FOI
3000 requests made as FOI reaches 5th anniversary
CNS): It is five years ago this month since the Freedom of Information Law came into force in the Cayman Islands and as a result of the work of a small team at the Information Commissioner’s Office (ICO), government is slowly becoming more accountable. More than 3,000 FOI requests have been made since the law was enacted and the ICO has dealt with more than 140 appeals, 36 of which have gone to full hearings where decisions were handed down. Despite well documented and ongoing procedural problems, which in most cases are down to poor record keeping in government, the law has assisted significantly in improving public sector transparency.
However, five years after the law was implemented by the former PPM administration politicians have failed to complete the review of the legislation, which was mandated by the law itself after twelve months. Although the former information commissioner, Jennifer Dilbert, undertook her review and passed her recommendations to the Legislative Assembly more than 18 months ago, no review of the legislation took place under the previous UDP administration. The acting commissioner has confirmed that the office has received no news on the current administration’s plans regarding the review, which is expected to be examined not just by government but the entire Legislative Assembly.
With several more years having passed since that review, Dilbert said before her retirement that there would now need to be a review of the review because of the greater experience the office has now gained after working with the law for so much longer.
While the office has seen many problems over the five years, it has also witnessed considerable improvements in the work of information managers across the 92 different public authorities that make up the Cayman Islands Government.
“The FOI Law’s requirements for transparency and proactive publication have gradually become accepted by public officials and public authorities. Five years after the Law came into effect, FOI has become a way of life in the public sector and in the Cayman Islands at large, not least thanks to careful vigilance on the part of the Information Commissioner’s Office and a continuing programme of training and public education,” the office stated this week as it marked the five year anniversary.
“As various hearing decisions have brought to light, some infringements continue to occur, but for the most part public authorities – and particularly the information managers in each entity – are trying their best to comply with the Law, to respond to requests on time, and to be more transparent and accountable.”
Upon her retirement, Dilbert thanked all those who helped in the establishment of an effective Freedom of Information Regime in the Cayman Islands.
“I can assure them, and the public in general, that both our Legislation and our operational systems meet or exceed international standards, and in my experience are among the best worldwide,” she said. “The majority of chief officers, heads of departments and statutory boards have embraced FOI, and are ensuring that their entities are well placed to respond to requests and meet the requirements of the Law, including the proactive publishing of as much information as possible.”
Dilbert retired in December 2013 at the end of a five year appointment as commissioner and after more than 30 years of public service. Jan Liebaers was appointed as acting commissioner in January 2014, having served as the deputy information commissioner from June 2010 to December 2013. Prior to that, Liebaers was a key member of the FOI Working Group which drafted the Cayman Islands FOI Bill from 2005 to 2007, as well as the FOI steering and implementation planning committees which assisted in the development and planning of the law.
On the occasion of the laws anniversary the ICO thanked the civil service and successive governments for their support, in particular the information managers, some of whom have been in this important role for the last five years. Through their attendance at the ICO’s training seminars, the commissioner has had the opportunity of being involved with discussions with many of them, and witnessed first-hand their dedication to their sometimes difficult job.
All ICO decisions released to date are posted on the ICO website. Dilbert’s farewell message can also be found on the website in Issue 18 of ICON, the ICO Newsletter.
FOI tangled in pension issue
(CNS): Jennifer Dilbert’s final ruling on a freedom of information dispute after five years as the information commisssioner has turned out to be one of the most complex cases she has dealt with. Publishing her 32nd decision on Thursday afternoon, Dilbert described it as a “particularly difficult hearing”. This was down to a catalogue of reasons, including ther fact that the public authority did not follow the law and because it was inextricably linked with a much wider complaint being made by the applicant about the failure of the National Pensions Office to uphold the law when a high profile private sector employer allowed at least one employee to make his own pension investment outside the statutory requirements.
Despite concluding that the ministry involved and the former National Pensions Office had correctly withheld records and redacted others because they contained the personal details of a third party, the request nevertheless threw up a myriad of procedural issues. The incredibly complex hearing also resulted in the information commissioner ordering the applicant to make a fresh request for what were believed to be more missing documents and others in dispute as it was virtually impossible for Dilbert’s office to untangle the mess.
