Staffordshire: Our submission to the Information Commissioner

Sunday, 20 December 2009

Our submission to the Information Commissioner

You can download a copy of the response here

1    Introduction

The DCSF Information Rights Manager, Mr Andrew Partridge, wrote to Mrs Stafford about her Freedom of Information requests and other communications with the Department on the 13^th November 2009; hereafter called the Partridge letter (Partridge, 2009). This supporting paper to the Information Commissioner outlines why Mrs Stafford is complaining about the Department's decisions regarding five information requests (2009/0067849; 2009/0074942; 2009/0074943; 2009/0090673; and 2009/0090678) and two other requests (2009/0059859 and 2009/0062825) where there is outstanding correspondence related to internal reviews.

The paper begins by attempting to reconcile the number of information requests stated in the Partridge letter (15) with the number that appears on Whatdotheyknow.com (12) (Section 2). The history and context to Mrs Stafford's requests is outlined (Section 3). The paper then considers in detail why the Section 14(1) and Section 14(2) exemptions have been erroneously applied by the DCSF (Section 4).

Annex A provides a timeline of the Review and Mrs Stafford's information requests.

2    Reconciling DCSF and WhatDoTheyKnow.com data on Freedom of Information requests

All of the information requests submitted by Mrs Stafford to the Department for Children, Schools and Families (DCSF) were made using the WhatDoTheyKnow.com website. According to this website she has submitted 12 information requests to DCSF (see Table 1). However, the Partridge letter identifies 15 information requests; 10 successful and five rejected.

Of the three 'missing' requests, the Partridge letter suggests that one arises because the DCSF treated a clarification to request 9 (2009/0074965) as a new information request (2009/009673) – and to reflect this Table 1 shows a 9a and 9b. As the DCSF's letters posted on WhatDoTheyKnow.com do not inform Mrs Stafford of when the Department decides that what is for her an ongoing request is, in fact, a new request it is difficult to identify the other two (successful) information 'requests'. However, it is possible that the Department treated a follow-up to request 11 (2009/0079644) as a new request (2009/0082698). Nevertheless, according to the Partridge letter, this leaves one information request attributed to Mrs Stafford unaccounted for.

Table 1:    Freedom of Information requests summary

Number	Subject of request	Initial reference number	Other reference numbers	Start date (2009)	Finish date (2009)	Number of working days	No. of times internal review requested	Outcome	Comments
1	Literature Review produced for Graham Badman's Report on Elective Home Education	2009/0053009		13 06	29 07	32	2	Successful - literature review made available
2	Evidence in support of Badman's report	2009/0059859	2009/0075295 2009/0079990 2009/0080057	01 07	13 11	97	2	Rejected	2009/0077597^# 2009/0077887^# Relates to statements attributed to Badman reported in the media
3	Post Report of the Review of Elective Home Education briefings given to anyone by Graham Badman or anyone else from or associated with the DCSF	2009/0062825	2009/0070413 2009/0081535	11 07	13 11	72	1	Rejected	Concerns post-publication briefings by Badman. The DCSF response is that no briefings took place.
4	Frequency count of responses to the Review of Elective Home Education	2009/0065106		19 07	17 8	21	0	Successful – summary data released	Refers to the online public consultation exercise
5	A summary of the answers to question 22/51 of the questionnaire to local authorities for the Badman Review of Elective Home Education	2009/0076600	2009/0067849	28 07	13 11	61	1	Rejected
6	Questions in the In Depth Survey to 25 Local Authorities in the Badman Review of Elective Home Education	2009/0068590		30 07	27 08	21	0	Successful – Questionnaire released	Request for copy of second questionnaire - also released to Ms Deuchars on 24^th August
7	Clarification of the data in the Explanatory note for the Badman Review Report	2009/0083915	2009/0074942	27 08	13 11	57	1	Rejected	Follows up specific findings reported in the safeguarding working paper
8	More clarification of the data In the Explanatory Note produced for the Badman Report	2009/0074943	2009/0081887	27 08	13 11	57	1	Rejected	2009/0075134^# Follows up specific findings reported in the safeguarding working paper
9a	Request for Annex A referred to in the Explanatory Note connected with the Badman Review	2009/0074965	2009/0081882 (2009/009673)	27 08			1		A request for Annex A mentioned in the serious case review section of the safeguarding working paper
9b		2009/009673			13 11	57		Rejected	The DCSF seems to have treated a clarification as a new FOI request
10	Who Initiated the Request for Supplementary Evidence to Support the Badman Review of Home Education	2009/0079983	2009/0087703	18 09	20 10 09	23	1	Successful
11	Remuneration for Graham Badman for call for more evidence for Select Committee Inquiry into his Report on Elective Home Education	2009/0079644	2009/0082698	18 09	15 10	20	0	Successful	Possibly the DCSF records this as two separate FOIs
12	Data quality checks on Badman's third local authority survey.	2009/0090678		26 10	13 11	13	0	Rejected

Notes:

Case numbers in italics are those listed as rejected or outstanding FOIs in Annex A of Partridge letter.

^# Mrs Stafford does not appear to have been informed of three of the 12 unanswered case numbers listed in Annex A of the Partridge letter. Based on information in the letter, the case number may refer to information requests listed in the relevant row.

As a consequence counts based on actual requests made using WhatDoTheyKnow.com do not match those mentioned in the Partridge letter:

WhatDoTheyKnow.comPartridge letter
Successful5Full answer6Partial1Information not held2Information elsewhere1Rejected75Total1215
Presumably the seven rejected requests on WhatDoTheyKnow.com include the two requests the DCSF said they did not hold the information and/or the request where information was held elsewhere.

Mr Partridge complains, in part, about the number of information requests submitted by Mrs Stafford. However, this situation is partly due to how the Department manages information requests. If the DCSF fails to inform people making information requests that an ongoing request has in fact generated a second request, it is not surprising that the DCSF believes the Review of Home Education has generated so many information requests. However, it does not follow that citizens progressing a request are aware of how the DCSF is counting requests. Certainly there is nothing in the correspondence to Mrs Stafford that the DCSF believes she has made three more requests than actually submitted using WhatDoTheyKnow.com.

In addition, there are three case number references included in Annex A of the Partridge letter that do not appear to be given in any of the Departmental correspondence posted on WhatDoTheyKnow.com. The relevant case numbers are: 2009/0075134, 2009/0077597 and 2009/0077887. Based on associated information given in the Partridge letter these case numbers have been tentatively assigned to information requests in Table 1 (requests 2 and 8).

