.
A response pointed them to this FOI response from the University of Oxford, indicating that passing four A-levels does indeed appear to help for Oxford, while astutely adding that cause does not always align with correlation: “It’s hard to know whether other things impacted the offer rate there, eg are people more likely to do well on the admissions tests if they’re doing four?”.
What GCSE marks do I need to achieve in my exams to enter the university I want?
The anxieties start early, as we see from this post asking “Does Cambridge ever reject people because of slightly weaker GCSEs compared to the applicant pool?” and this one wondering whether a B in Maths GCSE is enough to get into Bath Uni.
The required data was provided here and here, for the prospective students to consult and draw their own conclusions.
How can I access past university entry tests for practice purposes?
One chemistry enthusiast found that old Oxford Uni entry tests were available only to current students on the student portal — not much use for those wanting to practice before the real thing!
A kind soul was able to point them at this request, giving access to several past papers from 2003 to 2017. That’s just one of many such requests across multiple subjects at several unis: in fact, there have been so many on WhatDoTheyKnow that we’ve created a ‘past exam papers’ section on our categories page.
How do universities decide shortlists?
This Reddit post was subsequently deleted by its author, but from the responses it is clear that it was asking whether the author’s results would be likely to see them shortlisted for interview.
The FOI request provided in the comments is a smart one, referring back to a previous successful request and asking that the same data be provided for the most recent time period.
When do universities send out offer letters?
Once you’ve done all you can on your application, interview and any entrance tests, all that remains is to sit back and wait for the hoped-for offer letter.
This helpful Redditor, sharing dates from previous years around the Maths with Data Science course at LSE, said, “I thought the following would be worth mentioning for those who have applied, and are agonisingly checking their emails at 8pm; waiting for news that will seemingly never come.”
They shared this request, the response to which provided rich data beyond just the decision dates for each applicant: we can also see predicted grades, country of residence, and their TMUA test scores.
What’s the best way to pick university course modules?
So you’ve been accepted onto the course? The usefulness of FOI doesn’t stop there! In this request, a student about to start their first year studying Maths at Warwick University was wondering which optional course modules to select.
They were asking which might have the best lecturers or be the most interesting overall; but in a comment, another fresher shared that they had already submitted an FOI request to understand which modules resulted in the highest number of exam/coursework marks — so not only were they able to provide useful extra context, but also to identify themselves as a soon-to-be classmate!
What are the stats around Postgrad waiting lists?
Finally, for those who got onto a uni course and then enjoyed it so much that they went on to apply to a postgraduate degree, there are still more questions to be asked.
Questions like the total number of applications received, the number of applicants placed on a waiting list, and the number who subsequently received an offer.
This kind Redditor gathered together three FOI requests to answer those questions.
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If you’re a student wondering about similar questions to those above, we hope this has been a useful guide to everything you can discover thanks to Freedom of Information. The first step is to search WhatDoTheyKnow to see whether what you need has already been requested — and if the exact information you seek isn’t already on there, check out our handy guide for some basic guidance in making a request yourself.
Requests come thick and fast at this time of year, and we suspect from a younger userbase than is our norm. We don’t mind it at all — in fact, we hope it provides a gateway to using FOI for life, and perhaps exploring all mySociety’s other useful online tools for civic action.
Oh, and if you’re a member of university staff yourself, here’s food for thought: as we’ve demonstrated above, this type of information is very much in demand. You could consider proactively publishing it on your site, so there’s no need for students to make requests at all. WhatDoTheyKnow will also be a useful resource for you — check what students have requested from your uni, and from others, to help understand what type of information people are keen to access.
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Image: Chris Boland
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Many of us may have wanted to put the Covid pandemic out of our minds once it passed — but those with more medical and scientific understanding would be justified in exploring a little more deeply into how well the UK government and our NHS services handled it. What can we see from the facts and figures around lockdowns, mortality rates and even the efficacy of testing?
One ideal tool for this type of enquiry is Freedom of Information — the right to ask public authorities for recorded information. And the Trust The Evidence project, run by Tom Jefferson and Carl Heneghan, has made very good use of that, thanks to WhatDoTheyKnow.
Their approach? Small, focused FOI requests lodged via WhatDoTheyKnow (and therefore accessible for everyone to see), followed by deeper analysis and articles both in the media and on their own SubStack, which is supported by an engaged audience.
We asked Tom and Carl to tell us a bit more about how they’ve used FOI and what they have discovered about the UK’s response to the pandemic, as well as other pressing health matters. First of all, how have they come to be working together?
“We’d collaborated for a decade before beginning our research on the evidence surrounding the Covid pandemic in 2020. We’re both medically trained epidemiologists and academics with a background in primary care.”
As you may remember, in the UK, lockdowns and the closure of many businesses and public spaces began in the spring of 2020. “As early as April 2020, we predicted that lockdowns would have devastating effects on both lives and the economy.”
Background knowledge
They weren’t basing that prediction on mere speculation— they had the professional expertise to back it up. Tom is a Senior Associate Tutor at the University of Oxford, a former researcher at the Nordic Cochrane Centre and a former scientific coordinator for producing HTA reports on non-pharmaceuticals for Agenas, the Italian National Agency for Regional Healthcare.
Carl is Professor of Evidence-Based Medicine at the University of Oxford. He is a clinical epidemiologist with expertise in evidence-based medicine, research methods, and evidence synthesis. He also works as an NHS urgent care GP.
Nonetheless, their early interventions did not go down well.
“We faced persecution for asking questions. We endured personal attacks and censorship from self-proclaimed experts, influencers, and the very institutions we’d dedicated decades of our careers to.
“That’s when we decided to launch our own SubStack forum called “Trust the Evidence”, where we focus on examining evidence rather than popular narratives or spin. The goal is to advocate for policies grounded in evidence rather than dogma, ultimately driving meaningful change.”