The commissioner said the administrative confusion was compounded by both sides in the dispute as well as the late arrival of the legal department in the matter and a list of records in question that did not match those the information commissioner’s office was dealing with.
“I believe that it has been frustrating for the Applicant, who has felt that the NPO and the ministry were often not in compliance with the FOI Law, and that there have been unacceptable delays,” Dilbert said about the hearing. “At the same time, the public authorities have made a huge effort, albeit sometimes after delays, to provide the Applicant with a multitude of records.”
She noted that as a result of her office’s intervention almost 18 months ago when the applicant made the appeal to the ICO, many more documents had been released than at the start of the appeal. Dilbert noted that regardless of the much wider dispute, she had to focus on the FOI Law and the legal exemptions claimed and could not consider any other factors.
“While there have been delays and other difficulties with respect to the public authorities’ compliance,” she said, there was “no egregious or wilful failures to comply with the FOI Law" in the case.
“Given the huge amount of time and resources that have been expended on this matter to date, I am not prepared to continue with these appeals in the current form,” she said. “Section 39 of the FOI Law states that the Commissioner may hear, investigate and rule on appeals filed under this Law, and I am hereby exercising my authority to decline to hear or rule on these current appeals,” she added.
Dilbert explained that records being requested were overlapping with some already received by the applicant and in others the exemptions were similar to those applied to the requests in this decision. She also said there was significant confusion between the parties as to what has been already provided, what has been internally reviewed, and what records remain outstanding.
“The most effective way to continue the process of getting access to further records, would be for the Applicant to carefully examine all the records that have been provided, consider the exemptions that have been applied by the NPO and upheld by me, and make a new FOI request for any outstanding records,” Dilbert ruled. “Thiswould include clearly identifying any records that are referred to elsewhere in records already received. These requests could then work their way through the processes in a timely and organised manner.”
In recent weeks, as her tenure drew to a close, Dilbert has pointed to the increasing complexity of the hearings that she is dealing with, which is illustrated by this particular decision. In every case, however, it seems that either poor record keeping or lengthy delays and procrastination on the part of public authorities is compounding the problems, which the ICO is left to try and unravel while applying the FOI law.
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No progress made on the review of FOI law
(CNS): According to the latest quarterly report released by the Information Commissioner’s Office (ICO), no progress has been made on the review of the law under which freedom of information operates in the Cayman Islands. The law itself mandated a review of the legislation after its first year to gauge how it was working in practice and give legislators an opportunity to correct any issues resulting from the day to day use of the law. While Jennifer Dilbert, the soon to be retired commissioner, and her team completed the review over three years ago, the government has not yet acted on it and the ICO says that the review will need to be reviewed now as a result of the time lapse.
“Given the time elapsed since the Information Commissioner submitted recommendations in September of 2010, the ICO will be reviewing the Committee’s Report and making further recommendations as soon as possible,” ICO officials said in their first quarter report for this financial year.
The report, which was made public last week covers the work of the office between the start of the 2013/14 financial year on 1 July until the end of September. The report also looks at the statistics and found that between 1 April and 30 June, 144 freedom of information requests were logged into the central FOI tracking system by public authorities. This represents a 50% increase compared to the same period in 2012. Of the requests received, 99 were closed during the same period and 44 remained open. A total of 29 out of 92 public authorities received requests.
Having dealt with 133 appeals since the office opened, the ICO said that many appeals are made to the ICO because of poor procedural handling of requests by public authorities and the officials noted that public authorities are not as cooperative as they should be.
“Over the past several months it has become evident that some public authorities have dealt poorly with requests before they reach the ICO as an appeal,” the report reveals. “Once an appeal is accepted and a pre-hearing investigation has started, some public authorities are still not fully cooperating with the ICO, and are even reluctant to do so when a formal Hearing has commenced, in contradiction to the applicable policies and procedures.”
As a result, the office will be focusing its next Information Managers Seminar Series on the public authority’s role in an appeal.
In the meantime, the ICO has been keen to conduct a number of own-initiative investigations under section 46 as a result of procedural concerns but a shortage of staff and resources alongside the growing number and complexity of appeals meant these have had to be postponed.
However, a small boost in the ICO budget in the 2013/14 financial year has seen staffing levels improve and the recruitment of a senior analyst at the very end of the quarter has meant that some of those investigations have now been started.