Mr. Partridge complains that Mrs Stafford in correspondence following up an information request did not always include the case number. However, her letters were created by WhatDoTheyKnow.com and there is nothing on the website nor in the template letter it generates to suggest that a case number should be included in any subsequent correspondence. Although a DCSF official did try to clarify the need for case numbers in one posting, providing these case numbers is made difficult if, as here, Mrs Stafford was not informed of all relevant case numbers.

3 Context and history

The establishment of the Review of Elective Home Education in England by Graham Badman was announced on the 19th January 2009 and the report published on the 11th June 2009., It is argued here that the Freedom of Information requests submitted by Mrs Stafford are because the DCSF failed to publish a Review report that provided a full, accurate and comprehensive account of the Review's evidence base. As a consequence the responsibility for the workload generated by the Freedom of Information requests rests entirely upon the Department. Mrs Stafford and her husband, Professor Stafford, would have preferred not to have submitted any information requests. However, the published report is so lacking in the evidence that a reasonable person might expect to see that there was a degree of inevitably about the information requests. If they had not been submitted by Mrs Stafford similar requests would have been made by other parents who home educate their children.

3.1 DCSF created the conditions that generated the Freedom of Information requests

In a Ministerial Statement accompanying the publication of the Review's report the Secretary of State for Children, Schools and Families, Ed Balls, stated:

I am grateful to Graham Badman and the review team for conducting a thorough review which carefully considered extensive evidence provided by home educators; local authorities (LAs); and representatives from a wide range of organisations and individuals working with children and parents involved in home education.

Furthermore, he said:

The review makes a compelling case for substantial changes to the arrangements for supporting and monitoring home education.

That claim was repeated in a press release by the Children's Minister, Delyth Morgan. A reasonable person, therefore, would expect that the published report included robust and extensive evidence that supported the Review's recommendations.

However, in terms of quantity and quality there is a lack of evidence in the Review's published report:

The review included a literature review (Badman, 2009a:4) yet it is neither summarised in the main body of the report, nor published as either an annex to the report or as a freestanding publication.

The results of the on-line public questionnaire and interviews with home educators are only cursorily summarised in paragraph 4.2 of the published report (Badman, 2009a:12). This paragraph gives an indication of the range of responses, but not the magnitude of support or opposition to further reform, because it fails to quote percentages from the consultation exercise (Badman, 2009a:Annex C).
There are no tabulations or graphs presenting findings for the survey conducted of local authorities (Badman, 2009a:Annex D), instead there are cursory references to the questionnaire, interviews, conversations and visits to local authorities (see Badman, 2009a:15, 21, 28). Notwithstanding Freedom of Information requests for summary findings for the first questionnaire of local authorities, only selected findings have been placed in the public domain.
In addition, the representativeness of the survey of local authorities is not discussed anywhere in the report. Whether the survey sample is representative is important because if the sample was biased the resulting estimates would not be valid. However, readers are informed that only 90 local authorities replied, but whether they are typical of all 150 local authorities is not mentioned, nor whether the data were adjusted to take account of any non-response bias in any analyses.
The Review document states at paragraph 8.12:

'… on the basis of local authority evidence and case studies presented, even acknowledging the variation between authorities, .the number of children known to children's social care in some local authorities is disproportionately high relative to the size of their home educating population …'

This is the only substantive statistical claim made in the report which suggests there is a policy 'problem' to be addressed. Moreover, there are a number of shortcomings with the statement:
- The actual estimates for the proportions and numbers of home educated and non-home educated children 'known to social care' are not presented in the published report.

Press reports of the publication of the Review's report allege that Badman said that twice as many home education children were known to social care compared to the rest of the population – a claim not made in the report. That this statement was made in media briefings further highlights the importance of paragraph 8.12. Not surprisingly many parents who home educate would like to know the statistical basis for the claim. Mrs Stafford's information request number 2 (2009/0059859) relates to the media coverage and the 'twice as likely' claim. Subsequently, evidence related to paragraph 8.12 was release by the DCSF to other people making Freedom of Information requests, and this is discussed further below. As discussed below, several of Mrs Stafford's subsequent Freedom of Information requests follow-up this subsequent 'evidence'. The key issues pursued relate to identifying the actual data source and the representativeness of the data.

(Mrs Stafford's request 3 (2009/0062825)
sought to establish if, in addition to the media, other parties could have been told that twice as many home education children were known to social care compared to the rest of the population.)

Nor does the report highlight that 'known to social care' covers a number of administrative categories some of which cannot be interpreted as meaning that there is a safeguarding problem with home educated children. For example, Section 47 cases under the Children Act 1989 not only include child protection inquiries but also referrals to social care irrespective of whether or not child abuse is subsequently established. It is likely that home educators are, wrongly, over-represented amongst Section 47 referrals because (concerned) third parties, unaware of the legal right to educate at home, mistakenly contact social services. So unless the statement excludes Section 47 figures, it over-estimates the number of 'at risk' cases amongst the home educating community. The lack of detail in the report means that whether the 'known to' proportion mentioned in the paragraph includes Section 47 cases is unknown.
The data source for the claim in paragraph 8.12 is not given. It is not the survey of local authorities presented in Annex D, as it contains no questions on 'known to cases'.

The review included case studies, and there are four local authority 'case studies', although they more accurately resemble 'pen pictures' (Badman, 2009a:15-16) and there is a passing reference to 'case studies' in paragraph 7.1 in connection with SEN children educated at home (Badman, 2009a:24). However, there is no justification provided for the selection of these case studies (that is, what criteria were used), and no details about how the data were collected or analysed.
A brief reference is made to an (unpublished) analysis of case reviews (Badman, 2009a:29-30), but no information on what cases were studied, and no full account of the findings of the analysis is given in the report, although paragraph 8.12 also states

'… despite the small number of serious case reviews where home education was a feature, the consideration of these reviews and the data outlined above, suggests that those engaged in the support and monitoring of home education should be alert to the potential additional risk to children. So saying is not to suggest that there is a causal or determining relationship, but simply an indication of the need for appropriately trained and knowledgeable personnel.' (Badman, 2009a:30-31)

There is a reference to an unidentified 'small study' by OFSTED conducted in 2008 on local authorities' policies to manage risks for home educated children (Badman, 2009a:30-31).
There is limited referencing of relevant social research (Badman, 2009a:3, 8, 12, 18, 32).

