Response 847200554

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About You

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Bill Scott

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Ticked Organisation

What is your organisation?

Inclusion Scotland


1. Do you agree that freedom of information legislation should be extended to Registered Social Landlords, as proposed in this consultation paper?

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Ticked Yes

2. Freedom of Information can be extended to organisations that undertake ‘functions of a public nature’. You may wish to provide comments on how you consider that RSLs undertake functions of a public nature, for example, with reference to the factors referred to earlier in the consultation paper.

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They provide social housing. Given that several Local Authorities have transferred their entire stock to RSLs it makes little sense to compel Local Authorities to comply with Freedom of Information law in regard to housing issues but not Housing Associations which have even larger numbers of tenancies. It makes building a comprehensive picture of housing policy across Scotland difficult and means that large RSLs carrying out an important largely funded with public money (Scottish Government Housing Grant) are not subject to basic levels of scrutiny.

3. The proposed order would be expected to come into force on 1 April 2018. Do you consider this a reasonable timescale, allowing for preparation for inclusion?

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Ticked Yes

5. We would welcome comments on how these proposals might impact on ‘Equality Groups’ i.e. in respect of age, gender, race, religion, disability, sexuality, children’s rights etc. Comments will inform the Equalities Impact Assessment and Child Rights and Wellbeing Impact Assessment to be completed following consultation.

It would provide these groups with more information on whether Housing Associations are taking equalities issues seriously and that their policies and practice is in line with equality and human rights law.