FI15857
Request
1. The official job title, salary band, and grade for the Housing Manager (Income and Systems) post.
2. The date the current postholder was appointed to this role.
3. A copy of the job description and person specification for the position.
4. The qualifications and professional experience required for the role at the time of appointment.
5. Whether the position was advertised internally or externally, and whether interviews were conducted.
6. Details of the recruitment or promotion process used to appoint the current postholder to the role, including who authorised the appointment and whether any competitive or formal process was undertaken.
7. Whether there were any minuted discussions, emails, or written records between HR or senior management and the Housing Operations Manager concerning the postholder's promotion at the time it occurred.
Response
The job description for the post of Housing Manager (Income and Systems) is attached. The rest of the information you have requested is considered personal data and therefore exempt from disclosure under Section 40(2) of the Freedom of Information Act. Information about individual members of staff is considered personal data as defined by Article 4(1) of GDPR and also Section 3 of the Data Protection Act 2018 and the release of this data would contravene the data protection principles.
Attachments
Attachment
Internal Review Documents
Internal Review Request:
There was no consultation, communication or organisational update issued regarding the role being redefined to include "Systems". This pattern – the quiet reallocation of duties and the sudden emergence of new roles without due process – aligns with the broader dysfunction. The refusal to disclose how this post was created, who approved it, or how it was filled, only reinforces the impression of deliberate opacity and damage limitation by the Council.
I therefore formally request an internal review of both FOI responses on the following grounds:
- Over-reliance on Section 40(2) where a public interest test should clearly favour transparency.
- Failure to disclose process-based information that does not constitute personal data.
- Emerging evidence that role creation and recruitment processes may have been misused to protect senior staff or marginalise others.
Internal Review Response:
In undertaking this review I have had to make consideration of the Data Protection Act and what information is classed as personal data. Section 3(2) of the DPA defines personal data as: “any information relating to an identified or identifiable living individual”. An identifiable living individual is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual. Information will relate to a person if it is about them, linked to them, has biographical significance for them, is used to inform decisions affecting them or has them as its main focus.
In respect of your request for information relating to the appointment of the Housing Manager (Income and Systems), you were provided with the Job description and person specification. For ease of reference I have broken down your request and provided my findings against each individual point.
1. The official job title, salary band, and grade for the Housing Manager (Income and Systems) post.
Job title – already provided, as included within the Job description
Salary band – this would be considered personal data and therefore exempt from disclosure in accordance with Section 40 of the Freedom of Information Act.
Grade – this is personal data and therefore exempt under Section 40, as above.
2. The date the current postholder was appointed to this role.
The appointment to the role is personal data and exempt under Section 40, as above.
3. A copy of the job description and person specification for the position.
Already provided
4. The qualifications and professional experience required for the role at the time of her appointment.
Included within the Person Specification which has been provided.
5. Whether the position was advertised internally or externally, and whether interviews were conducted.
This was a re-evaluation of an existing post in accordance with the Council’s Job Evaluation Scheme.
6. Details of the recruitment or promotion process used to appoint the current postholder to the role, including who authorised the appointment and whether any competitive or formal process was undertaken.
The Job Evaluation Scheme was utilized to re-evaluate the postholders existing post. As part of the Job Evaluation Scheme, employees must obtain Director and Head of Service approval before submitting an initial job evaluation request. The request is then assessed by different assessors for approval.
7. Whether there were any minuted discussions, emails, or written records between HR or senior management and the Housing Operations Manager concerning the postholder's promotion at the time it occurred.
This would be classed as personal data relating to a third party and therefore exempt from disclosure in accordance with Section 40 of the Freedom of Information Act.