Response 986597141

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About You

What is your name?

Name
Dr Kenneth Meechan

Are you responding as an individual or an organisation?

Please select one item
(Required)
Individual
Ticked Organisation

What is your organisation?

Organisation
Glasgow City Council

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 receive significant public funding and play a critical role in housing supply and providing support to the homeless, amongst other functions. The position is more heightened in an area such as Glasgow where, following the 2003 stock transfer to GHA, the local authority no longer has any housing stock to provide these functions and is reliant on RSLs in the city. The Council consider that RSL’s are bodies that undertake ‘functions of a public nature’. The ongoing implications of the ONS decisions on the status of RSLs may have implications for this view and could impact on this FOI proposal. Will SG be considering these implications and is there a timescale for a view on the private versus public nature of RSLs arising from this?

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
If not, you may wish to indicate what timescale you feel would be more appropriate and why.
We consider this to be a reasonable timescale.

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

Comments:
Paragraph 4.11 of the BRIA suggests some cost savings for the SHR and local authorities as a consequence of extension. This council receives around 12 RSL-related FOI requests each year and given our particular circumstances would expect this to be the highest number for any local authority. Removing 12 requests per year from ourselves (normal FOI workload 2,500 – 3,000 per annum) would not produce any meaningful saving for ourselves and we do not think this part of the BRIA is justified. We agree with the remainder of the BRIA.

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
Extending FOI to RSLs will give equality groups more opportunity to explore how RSLs are meeting their own particular requirements.