Can you bring about more transparency with a simple map?

Apparently yes – that’s what the Alaveteli site Transparencia.be have pulled off with their interactive map of Wallonia.

This shows which municipal councils in the region are making useful documentation publicly available ahead of their committee meetings.

If the district is coloured green, they’re proactively publishing the documents; amber shows that they are publishing, but only on request; and red indicates a complete lack of publication. A decree going through Belgium’s lawmaking procedures will require such proactive publication, and while some are ahead of the loop, others have a way to go.

 

“The law is going through the last phase of regional parliament”, said our contact at Transparencia, Claude Archer, last week. “Lawmaking is slow, but this does now look like it’s reached the final step.” 

And that progress would have been even slower if it weren’t for Transparencia’s efforts. That it has come this far, says Claude, is “a direct consequence of the heatmap. The heatmap forced them to go faster and not to forget the decree. We’re two years away from the next local election, so we have to keep pressure up if we want to see results!”.

Informing citizens

Municipalities must publish an agenda ahead of their meetings, but this is often very concise and the titles of the various points aren’t always self-explanatory.

The heatmap forced them to go faster and not to forget the decree.

And minutes of the meeting are shared afterwards — but by then it is, of course, too late for an interested party to intervene. For the sake of transparency, the ideal is to provide citizens with a bit more detail before meetings go ahead.

This isn’t a huge burden: it only requires the councils to publicly share documents that they would already be preparing for councillors — a summary of the topics to be discussed, and the ‘draft deliberation’, which gives a rough indication of what is likely to be said during debates.

This pre-publication would allow citizens to see if a topic they are interested in was about to be discussed or voted upon. They might alert their representative if they see any factual errors in the proposed points of debate, says Claude in a news story published by the popular Belgian daily Le Soir. But he adds that it would also be “a symbolic measure, [showing] that democracy is everyone’s business and not just that of elected officials”.

Gathering data

So, what does this map do, and how did Transparencia create it?

Transparencia used Alaveteli Pro to obtain the underlying data for this project. Claude explained how it has had such a decisive effect on the local municipalities’ commitment to transparency. If you run your mouse over the map, you can see that for each municipality, it says whether or not they are publishing documents ahead of council meetings. There are 262 municipalities in Wallonia, and for each one, an FOI request was sent to ask what their policy is around these documents (examples can be seen here – in French).

It’s the number one topic of conversation within the municipalities every time we update the map.

The data-gathering has taken more than two years, and has grown beyond a project of a small transparency organisation – they’ve extended their reach by training up journalists and showing what can be done with data from FOI requests. This has been an interesting exercise in itself, says Claude, who notes that while Transparencia are more about using FOI for activism, journalists can use it in their ‘everyday generic investigations’. And of course, journalists are the ones who can get stories in front of readers.

Alaveteli Pro is the add-on for Alaveteli sites, providing a suite of features for professional users of FOI — here in the UK we run it as WhatDoTheyKnow Pro, but the same functionality can be added to any Alaveteli site. Among these features is ‘batch request’, which eases much of the hard work involved in sending FOI requests to a large group of authorities, and managing all the responses.

Claude explains that Transparencia made the first wave of requests themselves, but they sensed that the project would get more leverage if it belonged to a couple of prominent newspapers, Le Soir and Le Vif. “We gave them ownership even though the project was instigated by Transparencia.”

Divide and conquer

So, for the second wave, “We divided the country into six regions. We allocated one journalist to each region and they made batch requests to the municipal councils in that region through their Pro account. We then exported the spreadsheet from the batch requests and from that we could build the maps with a bit of Python code and boundaries in a GIS system.”

And what’s the result when the municipalities see the map? “They don’t like being red or orange when their neighbour is green,” laughs Claude. “It’s the number one topic of conversation within the municipalities every time we update the map, and it makes a lot of new municipalities join the commitment to publish.”

Breakthrough

So things were looking positive — and then, yesterday, we received an ecstatic update from Claude. “Exactly one year after Transparencia’s hearing at the regional parliament, and six months after publication of the heatmap in the press, the Walloon parliament passed the bill this afternoon in the special commission, and it will be officially adopted 15 days from now.”

Pop open the bubbly, that’s a win for transparency; and it’s not just Claude who thinks so: “I have just proudly received a congratulatory text from the head of the Green Party, Stéphane Hazée, at Walloon regional parliament”, he tells us, sharing the screenshot:

(Translation: Just a word to inform you that the proposal for the ‘publicity decree of municipal councils’ was adopted this Tuesday in the PW committee. Thank you again for your involvement which clearly helped to convince. Sincerely.)