And where does that evidence come from?
“Well — this is where Freedom of Information requests become important.”
Advocating for policies based on evidence
“Over the last six years we have either reviewed or made hundreds of FOI requests, and in WhatDoTheyKnow we’ve found information released via other people’s requests, as well as the ability to pursue our own inquiries, openly and with short, sharp questions. We now routinely use FOI to try to understand what’s behind the official narrative and to verify its evidence base.
“So, for example, in the winter of 2021-2022 we set out to analyse public authorities’ understanding of PCR testing for SARs-CoV-2 in the UK by looking at FOI requests others had posed in 2020-21 to NHS Health Trusts, laboratories, and government agencies such as Public Health England and the Department of Health and Social Care.
“We searched WhatDoTheyKnow using specific terms, such as “PCR cycle threshold,” to understand the use of PCR in the UK public sector, and we reviewed 300 FOI requests from more than 150 members of the public who were asking questions about the £37 billion Test And Trace programme. We noticed that, often, members of the public understood and knew more about the topic than those who responded. We found evidence of extensive misuse and misreporting of the tests used.
“So FOI requests showed that members of the public understood the types of tests used, their shortcomings, and the willingness of public bodies to bend the results to fit the general narrative, which supported the government’s introduction of emergency measures without a credible assessment of the threat.
“We quickly followed up this work with research into several more related areas: Covid benefits fraud; various definitions of Covid deaths; excessive mortality in care homes; the potential harms and benefits of Covid vaccines (Comirnaty regulatory evidence & adverse effects, Vaxzevria and Yellow Card adverse-event data); Hospital-acquired COVID / respiratory-virus infections; Avian-influenza vaccines and procurement and then more broadly into NHS expenditure/accountability; Influenza and NHS winter-crisis evidence.”
A hectic few years
There is clearly an audience for this work. Carl and Tom are closing in on close to 1,400 posts to date, with subscribers from 140 countries having viewed their mailouts more than 11 million times.
But it doesn’t stop there. “When we consider the sharing and republication of our work, as well as media interest and parliamentary questions, the reach becomes remarkable. The content has been republished in various outlets and cited by multiple news organisations, with translations into several foreign languages.
“This all shows the central role that WhatDoTheyKnow has played and continues to play in our work. Subscribing to WhatDoTheyKnow Pro has made things much easier, as we can send batch requests to multiple authorities at once, building up a national dataset that didn’t previously exist.
“At present, we are working on summarising the replies to 161 batched FOI requests to NHS bodies regarding Influenza/NHS winter-crisis evidence. We’ll soon follow that up with over 200 requests to NHS bodies for details of their 2026-27 winter plans.
“It’s been a hectic few years of work! We can only add that FOI and WhatDoTheyKnow are central to what we’re doing.
“We’ve managed to get replies; but also, public bodies often try to evade transparency. We write about that, too — it is all part of the evidence.”
Evidence, rigour and expertise
The ultimate aim? “We present robust evidence. We apply scientific rigour alongside our extensive clinical expertise. This approach ensures that our insights are credible, and also deeply aligned with the societal values that should underpin healthcare.
“And by bringing diverse voices and perspectives into our discussions, we strive to foster richer conversations that pave the way for safer, more informed healthcare.”
Many thanks to Tom and Carl for sharing their experiences of using WhatDoTheyKnow. You can subscribe to Trust The Evidence to access their full archive of posts and they say, “we’re happy to see our posts republished with proper acknowledgement.”
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Image: iMattSmart
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Are you one of the many who has watched the BBC’s two-parter Buried with Michael Sheen? If so, you may have experienced increasing levels of outrage as the actor helps to uncover the scandalous dumping of toxic waste across sites in Wales and England — and lays out the effects, only now fully emerging, that this has had on local residents’ health.
Sheen, is, of course, the big draw; the well-loved actor getting the UK to take an interest in a complex, localised topic. But in several scenes, you’ll also have seen Paul Cawthorne, vicar and environmental campaigner: helping to test soil at the contaminated sites; sharing a testimony from one of his parishioners who had been employed to dump the chemicals; and providing background information from more than a decade of investigations.
What you won’t necessarily have realised is that much of that background information has been obtained, over the years, from Freedom of Information requests made on WhatDoTheyKnow — this case stands as an example of how FOI can play a crucial part in bringing malpractice to public attention.
Over a decade of dedicated investigation
Paul’s investigation into the dumping dates back many years, and he has made great use of Freedom of Information to secure the evidence to show that giant chemical company Monsanto was appallingly negligent in the disposal of polychlorinated biphenyls (PCBs), now known to be cancer-causing “forever chemicals”, going back as far as the 70s.
Paul was happy to talk to us and let us know all about the part that FOI and WhatDoTheyKnow have played in his search for the facts — you can see his more than 200 requests for yourself, on the site.
Entering the public consciousness
He’s pleased that the programme has brought the topic that has been absorbing him for so long to the public eye: “For the first few years, everyone just assumed that I was making a fuss about nothing, and now it seems to have suddenly reversed.”
The first sign of that was a call from the TV production company, seeking evidence that they could shape the programme around.
If you’ve watched Buried, you’ll know that much of the programme is based around the meticulous records of whistleblower Douglas Gowan, now deceased. He had been an equally dedicated investigator into the issue, years prior, and Michael Sheen had interviewed him before he died.
“Michael had read an article in the Ecologist magazine that I contributed to in 2007, and that’s how he came across Douglas Gowan’s story. I managed to source him a briefcase full of Gowan’s papers, the one that we see in the TV programme.
“It had been very securely lodged, after his death. I’m not even allowed to say who with, but we managed to get access to it, and so it’s been quite a detective story, really.”
