Response 499019277

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About You

What is your name?

Name
Doctor Stewart Montgomery

Are you responding as an individual or an organisation?

Please select one item
(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Montgomery Housing and Equality Consultancy

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:
Many association functions are of a public nature such as allocations, estate management, repairs and maintenance and so on.

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
Yes
Ticked No
If not, you may wish to indicate what timescale you feel would be more appropriate and why.
1 January 2019 as associations would require considerable time to develop policy and procedural frameworks on top of extensive changes presently being implemented following the Housing (Scotland) Act 2014. Examples include comprehensive changes to allocation and tenants' rights.

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

Comments:
The regulatory impact assessment issues should be incorporated into other documentation, for example, Scottish regulatory guidance frameworks.

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.

Comments
It is essential to include issues relating to social class and to ensure that the social model of disability is implemented into documentation.