We’re always pleased to see our tools being used to bring about tangible change; and increased local transparency is something that’s very much on mySociety’s mind at the moment, as you can see in our work around climate.

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Image: Pierre André Leclercq (CC BY-SA 4.0, via Wikimedia Commons)

We’ve recently added lots of Business Improvement District (BID) organisations to our Freedom of Information service WhatDoTheyKnow.com. 

BIDs are directly funded via business rates. They spend public money, and have a significant impact on important public spaces, but are generally not subject to Freedom of Information law. 

We are listing BIDs on WhatDoTheyKnow because we think they should be subject to the Freedom of Information Act. WhatDoTheyKnow is not only an FOI service: we also actively seek to expand the scope of access to information law, and will add bodies to the site if it is clear that they should be open to public scrutiny.

Business Improvement Districts were introduced via Part 4 of the Local Government Act 2003. 

Most BIDs are focused on shopping streets, but there are others which work around industrial estates, and a handful seek to boost the tourism sector in their areas. 

BIDs’ activities vary from body to body. Examples include:

• Croydon BID funds police officers and specific police operations (Team London Bridge BID has a similar programme) 
• MyMiltonKeynes has street cleaning and pest control projects.
• Halton Chamber Enterprises Ltd, which runs the Halebank and Astmoor Business Improvement Districts, provides defibrillators 
• Brilliant Brighton runs Christmas light displays, and provides hanging baskets and bunting. 

The establishment of a BID requires the support of both: 

1. the majority of business rate payers in the relevant sectors and area, and
2. those representing a majority of the rateable value relating to the votes cast.

The local council responsible for collecting business rates may veto a proposal for a BID, but once it has been approved the council is required to collect the “BID levy” alongside business rates and pass it on to the BID organisation.

While these ballots provide a democratic mandate for BIDs, the ability to scrutinise how a BID is run during its period of operation is important so that people can assess the performance of these organisations and assure themselves that the public money they are responsible for is spent appropriately.

BIDs can increase the level of influence businesses have in their areas of operation. One argument in favour of BIDs is they correct for an “influence gap” arising due to the fact businesses don’t have a vote when it comes to electing local councillors. On the flip-side of that, BIDs can be argued to reduce the ability of local residents to influence projects relating to their local shopping streets, or other areas of BID activity. 

A recent report from the lottery funded Power to Change Trust on the operation of BIDs stated: 

“Business Improvement Districts (BIDs) have proven successful in involving businesses in the development of local economies, addressing a previous influence gap – but there is no parallel system for residents to participate, other than via indirect means with their local councillor or planning system. This leaves those who have ideas about how to shape their places without a strong voice.”

While listing BIDs on WhatDoTheyKnow won’t directly give people a greater say in how BIDs which impact their local areas are run, greater transparency will hopefully enable informed lobbying, better quality media reporting, and enable those running the organisations to be held to account. WhatDoTheyKnow is open to all, anyone with an interest in the operation of a BID, be they a local resident, a levy paying business, or anyone else, is welcome to use our service to request information from a BID.  

All public bodies which receive funding via council tax, such as parish councils, Police and Crime Commissioners and Fire Authorities are subject to FOI. It seems right that bodies funded via a levy collected as part of business rates should also be subject to the Act.

Enabling people to request information from BIDs in public, and automatically publishing any responses, will hopefully improve the transparency of these organisations. If there are refusals to provide requested information, these may be cited by those who, like us, think that BIDs should be made subject to the Act. 

A new approach to developing the public body database

We are currently listing around 300 BIDs on WhatDoTheyKnow. 

At the time of writing we don’t hold an email address for around 120 of them. If anyone seeks to make a request to those we don’t have an address for, they will be prompted to look for an email address for us to use, and let us know if they find one. 

To-date, we’ve generally avoided listing bodies without email addresses, although doing so would closely copy a model that’s worked well on mySociety’s WriteToThem site for many years — where someone wants to email their MP or councillor and we don’t have an address, we will ask users to see if they can find the required details. 

For WhatDoTheyKnow, this is an experiment to see if listing bodies without an address encourages users to find them for us. We hope to experiment with more nudges like this, to see if they motivate users to help us keep our database updated — thus spreading the load of a task that would otherwise take up quite a bit of our time.

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Image: Artur Kraft

We’ve recently been considering whether we should add individual courts to WhatDoTheyKnow.com, so that users could make FOI requests to them in public. Doing so would certainly align with our wider mission of making it easy to access information from public bodies; but there are also some clear reasons against their inclusion. 

