Response 883431031

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Ina Marshall

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Ticked Organisation

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Weslo Housing Management


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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Whilst Weslo Housing Management fully supports the principles of Freedom of Information Act 2002 (FOI) which encourages and develops a culture of openness and transparency across all public services, we do have reservations about it being extended to Registered Social Landlords (RSLs). Whilst RSLs do undertake some functions of a ‘public’ nature – specifically the provision of housing for those in need, their structure, remit and financial arrangements are markedly different from other bodies more commonly recognised as being in the public sector, particularly local authorities. Weslo also has reservations in relation to potential costs to the sector when funds are already extremely challenged. What real benefit will FOI bring bearing in mind the potential cost implication? RSLs are already subject to regulation and scrutiny through a number of different bodies, which places a duty on the information it provides to tenants, customers and other service users. The collation of this information requires a considerable amount of time and resource and we would question not only the added burden in terms of resource but also the cost implications of subjecting RSLs to FOI. The information collated and through the Charter demonstrates that RSL tenants feel significantly better informed by their landlord than Council tenants who are already subject to FOI. It is also fair to say that Local Authorities provide a much wider range of services than RSLs, financed by public money through Council Tax or Government grant. 

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 No
If not, you may wish to indicate what timescale you feel would be more appropriate and why.
Should the Scottish Government decide to extend FOI to RSLs, we would suggest that this timescale be extended by another year, to allow RSLs, if required, the opportunity to further develop the information they already publicise by formally adopting a framework similar to the ‘Model Publication Framework’ jointly published by SFHA and GWSFHA which is referred to in your Consultation document. This may mitigate the number of requests being made and therefore assist with cost implications. The extension to time will allow any changes that may be required to be carried out in a planned and diligent way.

4. We would welcome comments on the draft partial Business and Regulatory Impact Assessment provided at Annex A.

RSLs are committed to the Governments strategy of providing value for money at a time when they are suffering from reduced funding, the need to keep rents affordable, complying with regulatory requirements, maintaining their properties and providing enhanced services to meet tenant needs. All this, with pressure not to increase rents their main source of income. The extension of FOI to RSLs will undoubtedly lead to increased costs even if the predication is ‘low’. Research already undertaken estimates the costs would be in the region of £230 per case. If an RSL receives the lower estimate of 50 FOI cases per year as highlighted in the research, at a cost of £230 per case, this would incur annual costs of £11.5K, multiplied over the number of RSL’s this could potentially cost the sector over two million pounds. This does not take account of any financial start-up costs that may be involved including training for existing staff members who will have the additional burden of administering FOI requests.   In a time when housing needs are more pressing, and finances more stretched than ever before, would it not be better to look at ways that RSLs can meet these challenges without adding additional burden to already pressurised resources. A solution would be for RSLs to adopt a framework similar to that published by SFHA and GWSFHA in order to enhance the information already provided by RSLs, bringing a consistency throughout the sector without the added costs.