Don’t ask awkward questions
And that’s not the only dramatic detail: it was also mentioned in the programme that Paul was first alerted to the whole topic by one of his parishioners who had been involved in the dumping, on his deathbed:
“Yes. Well, more accurately, he had only a few months to live. And he asked to see me, so we sat over a pint, and he told me about all this night-time dumping that had been going on in Telford at Stony Hill, and how a driver had got some yellow crystals on his hand, and his hand broke out into an immediate rash.
“The poor worker, he’d felt very uncomfortable about this dumping, and he’d gone to the site manager and said, ‘What’s going on?’, and the site manager just looked him straight in the eyes and said, ‘You don’t want to go asking questions like that’.”
That was the start of it all, setting Paul off on his tireless campaign for truth. At what point did he realise that Freedom of Information was going to be useful?
“It’s been a steep learning curve. For the first few years, I very naively wrote to the various regulators, and they sent me their fob-off replies. And of course, there was nothing on the public record about that.
Putting information into the public arena
“So when I discovered WhatDoTheyKnow, it was a real breakthrough because I realised that if I asked authorities in public, they would realise that their responses were going to go on the public record. So they were less likely to lie to me. And with it being on the public record, future researchers could could follow up on stuff that I may have missed.
“I mean, it’s such a big subject. I suspect people in 50 years will be doing studies of what I’ve uncovered. Not to be pompous. I’m just being honest about the importance of it all.”
Paul soon realised he could do more on WhatDoTheyKnow than just lodge requests.
“Another benefit is that I can do searches on the relevant terms to see what other people have requested on the same subjects.
“But also, one of the lovely things has been to be able to put an enquiry with one regulator on WhatDoTheyKnow, and then forward that to another regulator to say, ‘You weren’t telling the truth, were you? Because these other people have said something so different’. That kind of-cross referencing has been incredibly valuable.
“That approach forced some information out of the Mines Remediation Authority, including the existence of some secret testing that had been done below the Stoney Hill site at Telford, which no one had told me about, so that was brilliant.”
But it hasn’t always been so easy.
Now you see it…
“A lot of the key lorry manifests from Telford, which was the first site I looked into, went missing. The Environment Agency’s Shrewsbury office had shown me them in person, proving that a lot of the dumping into this site in Telford had been done from the two Monsanto plants at Newport and Ruabon. And then when I asked to see them again, lo and behold, they’d gone missing.
“They said that they’d sent them to Telford Council, and Telford Council said, ‘We haven’t received them’. So I had two FOI requests, which said mutually contradictory things, and you just feel like locking the two parties in a room and saying come out when you’ve made your minds up!”
The discoveries are still coming.
“Only two weeks ago, we unearthed a 1,100-page document which shows that Telford Council have known all along how bad the site was, and that the site linings aren’t even non-porous because a cheap load of colliery spoil was used to line the bottom.”
Sometimes, the results of an FOI request have been quite surprising.
“I’d done a request about Cefn Mawr in North Wales — which features in the programme — and the answer came back with the information I’d asked for.
“But there was more information included, about the American Monsanto court case, and I thought, ‘That didn’t need to be included in the answer’. So, I believe a whistleblower managed to get out to me a piece of information that they knew I was looking for about an American court settlement. That’s somebody very honorable, who knows the significance of that document, and that’s why they’ve given it to me.”
As you can tell, Paul has been extremely meticulous and tenacious in his investigation. The circumstances of the toxic dumps haven’t made the job any easier, either:
“A lot of it was dumped at night, so isn’t recorded, and a lot of it was dumped in the early 1970s before the Control of Poisonous Waste Act came in, in ’74.
“So there was no stipulation to do it particularly carefully in most cases, and it’s left a really nasty legacy. A lot of the dumping was done in barrels, and the barrels are now rusting, so the stuff’s leaking out.
“A whole load of councils seem determined to avoid classifying the sites as contaminated land because they’re worried about obligations that they feel may be put upon them, and unfortunately, they don’t seem to understand that the legislation clearly says that if councils that own some of these sites aren’t able to pay, then the polluter can be approached to pay.”
What happens next?
Perhaps this TV programme will be a turning point, beginning to bring justice to the people and the communities that have suffered such severe health issues?
“If you see it as a chess match, I’d say that we’ve finished the end of the opening game, and we’re now moving into the middle game. Even this last week there’s been so much happening [We spoke to Paul just over a week after the programme first aired]. A legal firm is recruiting for for a major class action, so I’ve been giving them my contacts, especially people who’ve got cancers. And very sadly, there’s quite a lot of child leukemias turning up near the different sites, as well, which we didn’t include on the TV because it’s a bit heavy and a bit personal.
“A national newspaper is pursuing the idea of a series of features about things which we just touched on but didn’t have time to develop in this series.
“Plus we’re preparing for two judicial reviews. One of those is is likely to be a challenge against DEFRA for breaching the Stockholm Convention regarding persistent organic chemicals and pollutants; and the other one is against Caerphilly Council because they’ve issued a report saying that Ty Llwyd Quarry, which featured in the series, isn’t contaminated land — but they haven’t even tested the layby that’s known to have PCB in it, and they haven’t tested the river below the nearest village, Ynysddu, which we know from previous tests that there’s PCB in the bed of the river for at least three miles downstream. So, why aren’t they testing those miles downstream?”
Hopefully, this important work will continue to have significant outcomes. Many thanks to Paul for taking the time to share his remarkable investigation. If you’d like to help see justice done by the victims of the toxic waste dumping, look out for Paul’s crowdfunder page, coming soon — we’ll drop a link here as soon as it’s live.
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Image: Ilya Yakubovich
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The government is looking at whether public bodies should have more freedom to charge for access to their data, and we’ve responded to its call for evidence.
There are good reasons to be cautious about this. Peter Wells has written about some of them: charging reduces the number of people who can make use of public data, while adding new costs around licensing and administration.
In our fragmented public data report we recognise that public bodies can already spend considerable time publishing data without seeing much evidence of what happens to it afterwards. Where that data is difficult to find or combine, its potential value isn’t realised and the people doing the work have less reason to see publication as worthwhile.