In this post we’ll examine both sides of the issue. But first, some context.

At the moment, FOI requests for information held by courts can be made via the listing on WhatDoTheyKnow for the courts service, HMCTS. Individual courts are generally not considered to be authorities in their own right, so this would mean adding bodies that are not strictly subject to FOI themselves — which is not a new concept for us: we will often list parts of public bodies separately if we think this will help our users.

Transparency is particularly important when it comes to courts, as they exercise the power of the state and their decisions can have huge impacts on individuals, organisations, the environment and society. 

In favour of listing individual courts

Further to our general principle that it is good to give access to governmental bodies serving the public, there are some more nuanced reasons to include courts in our listings:

• Requests often end up there anyway. On receipt of a request better answered by a local or individual court, HMCTS will often forward it to them, or advise the request-maker to contact the court directly themselves. The FOI process may be quicker and more efficient for all parties if requests are just sent directly to the court in question.
• It would serve an educational purpose Listing courts individually would promote the fact that FOI requests can be made for information held by courts.
• Information can be obtained from courts via FOI. Statistics, information on spending, details of room usage etc. could all be requested from courts, and we would expect such requests to be successful. Section 32 of the FOI Act exempts court records, meaning they’ll just refuse an FOI request for these, but you should be able to access other information that they hold.
• Separate requests may not trigger the cost limit Under Section 12 of the Act, authorities can refuse FOI requests if it will take them more than a certain number of working hours to provide the information. Requests made to a series of individual courts may not be aggregated for the purposes of considering the cost limits, and more information may be obtained via a series of requests made to individual courts than would be obtained via a request made to the court service centrally.

Against listing individual courts

There is really just one substantial reason against listing courts, but it is important and we give significant weight to it:

• Courts may release sensitive information When authorities respond to a request made through WhatDoTheyKnow, the information they release is published on the website. But there are rights other than FOI that give access to information from courts, eg section 5.8 of the Criminal Procedure Rules and Part 5 of The Civil Procedure Rules 1998. Court officers may consider that, due to these provisions, they are required to release information which it would be irresponsible, and sometimes illegal, to publish in response to requests made through WhatDoTheyKnow.

In conclusion

Having worked our way through these pros and cons, we conclude that listing individual courts on WhatDoTheyKnow is currently high risk, and probably not the best way to pursue greater transparency from the court system.

As in other areas, rather than improving the way requests for information are handled, proactive publication of material such as information on cases before courts, and their outcomes, would be preferable. Information which it is not appropriate to publish should be separated from other material by the courts service.   

Another approach is to make FOI requests to bodies such as the police, for material they have presented to courts, and such requests may well be successful. 

It is worth noting that there are currently three courts listed on WhatDoTheyKnow:

• Supreme Court of the United Kingdom
• The High Court of the Justiciary, which is the supreme criminal court of Scotland.
• The Judicial Committee of the Privy Council

Due to the nature of the work that these courts undertake, we believe they are lower risk listings than others. In the case of the Supreme Court they do even have their own FOI contact point and publication scheme, so should be used to responding responsibly and appropriately to FOI requests.

If you want to join the discussion of the question examined in this post, you can do so on the public “ticket” for this issue on GitHub, or you can contact the WhatDoTheyKnow team.

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Image: Tingey law firm

We recently became aware of extensive misuse of our Freedom of Information site WhatDoTheyKnow, in connection with the academic status of Taiwanese politician Dr Tsai Ing-wen.

This activity became apparent through a very large quantity of correspondence being sent through the site, all focusing on the validity of Dr Ing-wen’s qualification from the London School of Economics and Political Science (LSE). 

The majority of this material was repeating the same or very similar FOI requests, and some were not valid requests at all. We also saw mass posting of annotations, some on completely unrelated requests, and new requests which copied the titles of unrelated existing requests in an apparent attempt to evade our attention.

Running the service responsibly

As an organisation, we positively and passionately support the citizens’ right to access information and to hold organisations accountable: this is the very foundation that WhatDoTheyKnow is built upon, and its reason for existing. 

Over time, we’ve formulated and consolidated policies to ensure that information on the site is preserved, as far as possible, as a permanent archive. We robustly contest unjustified requests to remove material from our service, and will only remove any substantive Freedom of Information requests and responses if we absolutely have to. 

We initially treated this misuse assuming good faith, putting significant effort into removing problematic material from correspondence while continuing to publish elements which could have amounted to a valid Freedom of Information request. 