Alongside this paucity of evidence are a series of assertions made by the author that are not supported by evidence or references to published sources. The author simply says 16 times 'I believe …'. The Review is also inconsistent in how it treats research. It claims that the sample sizes for some studies were too small for findings to be generalisable to the whole population. Yet it quotes from a qualitative study on reasons why parents home educate (Hopwood,V.,O'Neill, L., Castro G. and Hodgson, B. (2007) The Prevalence of Home Education in England: A Feasibility Study, DfES, Research Report 827) that is based on an opportunistic sample of 18 parents in nine areas; and references another small scale study (Kendall S. & Atkinson, M (2006) Some perspectives on home educated children, NFER) based on 21 interviews with local authority staff in 16 areas.

Furthermore, the review's recommendations are controversial as it makes proposals that adversely affect the civil liberties of home educators. The report recommends an intrusive control and monitoring system for those opting to home educate. Under these circumstances it is not surprising that some home educators seek clarification of the report's evidence base.

Arguably, Freedom of Information requests to obtain the evidence missing from the report are reasonable; indeed, it is information that a reasonable person might expect to find in the report. Information request 1 (2009/0053009) was submitted to obtain the literature review and request 4 (2009/0065106) to obtain findings for the public call for evidence. As already mentioned above request 2 (and some subsequent requests discussed below) relate to the only significant statistical claim made in the report (paragraph 8.12).

In summary, had the Department published a report that was 'fit for purpose', Mrs Stafford and many other home educators would not have had the need to devote considerable time and effort in trying to access the review's unpublished evidence.

3.2 Responses to early FOIs raise serious concerns about review's evidence base

Paragraph 8.12 generated a number of Freedom of Information requests by home educators. Unfortunately, once the DCSF began to answer people's Freedom of Information requests on paragraph 8.12 this only raised further concerns about the quality and validity of the review's findings and the competence with which it had been conducted. The concerns raised are non-trivial.

There are two inter-related issues – a second survey of local authorities and the release of an 'annex'/working paper – which directly lead to four of Mrs Stafford's Freedom of Information requests. These issues are discussed below:

In departmental responses to a Freedom of Information requests by Ms Deuchars and Mr Mckie both dated the 24^th August 2009 it emerges that there was not one but two surveys of local authorities. The second survey was administered to the 90 local authorities who responded to the first survey. There is no mention of this second survey in the published report. The DCSF letter gave no explanation as to why this second survey was not mentioned in the published report. This second survey is important because (unlike the first survey) it included questions on children 'known to social care', and given the sensitivity of this subject the omission of this survey from the report is difficult to understand.

However, there are a number of concerns about any derived estimates from this second survey questionnaire:

The data sought includes open and closed cases of 'known to social care'. But the data will not be comparable because of differences in the composition of the elective home education population in each local area. The questionnaire ought to have collected more data on the make-up of the population so that it could be weighted to make it comparable between local authorities.
It only collected data on home educated children, and so should not have been the basis for the claim made in paragraph 8.12 – which requires comparable data for both home educated and school educated children.
As several local authorities only provided a total 'known to' figure the DCSF is unable to disaggregate the data by different legal/administrative categories and so the data are difficult to interpret (see discussion f Section 47 above).

In addition, of the 90 local authorities only 25 responded. Neither the letters of the 24^th August nor any subsequent responses by the Department have addressed the representativeness of this sample. Given how the sample was obtained and its small size, the absence of any discussion about the representativeness of the sample is a serious omission because doubts remain about the quality of the evidence. Local authorities that responded to the questionnaire might not be representative of all local authorities, and as a consequence any findings from the survey are biased.

On the 24^th July the DCSF selectively released information from a working paper, 'Independent Review of Home Education - safeguarding evidence', that summarised information obtained from the two local authority surveys. Labelling the extract 'annex' caused some confusion amongst home educators; and in responses to subsequent requests the DCSF had to explain that it was an annex to the Freedom of Information requests, and not an annex to the Badman report. Eventually the Department released the entire working paper to Ms Deuchars on 26^th August 2009. The Department could have saved itself and home educators' considerable time and effort if the information in the working paper had been quality assured and included in the published report.

The 'annex' was released to Mr Maxwell on the 23^rd July 2009 in response to a request for information on the number of home educated children known to social care, and the request makes explicit reference to paragraph 8.12. The 'annex' was also released separately to Mr Mckie and Mr Machin on the 24^th July 2009 who made similar requests and either explicitly mentioned paragraph 8.12 or quoted from the paragraph. It is possible that the 'annex' (or later on the working paper) was released to other people making requests related to paragraph 8.12. These departmental responses established in the minds of home educators that there was a connection between the two local authority surveys and the 'disproportionally higher' statement in paragraph 8.12. In particular that, notwithstanding the shortcomings of the second survey mentioned above, it was the evidential basis for paragraph 8.12.

However, the working paper released to Ms Deuchars was prefaced by an 'Explanatory Note' stating that:

"The statement in para 8.12 in the Badman report '….the number of children known to children's social care in some local authorities is disproportionately high relative to the size of their home educating population…' is based on the raw data returns from LAs, rather than directly from the information contained in this working paper."

So in response to several Freedom of Information requests that explicitly ask for the evidence underpinning paragraph 8.12 of the Review's report, the DCSF released extracts from a working paper that did not directly provide the information requested. This might be because, as many DCSF responses stress, the data in the 'annex'/working paper had not been quality assured and so was not suitable for publication. At the time of writing this paper and in the light of the explanatory note the statistical basis for paragraph 8.12 continues to remain unclear.

Moreover, in a response to L Bone on the 29^th September the Department releases the 'annex', again in response to a query about paragraph 8.12, but admits that it contains an error, which did not affect the 'overall findings at paragraph 2.12.' Hence nearly five weeks after a working paper is released with an explanatory note saying that the information it contains was not directly used to underpin paragraph 8.12, the DCSF is still releasing an extract that implies a connection between the local authority surveys and paragraph 8.12.

The working paper does include information on serious case reviews, and this may or may not be the analysis of serious case reviews mentioned in the published report.

Four of Mrs Stafford's information requests relate to the second local authority survey and paragraph 8.12 (and these requests follow up information released as a result of other people's requests):

Request 6 (2009/0068590) successfully asks for a copy of the second local authority survey questionnaire.
Requests 7 (2009/0083915), 8 (2009/0074943) and 9 (2009/0074965) unsuccessfully follow up specific findings reported in the safeguarding working paper.