Charging offers one answer to this, in that income is easy to demonstrate, but it decreases the overall value and impact of the data. We’d rather see the government get better at making the wider impact of open data visible: who uses it, what they build with it, where it is reused elsewhere in government, and what difference that makes. Better impact tracking would help teams make the case for investing in open data without needing to turn it into a source of income.
There’s also a longer-term problem with using charging to fund new data services. If a team is encouraged to generate income from its data and does so successfully, that income starts supporting the service. At that point, making the data open means finding the money somewhere else. The Postcode Address File is a longstanding example of how difficult this can be to unwind. Once licensing income becomes part of how a service is funded, opening the data and replacing that income become the same problem.
This is why we’re wary of encouraging individual public sector teams to become ‘entrepreneurial’ and develop their own income streams from data. If a new dataset turns out to be particularly useful, we’d rather that provided evidence for investing in it as shared infrastructure than a reason to keep charging for access to it.
The government has identified a real problem: it can be difficult to make the case for spending money on open data when the benefits are spread across lots of different organisations and users. We think this could be tackled through better shared infrastructure and impact tracking, rather than making public data pay for itself, which would only limit its reusability and lock it away in the long term.
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Photo by Mathieu Stern on Unsplash
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Scrutinising governments’ use of AI is turning out to be one of the pressing demands of our time, so we’re very glad to have received funding from the Joseph Rowntree Charitable Trust that allows us to conduct meaningful and sustained work in this area. The project has already kicked off with fact-finding, consultation and exploration, and will culminate in the creation of a service for civil society, journalists, authorities — and individuals affected by AI-based decision-making.
Artificial intelligence systems are increasingly used in democratic decision-making from welfare and healthcare to policing, with significant potential for both positive and negative impacts on individuals, society and the environment.
The effective use of data-driven AI systems in government and the public sector could transform the delivery of public services and support evidence-based policymaking, bringing benefits to citizens, saving costs and driving policy innovation across many domains.
But a data-driven algorithmic approach also has known risks, including that of reproducing or even amplifying unfair or discriminatory outcomes that are represented in the source data. We want to know how transparent evaluations of AI deployment in government can support both effective use and democratic accountability.
This is not an abstract question, nor one for a distant future. A recent LGA survey revealed that a significant percentage of local authority respondents are using AI in health and social care — 44% of them in services for adults, and 31% in services for children. Large Language Model (LLM)-based tools are being piloted across diverse applications in government, from social housing and planning to the DWP.
As a new generation of LLM AI systems come into use in which the rules of operation are not explicit, explanations of behaviour are challenging, and training data is not available, the need to both assess and demonstrate the fairness, performance and value of systems through adequate and transparent evaluation of their effectiveness and impact becomes much more important.
Across the two year span of this project, we’ll work with others to tackle the practical questions of how we collectively evaluate government AI systems and their impact in a way that supports fairness and benefits society as a whole. Based on this, we’ll go on to develop an accessible digital service, fostering transparency and accountability where AI systems are used.
That last bit is crucial: this is not just a research project. The initial discovery will ensure that the service is designed to be as effective as possible, with primary users being civil society organisations and journalists, alongside public authorities learning from their peers — but it will also be designed with public participation in mind, providing structured pathways for affected individuals.
We’ve started already. Last week, we shared the outcomes of a roundtable, the first activity in this project, helping us to understand what useful infrastructure already exists for scrutiny, where the gaps are, and where there are shared needs across civil society.
There’s plenty more to come: watch this space, and do sign up for updates (check “artificial intelligence” as an interest) to receive our newsletter direct to your inbox.
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Image: Jamillah Knowles & Digit via Better Images of AI (CC-by 4.0)
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Governing Freedom of Information in the UK
Tl;dr: the governance model of the ICO is changing and FOI isn’t well-represented in their new strategy. Here is how it could be made better.
Freedom of Information gives us the power to ask public authorities for information about their work. It has been used to uncover wrongdoing, scrutinise how public money is spent, and give communities the evidence they need to hold public bodies to account. Also, when public servants know that their decisions and records may be subject to public scrutiny, this can encourage better record-keeping and more accountable government in the first place.
Effective Freedom of Information systems require effective oversight. The UK’s Information Commissioner’s Office (ICO) has substantial legal powers, an experienced FOI team, and a well-established role in resolving complaints and improving public authority practice. However, there are longstanding questions about how FOI is governed within an organisation whose much larger responsibility is data protection.
The transition to the new Information Commission brings those questions into sharper focus. FOI plays a relatively small part in the proposed corporate strategy; specialist FOI expertise is not obvious within the new governance arrangements and the FOI function continues to depend on government funding at a time of increasing demand.
There are different ways these problems could be addressed. The new Information Commission can do more to give FOI strategic clarity, visibility and support within the combined regulator. Parliament can play a stronger role in scrutinising and supporting the FOI function, including how it is resourced. And, more fundamentally, FOI regulation could be separated from data protection altogether.
For an example of the last approach, we can already see this in the UK with the Scottish Information Commissioner (a dedicated regulator for the Scottish FOI system, appointed and funded via the Scottish Parliament). This arrangement does not need to be exactly replicated, but the new Information Commission needs to show how it can deliver the same kind of strategic clarity and agenda, and build a constructive relationship with Parliament on securing this important constitutional right.
If FOI remains within the new Information Commission, the challenge is to demonstrate how the combined model will deliver those conditions in practice.
What does effective FOI oversight need?
The existence of a legal right to information does not by itself guarantee effective access to information. FOI depends on an effective regulator.
Our 2022 Improving Oversight of Access to Information report looked at how information rights are regulated across Europe. It found that regulators need sufficient independence and resources to put their powers into practice, specialist knowledge of Access To Information law and practice, and good information about how the wider FOI system is working. This allows them not only to resolve individual complaints, but to identify where problems are occurring and intervene strategically.