Understanding the problem 

Several users took the time to report the misuse of our service to us, for which we are thankful. As a matter of course, we review all material reported to us and assess it before making a decision on what to do. It took our small team of staff and volunteers a significant amount of  time to respond to the number of reports made in this case.

Researching the topic more deeply, we discovered a statement from the Information Commissioner on requests they’ve also received on this subject, in which they say:

“The intent of these requests is clearly to try to add weight to theories around the falsification of President Tsai’s PHD, which have already been considered at length by the Commissioner and the Tribunal and found to be entirely lacking in substance.”

Further, both the LSE and the University of London have published their own statements, and a copy of the PhD thesis in question is now available online via LSE’s website. 

While rejecting one FOI request on this subject as vexatious, LSE raised the possibility that people in China could be making requests to benefit from the country’s citizen evaluation system, stating:

“We have been made aware that there is the possibility that the LSE has been added to a list of targets to gain social credits in China. As such we believe that your request and the others we received in this time period have not been made for just the purpose of receiving information but for personal gain.” 

With this information in hand, we were confident to treat the issue as mass misuse, more akin to spam or even a disinformation attack than to people making misguided requests.

Taking action

During the course of this situation, we have banned 108 user accounts, most of which have been created to circumnavigate previous bans and to post inappropriate material to our site. We removed more than 300 requests from the site and 1,640 comments from pages. 

To put this in context, we only banned 126 newly created user accounts in the whole of 2021, mainly for spamming (see more details in our 2021 Transparency Report). 

Current approach to the misuse of service

As a result of this misuse we are taking the following actions. 

While we will continue to adhere to our reactive moderation policy in most instances, we may occasionally review activity by new users while this incident is ongoing. When we are alerted to correspondence on the subject in question, we will not be taking our usual approach of trying to preserve any valid FOI request contained within broader correspondence. We will instead make a very quick assessment of whether it appears to be a genuine request for information or part of the concerted misuse campaign, in which case the request will be hidden.

The users making these requests will then be banned without warning or notification. The same will apply to any comments being made on existing requests. It will be up to any users that are banned in this process to make a case to us that they are making genuine FOI requests.

This approach is in line with that we have taken in other instances of misuse of our service.

We have also enabled enhanced anti-spam measures on the site, which will help us deal with other instances of misuse more efficiently.

We may never fully understand what exact circumstances instigated this wave of misuse, but it has been instructive, and has helped us formulate new ways to tackle the always surprising means by which our work – to help citizens make valid requests for information in public – can be temporarily derailed.

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Image: Olga Safronova

The Freedom of information Act is a defence against corruption and incompetence in public life. Arguments to exclude ARIA from FOI do not make a convincing case for an exception, and are part of a broader attack on a pillar of good governance. 

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The Advanced Research and Invention Agency Bill passed through Parliament this week. This creates a new research investment agency (ARIA), with the unusual feature of the organisation being explicitly excluded from Freedom of Information (FOI). 

This is unusual. Very few public organisations are explicitly excluded from Freedom of Information and the few other examples include the Queen and MI5 [1]. How FOI law works is that certain kinds of information are excluded, and so this means different organisations have different amounts of their work open to the public. Existing exemptions around research interests and confidential information mean that similar research bodies can operate within a reasonable balance of preserving confidentiality, space for policy making, and protection of on-going research (see the CFOI briefing on ARIA and an editorial on the topic in Nature). There is no real reason to believe FOI compliance would damage ARIA’s mission… unless you believe that FOI is bad, full stop.

When ARIA was announced, the statement said:

“Noting that ARIA will be a small body with minimal administrative capacity, we will remove the burden of processing Freedom of Information requests.”

This is already fairly negative about FOI, but when it came to defending the policy in the House of Lords, the language got worse. Lord Callanan (a minister at BEIS, which will have oversight of ARIA) called Freedom of Information a “truly malign piece of legislation” that does not achieve “anything at all” and “not much is ever released under freedom of information that causes any problems for government”. Punchy stuff, that also makes you think decision-makers are not opposed to Freedom of Information just for this case. ARIA is the embodiment of a bigger idea that the government takes too few risks, and so should place some risky bets on what is going to succeed in the future. The exclusion from FOI is also part of a bigger idea, that accountability and open government is bad.

You could pick apart the specific arguments made about ARIA, but these aren’t the real arguments, and taking them seriously makes everyone involved sound silly. It’s not credible that even if a well-funded agency received “a disproportionate” number of FOI requests, having a person sit in the corner and process them would substantially impact the mission. If FOI would really trip up ARIA, it is not going to achieve its goals. If, on the other hand, ARIA is going to be staffed with professionals making reasonable decisions on long-bet investments, these professionals could handle a few FOI requests, as professionals do across the public sector.