PA ordered to find records
(CNS): The acting information commissioner has ordered the Ministry of Education, Employment & Gender Affairs to go back and look again for records requested under a freedom of information application regarding documents used in a Human Rights Committee report published in 2007. Jan Liebaers found that the ministry did not make reasonable efforts to locate the records, as required in the law, when they told the applicant that the records he wanted did not exist. In this latest ruling, among the many procedural problems highlighted, the acting commissioner found, once again, that there was poor record keeping and ordered the ministry to get its house in order.
Liebaers pointed to the numerous past occasions commented on by the Office of the Information Commissioner (ICO) in respect of the poor record keeping standards applied by some public authorities. In this case, the records were generated by a government committee and the ICO raised concerns about the confusion surrounding who is responsible for keeping the records of committees, especially when, as was the case in this hearing, the committee no longer exists.
“This is a highly unsatisfactory state of affairs since committees perform important work, and their actions and decisions should be properly recorded and maintained over time,” he said. “Some committees in particular, such as the HRC in the present case, make decisions that may have a significant impact on individuals and organizations, and its records – like all government records — should be maintained in accordance with the provisions of the National Archive and Public Records Law.”
This particular hearing was triggered when an applicant seeking documents that were used to write a human rights report, which included details about him which he felt needed to be amended, was told the relevant records did not exist. However, he believed they did and in order to prove that the report needed to be changed he requested all of the documents that had been used in the making of it.
During the course of the appeal the acting commissioner found that there obviously were relevant documents in existence somewhere because there was a reference to them in correspondence with the applicant as well as in the report.
Therefore, Liebaers found that the authority did not look hard enough and did not make the necessary effort to find the records, and he told them to try again. He pointed out that although the records related to the Human Rights Committee, no one contacted the Procedural Sub-Committee involved in making the report or the former chair of that committee.
“This seems to me to be a serious flaw as he would be a person who might reasonably be expected to hold records of the Committee’s activities,” Liebaers noted.
The acting commissioner also raised the point that while the public authority in question says the records do not exist, it has not explained why they no longer exist or what has happened to them.
“The Ministry has not provided any explanation of why these records — which they were responsible for at the time of their creation — apparently no longer exist,” he notedin the decision. “In the course of the appeal the Applicant made an email available to the ICO which dates from just before the HRC Report was issued and in which a member of the HRC stated that the HRC at that time was making inquiries and expected to receive further documentation from various parties on the Applicant’s case. Similar statements are also included in the HRC Report itself, for instance at paragraphs 56, 59 and 60.”
Given that many important pieces of information were not provided by the ministry in the explanation of its search efforts, Liebaers concluded that the rigour and efficiency of the search conducted by the ministry was inadequate. He said the education ministry did not meet the requirement of the law to make reasonable efforts to find the records.
The acting commissioner gave the authority 30 days to either find the missing documentation or supply an affidavit listing the efforts made to locate the records.
See the decision in full here.
Another PA breaks FOI law
(CNS): Less than two months before stepping down from her post as Cayman’s first information commissioner, Jennifer Dilbert issued her 36th decision Tuesday, in which she ordered a government department to release a withheld document and comply with other elements of the law. She also found many procedural issues where the public authority had breached FOI legislation. She pointed to “appalling record keeping” by the Department of Labour and Pensions, the government entity concerned, and raised concerns about the perception in this case that the authority was deliberately hiding a document. Although she said there was no direct evidence in this case, she warned that her office would seek to prosecute any public authority if it acquired such evidence.
In this case a document from the Office of Director of Public Prosecutions was withheld by the Department of Labour and Pensions from an applicant, even though it related directly to the applicant’s complaint about a breach of employment law by their boss. During the course of the appeal hearing Dilbert found “extremely poor record keeping” and as a result ordered the government entity to address that issue, as is required under 52(1) of the law.
The hearing came about following an FOI request by a member of the public regarding all of the documents held by government departments relating to a complaint they had made about the non-payment of overtime benefits by their employer. Although documents were released, the applicant pressed the issue as they believed more documents existed. As a result an internal review was requested but it was not completed in the time required under the law and the applicant sough the intervention of the commissioner, who began an appeal hearing.