Concerns about the data underpinning paragraph 8.12 could easily have been addressed by DCSF through one of the many Freedom of Information requests made by Mrs Stafford or by a number of other home educators. Its failure to do so only raised doubts about the sources used. In general, trying to establish the evidence base for paragraph 8.12 has been frustrating and resembled 'peeling an onion' with many Freedom of Information responses just leading to further questions. The need for follow-up FOIs could have been avoided if the DCSF had initially published a Review that included all the relevant evidence.

3.3 Other sources raise further doubts about the integrity and reliability of the evidence base

Alongside queries about the robustness of the data used in the Review, other concerns emerge about its use of evidence.

The published Review includes at least two instances of highly selective quoting that do not provide a full and fair representation of the evidence submitted. Firstly, the report contains a quote from a home educator that is less than complimentary about local authority staff:

"'… no one from the LA [local authority] would in my opinion be on my child's intellectual level or they wouldn't be working for the LA.'

Badman (2009a:11)

Leaving aside the questionable motives for the inclusion of this quote, the Report fails to give the apparent context to the observation:

'It was in response to a question about whether a scientifically gifted child would benefit from having a science teacher from the LA come and give them tuition. It was to point out that scientists at the top of their profession are rarely working for the LA, so anyone sent out would not be on the same intellectual level as the scientifically gifted child.'

Secondly, the Review selectively quotes from a submission from the Education Division of the Church of England. The report includes a fairly lengthy extract that expresses their concerns about home education. However, the Review does not quote the Church's overall conclusion:

'10 We have seen no evidence to show that the majority of home educated children do not achieve the five Every Child Matters outcomes, and are therefore not convinced of the need to change the current system of monitoring the standard of home education. Where there are particular concerns about the children in a home-educating (sic) this should be a matter for Children's Services.'

The report omits the Church's view that they are not convinced of further reform, yet it does quote their concerns. Although the Church gave permission for the quote to be included in the report, an email from a Church representative says that at the time they were unaware of the report's content and are now 'not comfortable' with the selective use of their evidence.

These two instances of failing to provide a full and honest account of the review's evidence are critical to understanding Mrs Stafford's dealing with the Department. The selective use of quotes in the report showed that evidence was not necessarily being fairly and accurately presented, and helped to create a climate in which statements by the DCSF could no longer be simply trusted. In effect, the DCSF 'lied by omission' and this reinforced the need for 'healthy scepticism', in particular that the report and any associated Freedom of Information responses needed to be carefully scrutinised and, if necessary, challenged by following up any emerging queries. Through publishing a report that included highly selective quoting, the DCSF created the conditions in which home educators were likely to query Freedom of Information responses and request further clarification– a situation that would not have arisen had the DCSF published a report that was more 'balanced' in these two instances. In this context it is not surprising that answers to Freedom of Information requests could generate further requests.

That the Department behaved in this unethical way is also an important part of the context to Mrs Stafford's subsequent comments in annotations to Freedom of Information requests on Whatdotheyknow.com (and this is discussed further below).

The selective use of quotations has seriously damaged the reputation of the DCSF in the home education community.

Other home educators and commentators have also highlighted the conceptual confusion underpinning the report. It confuses safeguarding and educational issues and also safeguarding with child protection.

3.4 The third survey of local authorities

On the 22^nd July 2009 the Children, Schools and Families Committee announced a short inquiry into the Review of elective home education. Badman writes to the Directors of Children's Services on the 17^th September asking them to complete a third questionnaire. Thus 14 weeks after the publication of the review yet another survey to establish the evidence base was being conducted by the DCSF. In the letter Badman accepts that the sample sizes for previous surveys were small and that this third survey was prompted by the Select Committee's inquiry:

'… it was a small sample and we would like to supplement this data in order to provide more statistically rigorous information to the Select Committee about safeguarding and educational issues that affect home educated children.'

Badman (2009b:2)

The third survey is important, because for the first time the Review is seeking data (on Child Protection Plans) that could be comparable with the national population (as recorded on a CPR3 return) (but see below) (Badman, 2009b:2). Local authorities had to reply by the 1 October 2009. However as submissions to the Select Committee had to be made by the 22 September 2009, there was no opportunity for home educators to comment on, or query, in their submissions any evidence arising from this third survey. In a letter to the Select Committee's chair dated the 9^th October 2009 Badman outlines the findings from the third survey of local authorities (Badman, 2009c).

A reasonable person might expect that given public concern about the representativeness of the previous two surveys that details would be given about the representativeness of this latest survey. However, the letter simply asserts that it was a representative sample (Badman, 2009c:3). Whilst the response rate was 49 per cent (74 out of 150 local authorities responded), that nearly half replied does not make the sample representative – because the half that did not reply might be very different from those that did.

Given the uncertainty about the quality of the data supporting paragraph 8.12 and the failure to provide the context to quotes in the report, it is reasonable to be sceptical about the representativeness of the sample for the third survey. Indeed, there are reasons to believe that the sample tends to over-represent those local authorities with a larger proportion of the child population. Badman states that the mid-2008 population estimate for the 74 local authorities was 4,303,700. The same mid-year population estimates show that the number aged 5 to 16 years was 7,201,400. This means that the 74 local authorities covered 60 per cent of children of school age, and the 52 per cent that did not respond to the third survey include 40 per cent of the child population. The implication is that the sample is biased.

In addition, there are concerns about what data were collected. For instance, the third survey collected data on child protection plans, but not on children in care who may not have a child protection plan. To provide a valid measure of children at risk data on both needed to be collected.

Mrs Stafford's 12^th information request (2009/0090678) explores the representativeness of the third local authorities sample and checks made on data quality. Two other information requests, 10 (2009/0079983) and 11 (2009/0079644) relate to circumstances surrounding the initiation of the third survey.

4 DCSF grounds for refusing Mrs Stafford's information requests

The DCSF rejects Mrs Stafford's outstanding information requests on the grounds that:

they are vexatious under Section 14(1) of the Freedom of Information Act 2000; and
they are repeat requests under Section 14 (2) of the Act.

4.1 Vexatious requests

The Department applies the Commissioner's guidance (ICO, 2008a:2) and finds that (Partridge, 2009):

The requests are not obsessive
The requests were harassing the department and causing distress to staff
The requests do impose a significant burden
It has no view on whether or not the requests were designed to cause disruption or annoyance
The requests had a serious purpose and value

4.1.1 The requests were harassing the Department and causing distress to staff

This is an objective test and '… a reasonable person must be likely to regard the request as harassing or distressing' (ICO, 2008a:5). Relevant factors include … the volume and frequency of correspondence, the use of hostile, abusive or offensive language, an unreasonable fixation on an individual member of staff, or mingling requests with accusations and complaints.' (ICO, 2008a:5-6). These are discussed in turn below.