These arguments are not really about ARIA, and it is not fair to the people tasked with delivering ARIA’s expansive vision that they are starting off under the implication that they have something to hide. The real argument being made is that Freedom of Information is annoying and it stops people doing things they shouldn’t. If FOI was as useless as Callanan says, he wouldn’t care enough to block it, and no one else would care if he did. Indeed, while he was speaking the government was separately dealing with the fallout from the Owen Patterson scandal which was sparked by an FOI request. FOI is an effective way to discover bad things that are happening.

Freedom of Information is swiss-army-knife legislation that stops the need for a thousand bespoke systems of disclosure for every new government agency.  Most FOI requests do not discover big scandals, but more than none do, and these have a very big impact. Freedom of Information has a chilling effect on government incompetence and corruption, and those trying to hide from it should be seen as suspiciously as people carrying bin bags of money into a bank. 

ARIA is going to be outside FOI, and that’s a shame. But they’re only small in the grand scheme of things. Last year, we outlined a series of straightforward reforms to make the whole system of FOI better and more effective. Over the next year we’ll expand more on how we can improve the power of Freedom of Information, to make sure it continues to expose bad government, and annoy the right people far into the future. 

When created, ARIA will be subject to the environmental information regulations, and will be listed on WhatDoTheyKnow, in line with our policy on including authorities beyond the scope of FOI. We would hope that ARIA chooses to answer questions from the public, even in cases where they are not legally required to do so.

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Header image: Michael Held on Unsplash

[1]: Technically the ‘Royal household’ and it’s the wider range of security services such as MI5, MI6 and GCHQ. 

In 2021 WhatDoTheyKnow users made 100,092 Freedom of Information requests.

Those requests, and the responses they received, are public on the website for anyone to see. But what’s not quite so visible is the work the WhatDoTheyKnow team do behind the scenes — answering users’ questions, removing inappropriate content and keeping everything ticking over.

Some of the team’s most difficult calls arise around the removal of information. WhatDoTheyKnow’s guiding principle is that it is a permanent, public archive of Freedom of Information requests and responses, open to all.

For this reason, the default position is not to remove substantive public information requests and responses; however, we act quickly if problematic content is reported to us. And, to help everyone understand exactly what has been removed and why, where possible we record these details on the request page.

This year, for the first time, we’re extending our efforts towards transparency even further, with this report in which we’ll summarise the information removal requests and actions taken during the last twelve months.

To allow for a full 12 months of data, the date range used throughout this report is 1 November 2020 to 31 October 2021

Headline facts and figures

• 20,714,033 visitors to WhatDoTheyKnow.com this year
• 22,847 new WhatDoTheyKnow user accounts this year, taking the total to 222,694
• 7,971 total number of email threads in the support inbox in 2021
• 822 requests hidden from WhatDoTheyKnow in 2021
  …in the context of 100,092 requests made in the year, and a total of 772,971 requests now published on the site
• 196 Total number of published requests where we redacted some material in 2021
  …usually due to the inappropriate inclusion of personal information, or defamation.
• 126 The number of users who created accounts this year banned
  …that’s just 0.06% of new users.
• WhatDoTheyKnow is a project of mySociety run by a small team of staff and dedicated volunteers.

And in more detail…

Requests flagged for our attention

The table below shows the reasons that requests were reported for admin attention this year. Note that we also receive many reports directly by email, so while not comprehensive, this is indicative.

Reason for attention request	Total number
Contains personal information	143
Not a valid request	108
Vexatious	94
Request for personal information	85
Contains defamatory material	51
Other	287
Total	768

Material removed from the site

The following tables show where members of the support team have acted to remove or hide requests from WhatDoTheyKnow in the last year, and the reason why.

There is a range of options available to moderators, from ‘hidden’ (the most extreme) to ‘discoverable with link’. This is in addition to the censor rules that are used to hide certain information within a request or response.

Request visibility	Total number
Visible only to the request maker	805
Discoverable only to those who have the link to the request	11
Hidden	8

Reason for removing from public view	Total number
Not a valid FOI request	701
Vexatious use of FOI	29
Other (reason not programmatically recorded*)	124

*Current processes do not create an easily retrievable list of reasons beyond the two above, but we are hoping to improve our systems so future transparency reports can include a more detailed breakdown.

