Freedom of Information Policy

Introduction

The Freedom of Information Act (2000) gives general right of access to all types of recorded information held by public authorities. It came into force in January 2005, and the National Army Museum (NAM) is named as a public authority under the Act. This legislation gives the public the opportunity to find out what the Museum does and how we do it, and makes it more accountable.

This policy covers how the Museum complies with the Act, responsibilities of staff, and relationship with existing Museum policies.

Scope of the policy

This policy applies to all information created, received or held by staff in connection with their work at the Museum, regardless of format, storage medium and age.

The Museum will provide information when requested in compliance with the following legislation:

The Freedom of Information Act (2000)
The Environmental Information Regulations (2004)
The Data Protection Act (2018)
RoPSI Regulations (2015)

The Museum will manage its records in accordance with the Section 46 Code of Practice of the Freedom of Information Act, and the recommendations found in the Lord Chancellor’s Code of Practice on the management of records (2000).

Requirements

The Act places the following requirements on the Museum:

Information which is routinely published by the Museum is made available in accordance with the Museum’s Publication Scheme.
Information which is not covered by the Publication Scheme is made available to enquirers on request, within 20 working days, unless a valid exemption or limit applies.
Exemptions under the Act and Regulations are applied appropriately
Requests for information relating to the natural, historic or built environment are covered by the Environmental Information Regulations, and can be made verbally, receiving a response within 20 working days.
A fair and efficient internal appeal system is administered.
A properly structured approach to managing records is in place to ensure that essential records of the Museum’s activities are maintained.

Responsibilities

The Museum Director has legal responsibility for the Museum’s compliance with the Freedom of Information Act.

The Museum’s Records Officer is responsible for coordinating and monitoring information requests received by the Museum, monitoring and updating the Publication Scheme, and providing advice where necessary.

The Museum’s SIRO has responsibility for leading internal reviews and making a decision in the case of an appeal; in the event that the SIRO was involved with the original response, the Assistant Director (Human Resources) will lead the review.

All staff have a responsibility to familiarise themselves with policies and procedures relating to the Act, to respond to requests for information in accordance to the Act, and to provide the Records Officer with the necessary advice and assistance for the purpose of responding to requests for information.

Fees

When information is provided as copies of documents, photographs, film, etc, the Museum reserves the right to charge the current fee for reproductions. A fees notice will be sent to the enquirer prior to the supply of any information.

Where the costs of locating, retrieving and extracting information exceeds the cost of £450 (18 hours), the Museum reserves the right to charge for the additional costs in staff time. Costs are set at £25 per person per hour regardless to actual rate of pay.

Relationship with existing policies

This policy is supported by internal procedures available to Museum staff on the NAM Intranet, together with the following policies, which are available on the NAM website:

Privacy notice

Our primary purpose for using your data is so that we can process your information request.

In addition, we use your data for the following secondary reasons:

Recording the types of applicant making requests to us by broad category for reporting purposes
If you are a journalist or from a media organisation, our Marketing and Communications team will be notified that you have made a request so that they are aware of any potential forthcoming news coverage to which they may need to respond
We sometimes discuss requests that have been received with other public authorities (eg other national museums) to obtain advice. Although we never deliberately share the identity of applicants in these circumstances, if you have submitted the same request to a number of authorities, your identity may be obvious to those who have received the request.

Legal basis for processing

The legal basis for processing your request is article 6(1)C of the GDPR, which relates to processing necessary to comply with a legal obligation to which we are the subject.

If any of the information you provide us in relation to your information request contains special category data, such as health, religious or ethnic information the legal basis we rely on to process it is article 9(2)(g) of the GDPR, which also relates to our public task and the safeguarding of your fundamental rights.

What we do with it

When we receive a request from you, we will record the details of your request in our customer management system. This normally includes your contact details and any other information you have given us. We will also store a copy of the information that falls within the scope of your request.

If you are a journalist or media organisation making a freedom of information or environmental information request, we will let our Marketing and Communications team know that a request has been received from you and keep them informed of progress. Note that this will not affect the information that you receive.

If you are making a request about information that we have received from another organisation we will routinely consult the organisation concerned to seek their view on disclosure of the material.

We may compile and publish statistics showing information such as the number of requests we receive, but not in a form that identifies anyone.

How long we keep your data

Requests, and all personal data associated with them, made under Freedom of Information are in most cases destroyed after 2 years from completion, in line with enquiries procedures set out in NAM’s retention schedule.