The way a regulator is governed matters to its ability to do this. Its institutional purpose needs to be clear, expertise on Access To Information needs to inform its leadership and strategy, and its resources need to reflect the scale of the job it is expected to do. There also needs to be meaningful accountability for whether the regulator itself is delivering an effective FOI system.
These conditions are particularly important when FOI is one function within a much larger regulator. The Information Commission’s data protection responsibilities are substantially larger than its FOI role, with different funding arrangements, professional networks and regulatory priorities. Without deliberate arrangements to protect the strategic position of FOI, there is a risk that it becomes secondary within the priorities, governance and resources of the wider organisation.
This is the challenge facing the new Information Commission. It is not enough for the Commission simply to retain the ICO’s existing FOI responsibilities and powers. The new governance arrangements need to demonstrate how their FOI function will have the expertise and resources necessary for the regulator to use those powers effectively and improve the operation of the UK’s FOI system as a whole.
FOI within the new Information Commission
The new corporate strategy
FOI only plays a small part in the draft corporate strategy, and is not well-represented in the key strategic objectives.
There is a proposed objective for public authorities to be “transparent and provide public information openly and on time”. The suggested measurement framework also includes FOI compliance and complaints data, alongside qualitative evidence from FOI practitioners. Measuring the health of the wider FOI system is vital: our previous research demonstrates that regulators need to better understand more than just the complaints which eventually arrive with them.
However, considering the strategy more broadly, FOI is not well-represented. In particular, it is not always clear how the Commission’s wider strategic priorities and activities apply to its Access To Information responsibilities.
This may partly reflect the origins of the strategy itself. The Data (Use and Access) Act creates new requirements around the Commission’s strategy for data protection, while FOI legislation does not create an equivalent requirement for a dedicated FOI strategy. The ICO has previously operated with a distinct strategy for its FOI work; this should be revived.
FOI expertise within the new governance structure
The move from a single Commissioner to a Board creates new opportunities to bring a wider range of expertise into the organisation’s strategic governance. Seven non-executive members have now been appointed to the new Information Commission Board. They bring a range of experience; however, none of the members’ biographies identify specialist experience focused on information rights. FOI expertise is similarly not prominent in the published recruitment material for the new Chair.
It’s not necessarily the case that a seat on the Board needs to be reserved for an FOI specialist, but this does raise a practical question about how the Board will gather specialist Access To Information expertise and maintain strategic oversight of this part of the Commission’s responsibilities. Looking to Scotland, the Commissioner is appointed with a clear FOI remit and is expected to have experience with relevant legal/public sector matters.
Resources and independence
Funding is another longstanding issue for FOI within the ICO. Unlike much of the ICO’s data protection activity, which is funded through fees, its FOI responsibilities are supported through government grant funding. This creates an unusual relationship in which the resources available to enforce information rights against the government are ultimately determined through the government.
This has previously had practical consequences. In evidence to Parliament in 2021, the then Information Commissioner Elizabeth Denham linked resource constraints to the ICO’s ability to take enforcement action, noting that its FOI funding had fallen substantially over the preceding decade. Our comparative research subsequently identified the UK as an example where a regulator has extensive formal powers but their practical ability to deploy them could be constrained by resources.
It is important to recognise that the ICO’s performance on FOI has improved in recent years. However, we must not take this progress for granted – and the ICO is currently warning that at its current funding level increased pressure on the complaints system is increasing the size of the backlog and delays before cases are allocated. Giving evidence to the House of Commons Procedure Committee, Warren Seddon (Director of Freedom of Information and Transparency) – highlighted the increase in volume and impact on response times:
In the last 12 months, we saw our intake increase by 16% in Q1, 38% in Q2, and then 60% in Q3 and Q4. That is in a context where, historically, over two decades of the FOI Act, you see a 20% to 25% increase every five years. We have seen a massive surge in the number of complaints in the system. Although the evidence is not there to pull that apart in detail, I think AI is probably driving that.
[..]In terms of the impact on performance and how the system is working at the funding levels that we are seeing coming in right now, there is a real concern from our perspective about where we will end up. We are projecting at the moment that, by the end of this financial year, it will take about 16 months to allocate a case, which is not good from our perspective.
In a response to an FOI request, the ICO highlighted both the increase in workload and that they have been unable to secure an increase in budget to reflect this:
[D]espite bidding for more resource to recruit more staff at the last Comprehensive Spending Review (CSR), this was not successful. We continue to engage with government on this issue, but as a result, we currently anticipate allocation and wait times will continue to grow as approximately 400 excess cases a month are being added to our caseload.
Improvements to processes and technology may all help the regulator use its existing resources more effectively, but there is a limit to how far operational improvements can compensate for a sustained mismatch between workload and resources.
Responding to the Information Commission strategy
The current consultation on the Information Commission’s corporate strategy provides an immediate opportunity to strengthen the place of FOI within the new organisation.
The draft strategy includes an outcome focused on public authorities being transparent and providing information openly and on time, as well as proposals to use compliance, complaints and practitioner evidence to understand FOI performance.
However, it is less clear how these commitments connect to the wider strategy: how the Commission will use its regulatory powers and resources to achieve this FOI outcome, how progress will be scrutinised, and how the experience of people using FOI will inform its approach.
Proposals to strengthen the strategy:
- Explain how the corporate strategy applies to the Commission’s FOI work. The inclusion of an outcome on public authority transparency is welcome, but it is not always clear how the wider priorities in the strategy apply to the Commission’s Access To Information responsibilities. The final strategy should make clearer how the FOI outcome connects to regulatory priorities, activities, enforcement and resources.
- Commit to a dedicated FOI strategy. A more detailed Access To Information strategy sitting underneath the corporate strategy could explain how the Commission intends to approach casework, enforcement, systemic intervention, public authority compliance and the wider health of the FOI system.