Censor rules (programmatically hiding the problematic part/s of a request)	Total number
Number of censor rules applied	881
Number of requests with censor rules applied	196
Number of requests with censor rules applied which are still publicly visible, but with problematic material hidden	188

Data protection issues raised to the WhatDoTheyKnow user support inbox 

The following data shows the number of email threads* received into the WhatDoTheyKnow user support inbox regarding the most common types of concern around information published on the site. Not all issues raised resulted in material being removed from the site.

GDPR = UK General Data Protection Regulations
DPA: Data Protection Act

Label	Total number of threads
GDPR Right to Erasure	317
Defamation	130
Data breach	96
GDPR & DPA concerns (type not specified)	42
GDPR Right to Rectification	33
GDPR Right of Access	21
Harassment	17
GDPR Right to Object	12
Data breach – internal**	2
Impersonation	1
Total	674

* Email threads may be either automatically categorised by the system, or manually categorised by the WhatDoTheyKnow support team on the basis of the information given by the person reporting them.

** “Data Breach – internal” refers to cases where WhatDoTheyKnow has identified that a data breach may have been caused due to our own staff actions. We take our obligations seriously, and use such instances as a learning opportunity, so these are reported even if very minor, and often when they’re nothing more than a near miss — which both of these cases were.

High risk concerns raised for review 

Our policies ensure that certain issues can be escalated for review by the wider team and, where more complex, by a review panel that includes mySociety’s Chief Executive and the Chair of the Trustees.  Escalation is typically prompted by threats of legal action, complaints, notifications of serious data breaches, complex GDPR cases, or cases that raise significant policy questions.

Case type*	Total number
Defamation	66
GDPR Right to Erasure	42
Data breach	40
Complaints	33
GDPR & DPA concerns	11
GDPR Right of Access	6
Harassment	5
Takedown	2
GDPR Right to Object	2
GDPR Right to Rectification	1
Other	78
Total	286

* Email threads may be either automatically categorised by the system, or manually categorised by the WhatDoTheyKnow support team on the basis of the information given by the person reporting them.

Users

User accounts	Total
WhatDoTheyKnow users with activated accounts	222,694
New user accounts activated in 2021	22,847

Reason for banning users in 2021	Total
Spam	3,936
Other site misuse	166
Total number of users banned in 2021	4,102

Anonymisation*	Total
Accounts anonymised in 2021	170

* Where accounts have been anonymised this is at the user’s request, generally to comply with GDPR Right to Erasure requests.

Users are banned and their accounts may be closed due to site misuse and breach of the House Rules. Anonymised and banned users are no longer able to make requests or use their accounts.

Thank you for reading

This is the first time we’ve compiled a Transparency Report like this for WhatDoTheyKnow, but it’s something we’ve been wanting to do for some time. We demand transparency from public authorities and it’s only right that we also practice it ourselves. 

Additionally, we hope that the report goes some way to showing the type of work the team do behind the scenes, and that moderating a well-used site like WhatDoTheyKnow is not without challenges.

In future years, we hope to build on this initial report, ideally automating many of the stats so that they can be seen on a live dashboard. For now, we thought it was worthwhile making a manually-compiled proof of concept. 

If there are specific statistics that you’d like to see in subsequent Transparency reports, or you’d like to know more about any of those above, do drop the team a line. They’ll get back to you as soon as the urgent moderation work is done!

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See mySociety’s 2021 annual review

Image: Create & Bloom

The Centre for Public Data has released significant new research on property in England and Wales that is owned by individuals based overseas.

The work is based on material released through Freedom of Information requests made to the Land Registry via WhatDoTheyKnow.com.

The headline findings include:

• Nearly 1% of properties registered in the UK are registered to individuals with an overseas correspondence address; this number has more than doubled since 2010.
• The number of properties registered to individuals with an overseas correspondence address is now more than double the number registered to overseas companies.

The work cites and links to the source data on WhatDoTheyKnow (and WhatDoTheyKnow in turn links back to the analysis and commentary).

One of the benefits of making FOI requests via WhatDoTheyKnow is the ability to easily link to the source when taking action based on released information. Citing sources gives work credibility, and it also makes it easy for others to verify what has been done, build on it, or conduct their own analysis based on their particular interests. We want to encourage this kind of exemplary use of WhatDoTheyKnow for well-referenced FOI based research.

The data obtained, and presented, by the Centre for Public Data in this case may inform debate on a range of socially important issues including how overseas property owners, who may well be investors, affect the supply and affordability of housing.

The Centre for Public Data have provided a tool enabling searching of the data – this means local journalists (or others with an interest in a particular area) can quickly obtain localised data.