A very high volume/frequency of correspondence

The Partridge letter claims Mrs Stafford made 15 information requests. From Mrs Stafford's perspective, and as recorded on Whatdotheyknow.com, she made 12. That the DCSF generated three additional requests from her initial requests is not her fault, especially when the Department did not inform her that they had done so. The difficulty of reconciling the number of known information requests on Whatdotheyknow.com with the Partridge letter has already been mentioned above.

The difference between 15 and 12 may seem small, but in percentage terms it is 25 per cent. Partridge claims that between 11 June and 27 October eight other home educators made 59 information requests (74-15), but if the number is similarly inflated by the Department this would give 47 requests, and the total number of requests on home education would reduce from 107 to 86. (The letter says these were on home education and whilst it is likely that they all relate to the Badman Review this is not certain.)

Mrs Stafford had absolutely nothing to do with the information requests submitted by others (see below) and accordingly it is unfair to include her requests with these other eight people. So the issue is whether a reasonable person would consider 12 or 15 requests over the relevant period as 'high'. Arguably the volume is not high because:

The need for the requests was driven solely by the DCSF's initial deficient report and its subsequent ad hoc release of information. There would have been fewer or no requests had the DCSF published a fit for purpose report or taken the initiative and made a full and frank disclosure of the evidence base once the shortcomings of the report had become apparent.

It represents an average of only one request every nine days. Given the serious shortcomings in the evidence base of the report and the draconian nature of the recommendations this seems a relatively modest number of requests.
Mrs Stafford had to issue ten internal reviews because DCSF had not met the 20 day target – inevitably this will have generated additional correspondence.
External factors gave urgency to Mrs Stafford's requests. The DCSF had set a closing date of 19^th October 2009 for the consultation on the recommendations and the Government had announced that legislation would be introduced in the Queen's Speech. The Select Committee subsequently announced that submissions had to be made by 22 September 2009. This timescale for consultation and submissions inevitably created a 'window' within which Freedom of Information requests had to be made. It is, therefore, somewhat disingenuous of DCSF to complain about the number of requests over this period of time, as they are wholly responsible for the tight timescales and (as previously mentioned) published a deeply flawed report.
The Department acknowledges that Mrs Stafford's requests had serious value and purpose and so given the factors mentioned above she had to make the requests when she did.

The Partridge letter notes that Mrs Stafford has made 15 information requests to other public authorities. The relevance of this observation is unclear. Whether someone has made information requests on a related subject should not be a material factor in the Department addressing requests made to it. Given the Department's concern about the diversion of resources, it is very surprising that staff devoted time to investigating the other requests made by Mrs Stafford. Whilst Mrs Stafford did not engage in a campaign against the DCSF, she was asked by another home educator to issue information requests to selected local authorities. The object was to collate robust data on local authority concerns about the provision of suitable education. In effect a group of home educators had to collect data that should have been included in the Review's published report. This is not an exercise that Mrs Stafford and other home educator should have had to do, and it further highlights the paucity of evidence presented in the Review's report. It does, however, explain the other Freedom of Information requests she has made.

The use of hostile, abusive or offensive language

The Partridge letter alleges that Mrs Stafford has harassed staff at the DCSF, and provides examples in Annex B. It should be noted that Mrs Stafford never intended for her requests to be harassing or distressing – given the threat that the Review poses getting replies to the requests was far too important to risk not getting a response from DCSF. Indeed, once the context of her comments are taken into account it is clear that the examples provided do not demonstrate use of hostile, abusive or offensive language against DCSF staff. Table 2 takes each of the comments made by Mrs Stafford listed in Annex B and discusses them in turn. For reasons of brevity, the individual circumstances of each comment are not repeated in the main text of this paper.

Annex B of the Partridge letter lists 12 examples of 'communications and other factors which have harassed or distressed'. Of these, four relate to correspondence with DCSF and eight are annotations. It is not clear why any annotation should cause an official distress, because they should not be aware of their existence. Annotations on Whatdotheyknow.com are not part of an information request, indeed they are not submitted to the Department:

'Annotations are so anyone, including you, can help the requester with their request. For example:

Link to the information requested, if it is already available on the Internet.
Suggest where else the requester might find the information.
Offer better ways of wording the request to get the information.
Advice on how to get a response that will satisfy the requester.

Annotations will be posted publicly here, and are not sent to Department for Children, Schools and Families.'

(Taken from http://www.whatdotheyknow.com/annotate/request/evidence_in_support_of_badmans_r on 6^th December 2009)

Departmental staff would only be aware of the annotations if they deliberately went looking for them – but there was no need for them to do this. Given this, the annotations should not be considered as material factors in assessing whether or not Mrs Stafford used hostile, abusive or offensive language because it is likely that staff could probably find material that they disliked for a great many Freedom of Information requests if they devoted sufficient time and resources to the searches.

Mr Partridge acknowledges that delays by DCSF could have caused 'frustration' (Partridge, 2009:3). However, this fails to recognise the seriousness of the impact of the delays. Whether intended or not, the delays effectively restricted legitimate democratic scrutiny of the evidence by those people most affected by the proposed changes.

In addition, in handling Mrs Stafford's and other home educators' Freedom of Information requests, the DCSF have arguably breached the Civil service code of conduct, which states:

'deal with the public and their affairs fairly, efficiently, promptly, effectively and sensitively, to the best of your ability;
handle information as openly as possible within the legal framework …'

Mrs Stafford's correspondence should also be seen in the context of:

This was the first time Mrs Stafford had used the Freedom of Information Act, she had to learn how to make and word requests.
If requests had been answered within the target of 20 days the follow-up correspondence (including internal review requests) and annotations simply would not have been necessary.
The timescales home educators had to meet in order to respond to the consultation on the recommendations and to make submissions to the Select Committee meant that quick and prompt responses were paramount.

The Partridge letter makes a number of observations, some of which are addressed elsewhere in this paper; however, a response is required to the other points made (Partridge, 2009:3-4).

Mr Partridge (2009:3) notes 'the availability of ample other opportunities and means to communicate views or concerns to the Government and to the Children, Schools and Families Select Committee …'. This is disingenuous because to do so would have required the publication of a report that in evidential terms was 'fit for purpose'. The failure of the DCSF to provide the unpublished evidence severely limited Mrs Stafford's contribution in these other spheres.

