Response 794476701

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About You

What is your name?

Name
Tony CAin

Are you responding as an individual or an organisation?

Please select one item
(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Association of Local Authority Chief Housing Officers (ALACHO)

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:
RSLs provide just under half of Scotland's social housing a significant proportion of which was previously owned and managed by public bodies that would, if they still existed by covered by the Freedom of Information provisions. As the consultation document points out RSL tenants sign the same form of contract as those that rent from local authorities and in all other respects have the same rights as Council tenants. In our view RSLs are very clearly undertaking "functions of a public nature". We would also argue that there is no justification for offering RSL tenants fewer rights in respect of access to information from their landlords than those renting from Councils.

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:
We agree with the Minister for Parliamentary Business that the impact assessment represents a reasonable view of the likely costs, benefits and impact of extending the Freedom Of Information provisions to RSLs.

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
The proposed extension of the FOI provisions to RSLs will give qualities groups some confidence that they can access sufficient information to allow them to examine and compare the performance of social landlords and the social housing sector as a whole on a like for like basis.