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Image: Gary Stearman

The nucleotide sequences of the AstraZeneca and Pfizer/BioNTech, vaccines used in the UK have been released in response to a Freedom of Information request made via WhatDoTheyKnow.com.

As the sequences have been released via WhatDoTheyKnow they can now be accessed by anyone.

The release, on 26th of October 2021, by the UK’s Medicines and Healthcare Products Regulatory Agency follows an initial refusal under Section 41 (Information provided in confidence) and Section 43 (Commercial interests) of the Freedom of Information (FOI) Act, which was overturned as a result of an internal review prompted by the requester.

The Medicines and Healthcare Products Regulatory Agency published “Information for healthcare professionals and the public” when they approved each COVID-19 vaccine:

• Regulatory approval of Pfizer/BioNTech vaccine for COVID-19 – 2 December 2020
• Regulatory approval of Vaxzevria (previously COVID-19 Vaccine AstraZeneca) – 30 December 2020
• Regulatory approval of Spikevax (formerly COVID-19 Vaccine Moderna) – 8 January 2021
• Regulatory approval of COVID-19 Vaccine Janssen – 28 May 2021

However, the information proactively released at the time the vaccines were approved did not contain their nucleotide sequences, and prior to this FOI response they had not been officially released by the agency.

While the vaccines had been described, details of the information they encoded had not been publicly released. Imagine the vaccine as data on a USB drive. Prior to this response, what the regulators proactively released when approving the vaccines was akin to information on the materials used to make, and package, the drive: plastic, and metal, along with a vague description of its contents, rather than a copy of the actual data contained on the drive.

It could be argued that people were not able to make a fully informed decision on whether or not to have the vaccine given that their sequences were not initially available. This was the case made by the requester when they asked for the initial refusal to be reconsidered. Of course one wouldn’t expect many individuals to review sequence data personally, but  as the data wasn’t generally available to those outside of the manufacturers and regulators, independent analysis and commentary was chilled.

The lack of transparency surrounding the detailed composition of the vaccines was not limited to the UK. The fact the sequences were not available prompted one group of scientists to seek to determine the sequences of the Pfizer/BioNTech and Moderna vaccines themselves, analysing small portions of vaccine doses that remained in vials after immunisation. They carried out this work, with the permission of regulators in the USA, and published their results on GitHub.

In its FOI response the Medicines and Healthcare Products Regulatory Agency stated that it had “obtained consent from the relevant companies to release the full nucleotide base sequences”. Not all the requested information has yet been released. The response states the Janssen Covid-19 nucleotide sequence has been released, however it is not contained in the attached documents (a protein sequence, rather than a nucleotide sequence has been provided). The response also says: “discussions are continuing with regard to the release of the sequence of the COVID-19 Vaccine Moderna.” This suggests two more sequences should hopefully be forthcoming on the correspondence thread soon.

We are hopeful the released material, which in some cases goes beyond the sequences and includes further information about the vaccines, is of value. As always we encourage those who make use of the released data to cite the WhatDoTheyKnow thread, and to link to their work via annotations.

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Image: Spencer Davis

Recently the discharge of untreated sewage into the sea and rivers has been in the news in the UK. This prompted us to update and expand our coverage of organisations responsible for such activities on our access to information website WhatDoTheyKnow.com.

Since a ruling in 2015 all organisations which provide certain water and sewage related services have been considered public bodies for the purposes of the Environmental Information Regulations; this means everyone has a right to the environmental information they hold.  Even private water and sewage companies can be considered public bodies under the regulations.

We often describe WhatDoTheyKnow.com as a Freedom of Information website, but it can be used to obtain public information under a range of access to information legislation, not just the UK and Scotland’s Freedom of Information Acts. So if you want environmental information about sewage we’d love to see you requesting it, in public, via WhatDoTheyKnow.

We’ve listed water companies on WhatDoTheyKnow for some time, and we have now specifically collected those responsible for sewers into their own category. This will hopefully assist people considering making a request for information and help ensure requests are directed to appropriate organisations.

We’ve also generally improved our categorisation of water companies and have made a specific list of general regional water suppliers available.

We’re always keen to see requests made in a responsible manner. Anyone considering making a request for information should check relevant bodies’ websites for the information they are seeking  before making a request. Some organisations publish some information about releases of untreated raw sewage, and information about their plans to monitor, and reduce, such occurrences.  Where information is collated by a central body, requesting it once, from that body, is more efficient than requesting it from many bodies. The Environment Agency for example collates and publishes some data on storm overflows centrally.