Table 2: Comments on Annex B of the Partridge letter

Annex B allegation	*Information request number^/ source**	Comments
Correspondence 1: an allegation (mentioned above in Annex A) that the Department has lied in its response to the effect that information was not held.	3	Mrs Stafford's comment made on 24^th September 2009: 'As you have now released a couple of scribled (sic) notes from the press briefing I think I can conclude that this answer is a lie.' Note: 1) The accusation of lying refers to the response received on the 28^th August 2009 and is not directed at the member of staff who wrote the letter. 2) The initial information request asked: 'Please could you supply me with a list of those individuals and organisations that recieved (sic) a briefing or similar contact following the publication of the Report of the Review of Elective Home Education, by Graham Badman, another member of the review team or anyone else from or associated with the DCSF?' The reference to 'briefing' would include media briefings, and the release of notes by DCSF demonstrates that Badman did brief the media (see http://www.whatdotheyknow.com/request/transcriptrecording_of_the_badma#incoming-44561), so the DCSF's statement to Mrs Stafford on the 28 August that 'The information you requested is not held by this Department.' is, therefore, factualy incorrect. (Mrs Stafford's original request was made on the 11^th July 2009 and followed up on the 6^th August with evidence of a briefing with the Church of England.) http://www.whatdotheyknow.com/request/post_report_of_the_review_of_ele#incoming-55610
Correspondence 2: an allegation of intent to delay on the part of the Department — made on 10 September despite the fact that you were aware of the problems the Department was experiencing. … [example given]	2	Mrs Stafford wrote on the 10^th September: 'have still not been given the information I requested on 1st July despite requesting an internal review on 31st July. I have had apologies and promises that I will get this information but as a select committee investigation into the Badman review ends on 22^nd September I am fearful that there is intent to delay until after this time. I have therefore referred the matter to the information commissioner.' Note: 1) The request relates to the most important claim made in the report (c.f. paragraph 8.12 discussion in main text). 2) Receiving a DCSF response was urgent because of the deadline for submissions to the Select Committee (22^nd September 2009 – 12 days away). 3) The original request was made on the 1^st July, and internal reviews were requested on the 31^st July 2009 and the 29^th August 2009. The latter request was repeated on the 9^th September 2009. Thus 51 working days lapsed between the original request and the 10^th September 2009. 4) The DCSF received similar requests from other people about the 'disproportionately high' claim made in the report and media briefings, but (to this date) has refused to provide the evidence underpinning paragraph 8.12 (c.f. vague references to 'raw data' in working paper). In this context it is not unreasonable to assume that the DCSF was, for whatever reason, delaying releasing the information that several home educators had requested. Given the pattern of requests relating to paragraph 8.12 and the media briefing it is difficult to understand why the DCSF did not act quickly to place the necessary evidence in the public domain. http://www.whatdotheyknow.com/request/evidence_in_support_of_badmans_r
Correspondence 3: the frequency of your requests and interventions, sometimes twice in the same day	N/A	This repeats a point made in the main part of the Partridge letter and has been addressed above. The number and frequency of contact with the DCSF is not exceptional given the shortcomings of the published report and how DCSF managed the subsequent inevitable information requests to access the unpublished evidence. In addition, it is unreasonable to restrict the number of information requests that citizens can make in any one day – there is no such limitation in the Act. Requests and follow-up letters were sent as they occurred to Mrs Stafford, sometimes following a discussion with her husband.
Correspondence 4: your apparent reluctance to quote the Departmental reference numbers in correspondence, and your derogatory remarks about what you perceive to be the inability of Departmental staff to click on links e.g: 'Please accept my heartiest commiserations for your inability to click on a link like the rest of the population, it must be most disabling.' (30 September 2009) [websites listed]	For example, 2 and 8	Mrs Stafford wrote on the 30^th September: 'Please accept my heartiest commiserations for your inability to click on a link like the rest of the population, it must be most disabling.' She also did not always provide reference numbers in correspondence following up requests to DCSF. Note: 1) The Whatdotheyknow.com site makes it very easy to submit follow-up correspondence and assists with the management of internal reviews. However, there is nothing on the site, including the template letters, to suggest that users need to include reference numbers. 2) None of the other organisations that Mrs Stafford has submitted an information requests to has needed a reference number. 3) Mrs Stafford found the multiple issuing of reference numbers by DCSF for single information requests confusing (see Table 1). 4) The department were inconsistent in providing reference numbers – for instance, Annex A of the Partridge letter includes three reference numbers that Mrs Stafford cannot find on the website. 5) The DCSF sometimes provided an answer without needing a reference number. Of the ten internal review requests made by Mrs Stafford, eight were made without a reference number and of these four (half) produced a departmental reply without a request for a reference number. One of the requests for internal review (request 7: http://www.whatdotheyknow.com/request/clarification_of_the_data_in_the#incoming-55603) made on the 2^nd October did not include a reference number because none had been issued by the DCSF, even though the initial request had been made 26 days before (27^th August). 6) Mrs Stafford believed that as correspondence was forwarded by Whtodotheyknow.com to the DCSF it was linked to the initial request – this is, after all, how it appears to her - the idea, therefore, that officials could 'click through' to the initial request was not unreasonable in the circumstances. The use of sarcasm by Mrs Stafford must be seen in the context of the seriousness of the shortcomings of the Review's report, that DCSF was failing to provide the evidence that supported the review, that the review proposes a significant diminution of parents' rights and that information was urgently required to meet two deadlines, for the Select Committee and the Department's own consultation.