In her ruling Dilbert said that the Ministry of Education, Employment & Gender Affairs contends that an Internal Review was completed on 9 April this year, but despite several requests from her office during the appeal, neither the ICO nor the applicant has been provided with a completed Internal Review. And even if they could claim it was completed it was still a week late, she noted.
During the course of the appeal other procedural issues were also identified, not least the fact that documents were missing.
“During the ICO’s pre-hearing investigation, further records were provided to the applicant, but the Applicant maintained that it could be seen from the records provided that additional records, in particular correspondence from the Director of Public Prosecutions concerning the case, must exist,” she wrote.
On 25 June the ICO requested the DLP provide an affidavit explaining why a record discussed in emails didn’t appear to exist or couldn’t be found. Several weeks later the employment ministry provided the ICO with an affidavit and a copy of the record from the director of public prosecutions, which related to the applicant’s case and was a relevant record which, the ministry claimed, had not come into the department of labour’s possession until 10 July this year, despite being dated 2011.
The ministry then refused to release the record under the exemption in the FOI law relating to legal privilege.
“It is surprising and not acceptable that this record could not be located during the entire life of the request and appeal, and was found only when the public authority was required to provide the ICO with an affidavit attesting to the fact that all responsive records relating to the applicant’s request had been provided to the applicant or the ICO,” Dilbert writes in her ruling.
“At best, this is an example of extremely poor record keeping on the part of the DLP at the time, which is disturbing as the Department has a key function in respect of safeguarding employment rights in the Cayman Islands. At worst, the inability of the DLP to locate this record could be perceived as an attempt to conceal it, either at this time or in the past,” she warned . “This important record should have been on the case file at the DLP, and it remains unexplained why it was not.”
Examining the claim by the labour department that the record was exempt, Dilbert disagreed as she said that there was no argument put forward by the authority why the document was exempt just because it came from government lawyers. She said the authority did not demonstrate why the subject matter of the advice, or the circumstances in which it was sought and rendered represented a solicitor-client relationship. Dilbert said the authority failed to show the communication occurred within a relevant legal context for legal professional privilege to attach to the record.
See the information commissioner’s decision below or visit the website here.
Tempura report release closer
(CNS) Updated with statement from the governor's office: The senior judge who heard legal arguments between the Information Commissioner's Office and the governor's office last week over a disputed report regarding an internal police probe has ruled that the ICO was right that defamation is not enough to withhold the document from release. However, Sir Allan Moses has ordered that the information commissioner re-hear further submissions from the governor's office about the matter of prejudice of public affairs as he found that not enough attention had been paid to this element of the law during the hearing. Following comment from the ICO on Tuesday, the governor's office issued a statement Wednesday claiming that the judge had "quashed the Information Commissioner’s decision" when he ruled that she had not considered the public interest test correctly over the conduct of public affairs.
On Tuesday morning the ICO explained that while the judge's ruling had not yet been released, he had cleared the way for the parties to reveal the outcome of his judgment.
“Important clarification of the law was achieved, as we now know that simply because a record may contain defamatory matter that will not be a basis upon which a public authority can withhold the record," Jennifer Dilbert, the information commissioner, stated. "This underlines the intent of the law, which is to provide transparency and accountability even where the content of records might be controversial.”
The office pointed out that having ruled out the issue of defamation, which was the major focus of the parties during the hearing, the senior UK judge, who visited the jurisdiction especially to hear this case, had determined that neither party had placed sufficient focus on the exemption related to prejudice to effective conduct of public affairs.
"As a result, the judge directed the governor develop and submit arguments confined to this exemption, and the commissioner is to reconsider the matter in light of these submissions and render a new decision," the office said. "We await the finalization of the detailed written judgment which will be made public."
The commissioner said that Lord Justice Moses had provided clarity on the application of the Freedom of Information Law in many key respects. Most importantly, it determined that records felt to contain any defamatory matter were not automatically exempt under the law, a conclusion reached by the commissioner in her decision that was the subject of the judicial review.
The governor's office commented on the judge's findings Wednesday in a short release.
"Lord Justice Moses ruled that section 54 of the Freedom of Information Law (FOIL), which relates to the disclosure of defamatory material, was not an exemption,"officials stated. "He also ruled that the Information Commissioner had not considered the public interest test correctly when interpreting section 20(1)(d) of the FOIL – that disclosure of the material would, or would be likely to, prejudice the conduct of public affairs.