- Measure the health of the FOI system from both sides. The proposed use of compliance, complaints and practitioner evidence is welcome. This should be complemented by evidence from requesters, alongside measures covering areas such as timeliness, disclosure, internal review and appeals. This would give the Commission a fuller picture of how FOI is working, beyond the cases that eventually reach it.
- Connect FOI ambitions to the resources required to deliver them. The Commission’s commitments on public authority transparency need to be supported by sufficient capacity within its FOI function. The final strategy should make clearer how the Commission will assess the resources required to meet its FOI responsibilities, particularly in the context of changing complaint volumes.
- Explain how FOI will be overseen within the new governance structure. With the move to a Board, the strategy could provide greater clarity about how specialist access-to-information expertise will inform decision-making and how the Board will scrutinise delivery of the Commission’s FOI responsibilities.
- Make engagement with FOI users and civil society more concrete. Continuing structured engagement with requesters, journalists, civil society and practitioners would give the Commission access to different perspectives on how the system is working in practice.
A stronger role for Parliament
Beyond the scope of the consultation, Parliament should play a greater role in supporting the independence and sustainability of FOI oversight.
Freedom of Information is a right created by Parliament, and the Information Commission is responsible for enforcing that right against public authorities, including the government itself. There is a reasonable argument that Parliament should have a stronger role in ensuring that the regulator has the resources it needs.
There are possible models (along the lines of the approach taken for the Electoral Commission) where a parliamentary committee rather than a government department is the sponsor. The ICO would submit an estimate for its FOI work to a parliamentary body, supported by independent audit and scrutiny, before the funding was approved through Parliament. This would help insulate decisions about FOI funding from the government whose compliance the ICO is responsible for regulating. It could also give Parliament a clearer role in scrutinising whether the ICO has the resources it needs, and how effectively those resources are being used.
There are precedents for this kind of arrangement. A number of independent constitutional and scrutiny bodies have funding arrangements involving parliamentary committees rather than conventional departmental sponsorship.
In Scotland, the Information Commission is funded through the Scottish Parliamentary Corporate Body and is subject to parliamentary scrutiny of both its resources and its performance. The Commissioner appears annually before the relevant parliamentary committee to discuss the office’s annual report and operational performance.
A separate FOI regulator?
One option for creating greater institutional clarity around FOI is to separate out the responsibilities for Access To Information and data protection.
The case for separation reflects the increasingly different scale and focus of the two functions. Data protection has developed into a much larger regulatory field, supported by an international profession and increasingly complex regulatory responsibilities. Within a combined regulator, there is a risk that the smaller FOI function has less influence over institutional strategy, leadership and resources.
A separate regulator would make responsibility for FOI explicit. It could provide a clear institutional purpose, specialist leadership and governance focused specifically on the effective operation of the FOI system. The Scottish Information Commissioner demonstrates some of the practical advantages of this clarity: there is an identifiable regulator with a specific FOI remit and a direct relationship with Parliament around its funding and performance.
Separation may not fix all issues automatically. Our comparative research found advantages to both specialist and combined oversight bodies. A larger combined regulator should, in theory, benefit from shared infrastructure, resources and greater institutional weight, while a separate regulator without sufficient resources or independence would not necessarily provide more effective oversight.
The important question is what institutional arrangements best deliver effective FOI regulation in practice. If responsibility for FOI remains within the Information Commission, the combined model needs to demonstrate how it will provide the strategic clarity, specialist expertise, resources and accountability that separation could provide more directly. Government and Parliament, in turn, need to ensure that the wider funding and governance arrangements make this possible.
Where next?
The creation of the Information Commission is an opportunity to strengthen the governance of FOI. There are actions that can be taken now within the new Commission, including giving FOI greater strategic clarity, making responsibility for it clearer within the new governance structure, and ensuring that its ambitions are matched by the resources needed to deliver them.
There is also a role for Parliament. Regardless of whether FOI continues to sit within a combined regulator or is ultimately separated from data protection, Parliament can play a stronger role in scrutinising the health of the FOI system and ensuring that its regulator has the independence and resources it needs. The government also has a responsibility to ensure that the wider regulatory and funding framework supports effective FOI oversight.
The Scottish Information Commissioner provides a useful example of how governance, funding and accountability can be aligned around a clear FOI purpose. If FOI is to remain within the new Information Commission, it should be clear how the combined model will provide the same kind of strategic clarity and focus, alongside a constructive relationship with Parliament that supports the effective protection of the right to information.
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Photo by Maksym Kaharlytskyi on Unsplash
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The EIR is a similar set of rights to those we have under Freedom of Information, but specifically give access to environmental information held by public authorities.
Those who remember reading about the sewagemaps project in our blog post of last April will recall that the discharge of sewage falls firmly under the category of environmental information — and may be interested to see an update from the Information Commissioner’s Office (ICO) celebrating an increased an “open by default” culture from the nation’s water companies:
“All of the water companies we wrote to have now committed to proactively publishing information relating to start and stop times of sewage discharges.”
This follows an intervention to water companies from the ICO, reflecting the national mood around sewage discharges, and is a good example of how their regulatory powers can be applied.
“All water companies across the UK have a legal obligation to make information about the environment available under the EIR and are required to both respond to requests for environmental information and to make information available proactively.”
That initial ICO post explained that they had issued six water companies with decision notices requiring them to disclose the start and stop time of sewage discharges, and contacted all 12 CEOs of companies responsible for sewage services to “clearly set out our expectations that [discharge data] should be made available to the public.”
Our own blog post on the sewagemaps.co.uk project has been one of our most read and discussed this year, so we know it’s a topic our followers feel passionate about — a sentiment that’s in line with the nation as a whole. So we were keen to know more, and Deborah Clark at the ICO was happy to oblige.
