Scottish Government

OTHER POINTS RAISED - NOT SPECIFIC TO TOPICS COVERED

A number of respondees expressed views on issues which were not specifically covered in the consultation paper. These included:

• The view that section 30, and in particular sub-section (c ) lacks clarity and guidance on its application from the Scottish Information Commissioner is urgently required
• The need for section 18 ("neither confirm or deny") to be useable in relation to other "exemptions", for example section 38 (1) (b) and section 36.
• Provision of examples where public authorities had not responded to requests within the required timescales or, in some cases, at all. "Thus, 50% of the [local] authorities responded late, while one in eight failed to respond at all."
• Suggestions for a greater obligation on authorities to publish their FOI performance data
• Need for more research to better understand the effective ness of FOI in practice and to what extent legally enforceable standards are required as a necessary support, for example with regard to records management procedures