'Lord Justice Moses therefore quashed the Information Commissioner’s decision and ordered her to reconsider it with reference to section 20(1)(d). He gave the Governor the opportunity to provide a submission on this.”
The judge has instructed the governor's office to re-submit arguments regarding the conduct of public affairs. However, with the defamation issue no longer a hurdle to release, that will remain the only area of consideration remaining to keep the document from release. It is not yet clear what timeline will be required for re-submissions and a new hearing and what further barriers the governor's office may depend upon if Dilbert still orders the release of the controversial document.
The record at issue is a report of a complaint made by the senior investigating officer in Operation Tempura, an internal police probe. Martin Bridger had complained to the governor about the way his investigation had been terminated, among other issues, and the report is an account of why his complaint was dismissed.
The report was then the subject of an FOI request. When it was declined, thesituation ended up as an appeal before Dilbert, who ruled that it was in the public interest to disclose the report. However, the governor's office then sought a judicial review to challenge the decision.
Parts of the report have already found their way into the British press but the document has so far remained under official cover here in the Cayman Islands and has not been leaked.
Judge’s FOI ruling remains a mystery
(CNS): Although Justice Sir Allen Moses came to a decision on Friday afternoon after listening to legal arguments submitted by the governor’s legal team and that of the information commissioner behind closed doors last week, he has not yet given an order about the release of his judgment, which was also delivered away from the public gaze. Both the Information Commissioner's Office (ICO) and the governor know what the judge has decided, but neither side can say whether or not it is in their favour. A spokesperson for the governor’s office told CNS that they have submitted a request to the judge for instructions and both parties are hopeful that they will be able to reveal the decision soon.
However, the secrecy continues around the issue, which concerns a ruling delivered by Jennifer Dilbert, the information commissioner, ordering the governor’s office to release a report that documents why a complaint made by the lead investigator on the controversial Operation Tempura internal police probe was not upheld by the governor’s office. With the ruling delivered behind closed doors and both parties still unable to discuss the matter, the document remains secret. It is not clear if the judge has ordered the report’s release and if so, whether the governor can appeal that decision, which would effectively continue to keep the lid on the report.
Significant details of the document has been disclosed, however, by the British press, which indicated that Bridger had reportedly complained about the way the investigation was terminated, among other issues, and made allegations against the local authorities and judiciary.
Although Bridger was allowed to see the review of his complaint and the reasons why it was dismissed, the document has remained secret for various reasons. When an applicant made an FOI request for it, the request was refused and subsequently the applicant appealed. Given the public interest and a host of other reasons, Dilbert ruled that the report should be released.
However, the governor filed for a judicial review of Dilbert’s decision and became the first public authority to challenge her in the court.
The legal arguments were heard before the visiting UK judge and focused heavily on the technical details of the freedom of information law and Dilbert’s interpretation, with only a short part of the hearing being conducted in public.
Check back to CNS for updates on this story.
Info boss awaits verdict
(CNS): After two days of mostly closed door hearings this week, visiting UK judge, Lord Justice Sir Alan Moses is expected to deliver his decision, Friday afternoon, in the first ever courtroom challenge to an order made by the information commissioner. The first public authority to defy an order to release a document by Jennifer Dilbert, who retires in December, was the governor’s office when it sought a judicial review after she ruled that it should release a controversial report relating to the bungled internal police probe, Operation Tempura. Lawyers for the governor’s office have argued on a number of grounds including defamatory content that the document should not be made public.
The irony of the closed door hearing in the first judicial review of a decision by the information commissioner has not been lost on most and the visiting judge is also going to deliver his ruling tomorrow behind closed doors but it is hoped that the ruling will still be made public regardless of the outcome.
See related story on CNS
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Public encouraged to ask for information
(CNS): Cayman will join 60 other countries on Saturday to celebrate the enshrined right of people to access information held by government under the freedom of information law. As part of the annual Right to Know celebrations, the The Information Commissioner’s Office (ICO) is encouraging people to use the law and seek the information they want or need. It is five years since the law was passed, and despite some issues regarding procedures, the law has had a significant impact on the relationship between the public and government. People are being asked to show their support for FOI by wearing blue on Friday.