What was the catalyst for this activity around sewage discharges?
“It was sparked by an increase in complaints we received about water companies and a series of decision notices we issued requiring disclosure of the start and stop time of discharges. This May 2024 document was the first of many decisions where we made our position clear that such information needed to be disclosed.”
Warren Seddon, Director of FOI at the ICO, described the steps you had to take in respect to one particular noncompliant water company — what did that entail?
“We specifically directed United Utilities to proactively publish frequently requested information, which includes historic data on sewage discharges, and to include it in its disclosure log. This was the first Practice Recommendation we have issued under the Code of Practice issued under regulation 16 of the EIR.”
And he also mentioned that you’re working with reluctant companies to show them how to achieve best practice in data publication.
“Yes — we asked the other water and sewage companies to publish the data in the interests of transparency. Here’s the relevant extract from the letters we sent:
In addition to providing timely and appropriate responses to requests for such environmental information, I strongly encourage you to proactively disclose appropriate information relating to sewage discharges on a regular, monthly basis. This proactive and timely publication of the information would not only provide this important information to the public more quickly and easily, but would also be more cost effective and efficient than dealing with the alternative of numerous responses to individual requests for the information.
How much power does the ICO have in this regard?
“This positive change was achieved through engagement rather than formal and specific regulatory action. Water companies are not required by law to publish monthly data.
“We are currently looking at what regulatory activity we can do to better support proactive disclosure provision at Regulation 4 of EIR [“The EIR require authorities to proactively make environmental information that they hold available to the public by electronic means”], but this work is at an early stage — so watch this space.”
Do you have any further advice for people who are frustrated by the sewage discharges they’re seeing in local rivers and beaches? What can they do, or should they be hopeful for change in the future as a result of this increased transparency from the water companies?
“Water companies are a lot more transparent now than they were a few years ago. We will continue to take an interest in this space and we’re involved in an EIR forum for water companies where we encourage proactive publication so this increased transparency should continue.
“At the ICO we’re concerned only with information rights, so that’s where we’re able to give advice; as a start, where possible check publication schemes and disclosure logs for relevant published information before making a request.”
Thanks very much to Deborah for taking the time to talk to us. If you’re interested in obtaining environmental information from public bodies, you should know that you can submit EIRs as well as FOI requests on WhatDoTheyKnow – there’s more about that here.
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Image: Mark McNeill
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Our website WriteToThem helps you contact your elected representatives, quickly and simply. In a recent blog post, we explained that we’ve added a Welsh translation across the site, and made it easier to navigate recent changes to the Senedd.
And while those improvements clearly have a great benefit for residents of Wales, the work has also introduced a couple of features that will help all users of WriteToThem, no matter where they are in the UK.
1. Extra help in getting the right message to the right place
If you live in an area with a devolved parliament, you have a lot of politicians representing you: not just your local councillors and an MP; but also Members of your nation’s parliament. For anyone deciding to make contact with a representative for the first time, this can be bewildering — who’s the right person for your specific message?
And to be fair, it’s not always straightforward even for those living elsewhere in the UK. For example, you might have both district and county councillors: do you know the difference? Likely not unless you’re a real democracy maven.
More people representing you might be a good thing, but when it comes to an individual wondering who best to contact about, say, bin collection, housing issues or the state pension, faced with a long list of potential recipients, it’s easy to just give up.
So how are we helping with that?
Once you’ve entered your postcode on WriteToThem’s homepage, the site displays a list of all the representatives you can write to, from councillors right up to Lords.
If you’re not sure which category of representative is right for your issue, there’s some brief guidance on the left of the page, explaining the top level of issues each is responsible for.
For more information, you can click “Not sure who to contact?” at the top of the page. By default, this takes you to an information page giving more information about every type of representative; but, as you’ve already input your postcode at this stage, it will only show you the information relevant to the representatives covering your area.
You can see this for yourself if you replace the postcode at the end of this url with your own: https://www.writetothem.com/about-yourrep?pc=LA1+2ES.
For those using the Welsh site, this guidance is also, of course, available in Welsh.
Watch this space, as we also plan to introduce help for those who are looking at a list of representatives within the same category (eg, several councillors or Assembly Members), and wondering how to choose which of them to contact.
2. A simple way for campaigns to mobilise their supporters
Are you working for a cause and want politicians to know about it?
Ever since its launch back in 2005, WriteToThem has been a useful (and completely free) tool for campaigners on a low budget. All you need to do is direct your supporters to the site and encourage them to get in touch with their representative/s.
If that sounds helpful, take a look at our guidance, which we’ve recently refreshed.
Even better, we’ve updated the code that lets you put a professional-looking widget on your site. This looks a lot smarter than just a plain link, and you don’t need to have design or development skills — just copy the html and put it on your web page.
We know that a lot of organisations don’t use WriteToThem to send messages: for them, the most useful part is being able to help their clients see who their representatives are, so there’s also the option to amend the widget so it says “find out who represents you”.
This widget can also be set up so that it toggles between English and Welsh, with your choice of what appears as the default.
There’s something else useful for campaigns, too: if you have a database of your supporters, including information such as their postcodes, you can make the path even smoother by sending a personalised link that saves them one or more steps in the email-writing process.
For example, if you know which type of representative you want them to contact, you can skip the screen where they have to select that; if you know their address, you can pre-fill those fields for them; and if you have their postcodes on file, you can take them directly to the letter-composing screen.
Finally, we’ve added information about building big impact locally, and evidence-informed campaigning, making use of some of the other free websites we run.
All of this is explained in more detail in our guidance, so if it sounds helpful, do take a look!
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Image: Dinah Makhmutova
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We think it should be easier to reliably answer the basic questions: what AI systems are public bodies using? How are those systems affecting people?
To help civil society actors work out how to get better answers to these questions, we brought together people working across academia, law, journalism, technology and public policy to discuss the challenges involved in scrutinising government use of AI.