Annotation 1: 'Four months to say no, such respect for it's masters the DCSF have, not!' (Annotation 2 also refers to same request)	Request made by Mrs J.E. Garrett	Mrs Stafford annotated on the 31^st October 2009: 'Four months to say no, such respect for it's masters the DCSF have, not!' The request generated nine annotations by three people (including Mrs Garrett and Mrs Stafford). The key events in this case are as follows: 25^th June 2009 - Mrs Garrett makes an information request related to the evidence underpinning the claims made in paragraph 8.12. 20^th August - Mrs Garrett requests an internal review. Mrs Garrett annotates: 'Obviously I and many others now believe that you have something to hide. If you have nothing to hide, then produce the evidence that you based the various assumptions on.' 23^rd August - Mrs Stafford annotates: 'I think using the WhatDoTheyKnow form for internal review might be more effective, the delay on this is nothing short of ridiculous.' A comment that seems reasonable. Mrs Garrett writes to the DCSF saying that she will be writing to her MP. 11^th September – Mrs Garrett annotates: 'To help others with the delaying tactics, the DCSF are ignoring first requests of Internal Reviews and only acting on second requests (after they have sent out their pathetic delaying tactic letter). The way to do this is as soon as their 20 day time limit is up ask for a review, then ask for a second a week later, eventually you will get their standardised 'apology', then put in another request, this one should go through. My first Internal Review request was made on the 25th July, I didn't get a confirmation of an Internal Review until the day I did my second Internal Review request on the 23rd August. So keep on top of your requests.' 1^st October - Mrs Garrett requests a second internal review. She annotates: 'These people really are a complete waste of tax payers money. I have to assume they do look at the automated system occasionally. But giving out new 20 day limits everytime we make a complaint is not good enough. This one is off to the information commissioner.' And Mrs Stafford annotates: 'My suspicion is that it is that awkward word evidence that is giving them the problem.' (see annotation 2 below). 2^nd October – DCSF request case reference number (that is, Mrs Stafford is not the only home educator to omit case numbers in correspondence with the Department). 30^th October – DCSF answer the request by providing a web link to the safeguarding working paper (see main text) 31^st October – Mrs Stafford makes the annotation specified in the Partridge letter Note: 1) The four month part of the annotation is factually correct – a total of 90 days. 2) Even ignoring that the findings in the working paper did not address the information requested (see main text), taking this long to provide a response is not dealing with it either quickly or efficiently. 3) It was Mrs Garrett who in an annotation (1^st October) linked the slow response of the DCSF to taxpayers. Mrs Stafford's annotation of the 31^st October merely reinforces the point that those required by the Act to process information requests are paid for by taxpayers. http://www.whatdotheyknow.com/request/home_education_review_recommenda#comment-5439
Annotation 2: 'My suspicion is that it is that awkward word evidence that is giving them the problem.' (Annotation 1 also refers to same request)	Request made by Mrs J.E. Garrett	Mrs Stafford annotated on the 1^st October 2009: 'My suspicion is that it is that awkward word evidence that is giving them the problem.' The request generated nine annotations by three people (including Mrs Garrett and Mrs Stafford), and key events in the history of the request are given above. Note: 1) Mrs Stafford's annotation is in response to an annotation by Mrs Garrett made on the same day and quoted above. Although the annotation was made in a public forum, it was not directed at DCSF staff. 2) Mrs Garrett's annotation suggested that the DCSF were seeking to delay answering Freedom of Information requests by issuing a new reference number following new correspondence. Mrs Stafford, however, sought to highlight an emerging pattern to her own and other people's information requests, namely, that those not asking about the evidence underlying paragraph 8.12 were being answered more quickly than those requesting evidence. The latter requesters subsequently received the 'annex' or the safeguarding working paper, which is known not to provide the evidence sought (see main text). Although Mrs Stafford's comment is impressionistic and not based on a detailed analysis of requests to DCSF, it was made in good faith and does appear to 'fit the facts' as they are known to her. http://www.whatdotheyknow.com/request/home_education_review_recommenda#comment-5439
Annotation 3: 'They are doing this regularly now, still not realised we are not stupid.'	8	Mrs Stafford annotated on the 1^st October: 'They are doing this regularly now, still not realised we are not stupid.' For this request three people each make one annotation (including Mrs Stafford). Key events are as follows: 27^th August – Mrs Stafford makes a request following up findings in the safeguarding working paper. 28^th August – Mrs Stafford clarifies wording of request. 26^th September – Mrs Stafford requests an internal review. 28^th – 30th September – exchange of correspondence about case reference numbers. (See correspondence 4 above) 1^st October - Mrs Garrett annotates: 'They must be getting desperate to be using these kinds of staalling (sic) tactics' And Mrs Stafford posts the annotation specified in the Partridge letter. Note: 1) Mrs Stafford's annotation is in response to an annotation by Mrs Garrett made on the same day and although made in a public forum, it was not directed at DCSF staff. 2) Mrs Stafford was simply expressing sympathy with Mrs Garrett's 'they must be getting desperate' comment. 3) Mrs Stafford's observation is wholly compatible with her understanding and experience of the issue of case numbers (see Correspondence 4 above). From her perspective, answering the request should have been straightforward; it was after all an evidential review, and the necessary information should have been easily accessible. In this context taking longer than 20 days to provide the requested information and issuing further case reference numbers was seen as a delaying tactic. http://www.whatdotheyknow.com/request/more_clarification_of_the_data_i#comment-5423
Annotation 4: 'They have had more than enough time to conduct an internal review on this, I would refer it to the information commissioner.'	Request made by Elaine Walton	Mrs Stafford annotated on the 25^th September: 'They have had more than enough time to conduct an internal review on this, I would refer it to the information commissioner.' This request produced 13 annotations by six people. Note: 1) It is difficult to see how this annotation could possibly cause distress to staff. The number of days lapsed between Ms Walton's request for an internal review (5^th August) and Mrs Stafford's annotation was 36 days. Arguably this was 'more than enough time to conduct an internal review'. 2) Annotations on Whatdotheyknow.com are designed to provide help and support to requesters, the DCSF cannot seriously be suggesting that advice to refer a request to the ICO would harm DCSF staff. http://www.whatdotheyknow.com/request/communications_with_nektus#incoming-47268
Annotation 5: 'Not even an acknowledgement, how rude.'	Request made by Mrs J.E. Garrett	Mrs Stafford annotated on the 24^th September 2009: 'Not even an acknowledgement, how rude.' The request produced three annotations from two people (including Mrs Stafford). The relevant request and annotations are as follows: 8^th September - Mrs Garrett requests information on the number of Freedom of Information requests (including those for internal reviews) connected with the Review. 12^th September – Mrs Stafford annotates: 'Waiting with great interest for this.' 24^th September - Mrs Stafford makes the annotation specified in the Partridge letter. (Notwithstanding a request for internal review, Mrs Garrett's request is still outstanding.) Note: 1) There were 12 working days between Mrs Garrett's request and Mrs Stafford's annotation, given that the DCSF should answer requests within 20 days and that requests are typically acknowledged by the Department, her comment seems wholly appropriate. 2) As an annotation on Whatdotheyknow.com, it was directed at Mrs Garrett and not DCSF staff. http://www.whatdotheyknow.com/request/number_of_foi_requests_made_conc#comment-5254