As part of Right To Know Week, the ICO has already begun a busy schedule of events that celebrate the value of freedom of information and stress the importance of government accountability. Activities aim to educate the public and encourage people to learn about their rights under the Freedom of Information (FOI) Law, which not only allows for public access to government-held records but promotes accountability and transparency.
Information Commissioner Jennifer Dilbert encouraged everyone to take advantage of the opportunities provided by the Law,.
“Obtaining information from public authorities is simple and anyone can make a request in writing, including by email,” she said. “If you want to know information in government that pertains to you, then FOI is the key.”
For a full list of Right to Know Week events, contact ICO at 747-5402 or visit www.infocomm.ky.
Bad records undermine FOI
(CNS): After more than 3,000 freedom of information requests since the law that allows the public access to government records and information came into effect, the information commissioner said that Caymanians have embraced their rights under the law but poor record keeping is undermining the process. Speaking just months away from the office’s fifth anniversary and during the annual Right To Know Week, Jennifer Dilbert told CNS that she believes the law has made a significant difference to the amount of information now available in the public domain but the issue of poor record keeping is the root cause of the many procedural issues applicants face during requests.
Dilbert said there have been many times during the mediation period or during an appeal when the public authorities she is dealing with have refused access to applicants even before they find a record. She explained that authorities are refusing applicants when the documents have never even been examined, which is why the reasons for refusal often change throughout the process. When a document suddenly turns up, the authority realises they can’t refuse under the exemption they have cited so they rush to add another exemption or recognise that they must release the record.
“The procedural problems take up so much time during a hearing,” she said, adding that this had been the focus of meetings with her office, the deputy governor and the chief officers, who are taking the lead to ensure a more proactive releasing environment and better record keeping. The information commissioner said that the civil service heads were the key to improving the FOI regime as they could put pressure on the political arm of government, where ministers are trying to prevent information coming out, and on their staff to improve record keeping and proactive release.
Dilbert said that while many authorities were doing far better on proactive release and responding to requests, there was still some resentment from information managers when they receive requests requiring a great deal of work to find the records. Dilbert noted that sometimes requesters themselves could be more specific about what they are seeking to improve their chances of getting what they need more quickly. But she confirmed that the onus was on the information managers to help by contacting applicants and establishing exactly what documents, records or information they are actually seeking.
The commissioner emphasised the need for public authorities to embrace the spirit of the law and start from a position of releasing everything unless there was a legal reason not to, rather than looking at a record and trying to find a way not to release it. She said they should not look at the timelines in the law, such as the 30 day period for release, as a target but if they have the information and it can be released it should be given to the applicant at the earliest opportunity. Dilbert said there was no excuse or proper reason for authorities to sit on records until the last legal minute.
Some authorities, she explained, also saw statutory deadlines relating to her orders as targets. After being ordered to release a record following a hearing, authorities are given 45 days to apply to the court for a stay on her order ahead of a judicial review. That time line was not meant to give authorities another month and a half to withhold a record, she said, and on more than one occasion an authority with no intention of challenging the release in the courts has held onto records until midnight on the 45th day, showing a deliberate disregard for the law’s intent.
In general, however, Dilbert was pleased with the improvements in many public authorities, and said they were getting better at fighting the culture of closely guarding government information. But some government companies and statutory authorities, where board members come from the private sector, were still struggling with the fact thateverything they do can be made public.
Overall, a great deal of information that may never have seen the light of day has been released to the people. The public has thoroughly embraced the law and the publication of important information is more widespread than ever. Dilbert explained that access to information was much more than shining a light on government or making the public sector more transparent.
“There are times when people request and receive information that can change their lives,” she said, as she pointed to personal record requests to authorities such as the pensions board, the police, immigration or for personnel records that can help them resolve long term problems.
With her own retirement approaching at the end of the year, Dilbert said she would be still be behind her desk until 31 December, when Deputy Information Commissioner Jan Liebaers will hold the fort until a new person is appointed to head the office.
With some additional money in this year’s budget and an empty post now filled, Dilbert said that the office would be able to handle much more work and focus on some of the persistent procedural shortcomings that are the main barrier to a smoother FOI regime.
Emphasising the success of FOI in Cayman so far, she predicted an even brighter and more transparent future as the public sector gets increasingly accustomed to releasing information to the public.
See below for the report and article detailing statistics relating to FOI and for the events planned for Right to Know Week.