We asked about what useful infrastructure already exists, and where the gaps are, and where participants identified shared needs across civil society.
The resulting discussion revealed a series of useful tensions: between collecting more information and making better use of what already exists; between understanding how a system works and examining what it actually does; and between involving affected communities and ensuring that governments remain responsible for proper oversight.
Do we lack information, or is it simply difficult to find?
In many cases we still do not have enough basic information about government AI use. Existing transparency mechanisms do not give us a comprehensive picture of which systems are being developed, trialled or used across government.
The UK government’s Algorithmic Transparency Recording Standard is widely seen as ‘good practice’, and could provide valuable information if used consistently, but we know that not every relevant system appears on the public hub.
Even then, the healthiest possible central register is unlikely to capture every way AI is used in practice. Alongside formally procured systems, staff may use generative AI for drafting, research, transcription or coding. Public bodies themselves may not have a complete overview of these kinds of informal AI use.
From some participants we heard that the problem isn’t actually lack of data, it’s what to do with the data. There is already considerable information available if you know where to look. Details emerge through procurement notices, court cases, policy documents, impact assessments, transparency publications and Freedom of Information requests. The problem is that this information is fragmented, and that it isn’t clear how to use it to influence the decisions made.
These are not necessarily opposing accounts. They point to several different failures:
- information that public bodies do not collect
- information that is collected but not published
- information held by private suppliers rather than public authorities
- information that is public but fragmented or difficult to find
- and information that is published without enough context to support scrutiny
- a lack of mechanisms for collating and effectively using information on impact
Saying that we “need more data” risks collapsing all of these problems into one. Before deciding on a solution, we need to understand where in the chain the information is being lost.
What counts as AI, and does the definition help us?
We debated how important it is to define what we mean by AI. There’s a risk that by focusing too much on what is or isn’t AI, we offer a get-out clause. A public body may argue that a system is not really AI, or has a human checking its output, therefore there is no cause for concern.
The example of an AI transcription tool used in social care was raised. On paper, transcription might look like a low-risk administrative task. In practice, the resulting record could influence how a conversation is understood and what decisions are subsequently made about a child or family. These transcribed accounts could become really important later down the line. Similarly, an AI tutoring tool may not make formal decisions about pupils, but its widespread use could still have major effects on children’s education.
Rather than waiting for a perfect definition of AI, it may be more useful to ask what the technology is doing, how people use its output, who is affected and what happens when something goes wrong.
How should we evaluate these systems?
In the room there was a lot of agreement around the need to focus on evidence about how the systems work in reality, how they affect real citizens, and especially the most marginalised.
However ‘evaluation’ can mean different things to different people. The existence of an evaluation does not necessarily mean that meaningful scrutiny has taken place. For example, technology suppliers may assess their own products using benchmarks that make sense to developers but not to the wider public or civil society. A claim that a system is “98% accurate” is difficult to interpret without knowing what was tested, which mistakes make up the remaining 2%, who experiences those mistakes and what the consequences are.
There is a risk of “evaluation washing”: the language of evaluation lending legitimacy to a system without answering the questions that matter.
What kinds of context help make an evaluation meaningful? Perhaps it should consider not only technical performance, but how a tool interacts with staff, existing services and the people affected by it. A decision-support tool may perform well in a controlled test but operate very differently when used by overstretched staff who have little time or authority to question its recommendations.
As part of this conversation about a focus on what systems actually do, there was some disagreement about how much attention should be paid to explaining how systems work. Focusing on impact helps rebalance the conversation towards what actually happens to people, but technical information can be necessary for researchers, lawyers and affected individuals in some cases. It may help explain why errors occur, whether particular groups are treated differently and where responsibility lies for this.
Connecting official records with frontline experience
Official records can tell us what public bodies say they are doing, but this is really brought to light by frontline organisations who can help reveal what happens in practice.
Caseworkers are often among the first to see the effects of new technology. They may encounter individual cases that appear isolated but form part of a larger pattern. We heard a powerful example from the domestic violence sector when 20 charities each reported one instance of a new trend: this helped both reveal the recurring issue and suggest a possible solution that no organisation could identify alone.
However, organisations do not always know what to look for or how to establish whether AI has contributed to a new problem. Changes may first appear as an unexplained decision, a new administrative barrier, or a small but specific reduction in service quality. Better connections between frontline organisations and more technically minded organisations could help turn these scattered experiences into evidence of systemic problems.
We heard some debate about how much to involve affected communities. Whilst real people should be at the heart of our thinking, participation must not transfer too much responsibility onto communities, especially those already vulnerable. People should not need to become experts in every system affecting them in order to be protected. Public bodies remain responsible for demonstrating that the technologies they use are appropriate, safe, fair and effective. Public participation should strengthen oversight, not replace it.
How do we move forward?
What would we like to see?
- We need to know what systems public bodies are developing and using, and for this to be reported as structured data. Reporting hubs for this purpose exist but are not well-used.
- We need information early enough for people to influence decisions, not after a system has been introduced. This requires better transparency throughout procurement and design processes.
- We need evaluations that examine real-world outcomes rather than relying on abstract benchmarks. Civil society has a role to play here in shaping these evaluations.
- We need practical ways to use that evidence to challenge individual decisions and wider patterns of harm. This requires sector-wide collaboration to share knowledge, cases, challenges and successes.
The task is not simply to publish more data (although that is a key request to public bodies). It is to connect official records with real-world experiences and create meaningful routes to challenge and improve. Transparency matters because of what it allows people to do.
Huge thanks to everyone who participated in this roundtable discussion. We’ll be using the outputs to help shape our future research and digital service development in this area.
This roundtable formed part of work supported by the Joseph Rowntree Charitable Trust.
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Image: Jamillah Knowles via Better Images of AI (CC-BY 4.0)