We list the Environment Agency, the Department for Environment, Food and Rural Affairs, Highways bodies (which are responsible for surface drainage from roads), and many other relevant bodies on WhatDoTheyKnow.

Before making your own requests it’s a good idea to look at work which has already been done by others to collate, present and share information: for example the Rivers Trust have published a map of where the sewerage network discharges treated effluent and overflows of untreated effluent and storm water into rivers in England & Wales.

The current interest in this subject in the UK has focused on MPs’ consideration of the Environment Bill. Proposals for the Bill include provisions requiring the publication of information on the location of “storm overflows” and the frequency, duration and volume of discharges from such overflows.  We’re keen to see timely proactive publication of information rather than having information only released on request; we’re more than happy to see the need for our service reduced by greater proactive transparency from public bodies.

We would like to see news articles, campaigners and academics citing, and linking to, the sources of the data on which their work is based. This improves the credibility of the work, and enables others to check, and build on, what has been done. Requesting information in public via WhatDoTheyKnow.com makes such citations and links easy to offer.

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Image: Ivan Bandura

It’s always so cheering to hear about campaigns that have had real results, and this week’s TICTeC Show And Tell gave us plenty of inspiration on that front.

We heard how FOI has been at the heart of investigations in Croatia, France, Scotland and the crossborder Lost In Europe project, along with two deep dives into the state of FOI in the UK — all in the name of International Right To Know Day.

As ever, you can catch up with the event in multiple ways:

• All videos are all available over on our YouTube channel. You can watch the entire event, or pick and choose from the individual presentations, as below.
• Speakers have shared their slides. Access them via the links to each presentation on the TICTeC website.
• We live tweeted as the event happened, including links to reports that were mentioned and previous case studies going into more detail about some of the campaigns mentioned.

Full video

Individual presentations

The FOI Clearing House: an openDemocracy investigation into freedom of information at the heart of government

Jenna Corderoy (openDemocracy, UK)

openDemocracy’s Jenna Corderoy discussed her recent investigations into the Clearing House, a unit within the UK Cabinet Office that “advises on” and “coordinates” FOI requests referred by government departments.

openDemocracy has uncovered alarming evidence that the Clearing House blocks the release of information and causes lengthy delays; their investigations and subsequent FOI tribunal hearing over Clearing House documents have sparked a UK parliamentary inquiry.

See this presentation

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Lost in Europe: deploying the Alaveteli network on a cross-border investigation

Liset Hamming (The Dutch-Flemish Association for Investigative Journalists (VVOJ), Netherlands

Ten European FOI sites were used in this Netherlands-based investigation into the thousands of children who go missing as they migrate across European borders. The FOI component of this journalistic investigative research project is led by an Alaveteli insider, running the recently launched Dutch Alaveteli site.

See this presentation

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Watch this space (and pay for it): Alaveteli-driven exposure of the misuse of public resources in an election campaign

Dražen Hoffmann (GONG, Croatia)

In April 2021, GONG used the Alaveteli-powered platform ImamoPravoZnati to unveil the practice of funding a YouTube channel by the mayors and country prefect of a county in Croatia, ahead of the May 2021 local elections.

The quaint footage of seaside towns and villages, and boasting of successful projects, in fact concealed a misuse of public resources for the purposes of incumbents’ campaigns. This practice of non-transparent media buying is one that GONG addresses continuously.

See this presentation

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Regulating Access to Information

Alex Parsons (mySociety)

The practical reality of Access to Information laws depends on how effective the system of regulation and appeal is.

Alex shares mySociety’s recent work in comparing different systems of regulation in the UK, and parts of our upcoming research that will do the same for regulation across Europe.

See this presentation

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Running an Access to Information platform in France: obstacles and success stories

Samuel Goëta (MaDada.fr, France)

Open data in France, says Samuel,  looks somewhat like the Tower of Pisa: a beautiful building (open data is mandatory by law), but leaning because its foundations (the Freedom of Information Act) are in bad shape.

Samuel speaks about the weaknesses of FOIA in France, how the French Alaveteli platform madada.fr manages them and the first success stories coming out of the platform. Importantly, MaDada has been responsible for a wider understanding of FOI among French citizens.

See this presentation

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A change in the law for school starters in Scotland — through FOI

Patricia Anderson (Give Them Time, Scotland)

Patricia from the Give Them Time campaign speaks about how FOI requests, sent via WhatDoTheyKnow, helped them get the law changed so that more children in Scotland can benefit from more time at nursery school.

Thanks to the campaign, from 2023 all children in Scotland who legally defer their school start date will be automatically entitled to a further year of nursery funding.

See this presentation

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