Response 1021281896

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About You

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Name
Geraint Jones

Are you responding as an individual or an organisation?

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(Required)
Ticked Individual
Organisation

Questions

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

Please select one item
Ticked Yes
No

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.

Please enter comments:
Statutory Role RSLs have a statutory role and all such organisations should be transparent and open to scrutiny - not just by regulators, government etc., but also by individuals who may be affected by their decisions. Public Funding I cannot accept that there are any legitimate arguments to made to prevent individual citizens (AKA Tax Payers) accessing information about any organisation which receives public money (with the exception of confidential information about individuals and possibly - but reluctantly - some aspects of national security). We're the ones handing over the money. Social Role The provision of social housing is a public service - whether the organisation is a charity a local authority. And just like any other public service it needs to be seen to be acting impartially and free from the taint of politics (not to mention the social engineering which I suspect is being practiced). In my view this kind of necessary scrutiny of RSL's can only be provided by making them statutorily required to answer questions put to them by individual citizens - the "awkward quad" if I can use that term - under FOI legislation. Rights To Information Tenants of those Local Authorities which retain their housing stock already have the right to make enquiries about housing under FOI legislation. The fact that tenants - or housing applicants/potential tenants of RSL's cannot do so or have to depend on the goodwill of those RSL's to "voluntarily supply information" according to their whim - is clearly unfair.

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?

Please select one item
Ticked Yes
No

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

Comments:
In my view the Scottish Government should implement Option 2. I am not a fan of allowing organisations - whether they be private, charitable of public - to operate voluntary codes or to operate "within the spirit of the Act". It is human - and corporate - nature to conceal what you don't have to reveal unless you absolutely have to do otherwise. Stakeholder engagement My status as a "stakeholder" was as a housing transfer applicant(now a satisfied tenant of a new property in Oban) with "HOME Argyll" and I was prompted to write to Mike Russell after failing to obtain information regarding our position on the housing list, likely timescale for a potential new tenancy etc. In my opinion applicants should routinely be able to obtain such information. I understand that there would be costs - both for the RSL's, who would have to employ or train up FOI officers and for the Scottish government in terms of enforcement. However I believe that the benefits in openness and transparency outweigh these costs. The argument re commercially sensitive information surely also applies to aspects of the way local authorities operate their housing - and other - departments - and if they can cope then so can RSL's.