FI15858

Request

1. The official job title, salary band, and pay grade of the role of Head of Housing.

2. A copy of the job description and person specification used at the time of recruitment.

3. The qualifications and experience required at the point of appointment.

4. Whether the role was subject to an open recruitment process, including whether it was advertised internally or externally.

5. Details of the recruitment and selection process undertaken, including interview records, panel composition, and decision-making rationale.

6. The exact date of appointment and any formal internal or external notifications made.

7. Any documented discussions, meeting minutes, email correspondence, or internal records regarding the current postholder's suitability, eligibility, or approval for this position — including communication between HR, senior management, or elected members.

Response

The job description for the post of Head of Housing is attached.  The salary band for this post can be found on the Council’s website at https://www.dover.gov.uk/Corporate-Information/PDF/Council-Senior-Management-Structure-April-2025.pdf.  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:

I have reviewed the information provided and must formally request an internal review of your refusal to disclose the remaining details, including recruitment process records, candidate qualifications, and rationale for appointment.

The Council’s own job description for the role (Head of Housing) clearly outlines a requirement for:

  • A Level 5 Diploma in Housing (or commitment to complete it),
  • Considerable experience in managing statutory housing functions and interpreting complex regulations,
  • Evidence-based leadership with full accountability for staffing, compliance, and resident service delivery,
  • Demonstrable competence in recruitment, staff development, and performance management.

Yet your response makes no effort to confirm whether these requirements were met or how the current postholder was deemed suitable. Instead, Dover District Council has relied on Section 40(2) (personal data exemption) to withhold any transparency about this public sector appointment. 

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 Head of Housing, 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 pay grade of the role.   -  

Provided – details published on website, link already provided

2. A copy of the job description and person specification used at the time of recruitment.  –

The attached Candidate Pack outlines the job description, person specification, qualifications and experience that the role required

3. The qualifications and experience required at the point of appointment.  

This information is included within the Candidate Pack attached.

4. Whether the role was subject to an open recruitment process, including whether it was advertised internally or externally. 

The Head of Housing role was advertised internally.

5. Details of the recruitment and selection process undertaken, including interview records, panel composition, and decision-making rationale.  

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 Personal data.

6. The exact date of appointment and any formal internal or external notifications made. 

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 Personal data.

7. Any documented discussions, meeting minutes, email correspondence, or internal records regarding the current postholder's suitability, eligibility, or approval for this position — including communication between HR, senior management, or elected members. 

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 Personal data.

Attachment - Internal Review