Annotation 6: 'you should ask for an internal review and if they don't do that refer to the information commissioner. There is a lot of stonewalling going on '	Request made by Rebeka Fox	Mrs Stafford annotated on the 21^st September: 'you should ask for an internal review and if they don't do that refer to the information commissioner. There is a lot of stonewalling going on.' Only Mrs Stafford made an annotation on this request. The relevant events were: 8^th July 2009 - Ms Fox submitted a request on the evidential and legal basis for a statement made by Baroness Morgan on the monitoring of those engaged in elective home education. 24^th July – Ms Fox asks for an 'acknowledge receipt' of her request 27^th July – DCSF acknowledges receipt and issue a reference number 1^st September – Ms Fox writes to DCSF: 'A response to my request is now more than three weeks overdue.' 11^th September – Ms Fox writes to DCSF: 'I would appreciate a response to my Freedom of Information request dated 8th July. Your Department's reply is now almost five weeks overdue. The correspondence reference number is 2009/0061638. Please respond urgently.' 21^st September – Mrs Stafford makes the annotation specified in the Partridge letter. (Ms Fox subsequently requests an internal review on the 8^th October, which is acknowledged, but the DCSF have still not replied to her request.) Note: 1) As mentioned above, annotation are used on Whatdotheyknow.com to offer advice and support to other people making requests. DCSF staff cannot reasonably object to Mrs Stafford offering advice to others given the Department's performance on Ms Fox's request. 2) The 'stonewalling' comment highlights the long gap between when Ms Fox submitted her information request and Mrs Stafford's annotation, 52 working days. Given the target was 20 days and the absence of an initial acknowledgement, describing the delay as 'stonewalling' seems apposite. 3) The lack of a timely reply by DCSF is consistent with it not replying quickly to 'evidential' requests. 4) Ms Fox's request was possibly urgent because of the Select Committee and consultation deadlines. http://www.whatdotheyknow.com/request/home_education_evidence_of_curre#comment-5181
Annotation 7: 'Tor (sic) goodness sake, Graham Badman has accused us of being abusers and knowingly allowed the press to slur us with false twice as likely claims. I also suspect allowed is a misnomer. The DCSF repeatedly refuse to release the evidence probably because they have none and you are getting upset because somebody called him a liar!'	Request by Feargal Hogan	Mrs Stafford annotated on the 18^th September: 'For goodness sake, Graham Badman has accused us of being abusers and knowingly allowed the press to slur us with false twice as likely claims. I also suspect allowed is a misnomer. The DCSF repeatedly refuse to release the evidence probably because they have none and you are getting upset because somebody called him a liar!' The request lead to six annotations, including two each by Mrs Stafford and Mr Hogan. Key events are: 19^th August 2009 – Mr Hogan makes a request about correspondence between the Information Commissioner and the DCSF regarding the backlog of Freedom of Information requests. 16^th September – DCSF replies to Mr Hogan with a pdf file of a letter from Mr Partridge to the Information Commissioner alleging '… a campaign by some supporters of home education which is threatening to inundate the Department with FOI requests.' and draws his attention to a number of web links illustrating '… harassment and a display of hostility towards Mr Graham Badman.' Mr Hogan posts the letter as an annotation. 18^th September – Mrs Stafford makes the annotation specified in the Partridge letter. Note: 1) Media reports following the publication of the Review's stated that home educated children were twice as likely to be known to social care as the population of children as a whole (see footnote 10 above). The proviso in paragraph 8.12 of the report that this was believed to occur in only 'some local authorities' was omitted. This omission serves to convey a very different order of magnitude about the prevalence of any problem amongst home educated children than that suggested in the report. In addition, 'known to social care' was reported as 'abuse'. Mrs Stafford was highlighting that neither the DCSF nor Badman have issued any press releases correcting the erroneous impression created by the media reports – in this sense the claims made in the media are a 'slur'. The 'allowed' comment reflects a view that Badman was ambiguous when discussing the extent of the problem with the media. 2) As shown in other parts of this paper, the DCSF 'repeatedly refuse to release the evidence', and the suspicion that the statistical evidence was not robust or even non-existent is confirmed by Badman having to conduct a third survey of local authorities after the report was published (see main text). 3) The 'liar' comment is linked to a blog by BLODGIAL, who persuasively argues that through the selective quoting of the Church of England submission Badman has lied by omission (see http://irdial.com/blogdial/?page_id=2). Mrs Stafford's comment is correct, the report 'lies' by not providing a full and frank account of the Church of England and an anonymous home educator's evidence. http://www.whatdotheyknow.com/request/communications_with_information#comment-5114
Annotation 8: 'Evil man'	Request by A White	Mrs Stafford annotated on the 10^th July 2009: 'Evil man'. The request prompted 11 people to make 21 annotations, including four by Mrs Stafford. The request sought the evidence underlying the 'twice as likely' claim in the media. The DCSF response on the 10^th July 2009 was the 'annex' paper that revealed that second survey of local authorities and the presumed basis of the 'disproportionally likely' claim of paragraph 8.12 was based on only 25 local authorities. The 'Evil man' annotation by Mrs Stafford follows comments by Shena Deuchars and Mrs Stafford on the small size of the second survey's sample. The annotation referred to way in which data had been manipulated and reported by Badman, notably, that statements in the report appeared to be based on a previously unreported survey of only 25 local authorities, yet his report rejected research studies on the grounds of small sample sizes (Badman, 1990:36). Mrs Stafford acknowledges that describing such duplicitous and logically inconsistent use of data by Badman as 'evil' was due to the shock and frustration that radical changes were being proposed on the basis of previously unreported flimsy evidence. http://www.whatdotheyknow.com/request/comparative_statistics_requested#comment-5127

^* Using Whatdotheyknow.com numbers in Table 1

Mr Partridge (2009:4) rightly and properly states that 'The Department is not suggesting that you have participated in any vilification or harassment of the author of the report …' Mrs Stafford can confirm that she has had no role or part in any vilification of Graham Badman.

The letter implies, but does not directly accuse, Mrs Stafford of being part of a campaign to 'inundate the Department with FOI requests about elective home education' (Partridge, 2009:4). Mrs Stafford can categorically state that she has not been part of any campaign to submit information requests to DCSF. The only person she has discussed the information requests she has submitted with has been her husband, Professor Stafford. Indeed, many of the requests were made at his request. It follows that she does not know who the other eight requesters might be. Moreover, to her knowledge she has never met, any of the other people submitting Freedom of Information requests regarding the Badman Review.

DCSF ought to know that home educators form a heterogeneous and fragmented community and, as a consequence, no one group represents them. Individuals working on their own have (unsuccessfully) sought the evidence that is so palatably absence from the Report. They have made extensive use of the internet and email discussion groups to share information. Mrs Stafford has been active in these forums; however, none of these have been used to mount a campaign to inundate the DCSF with information requests. This is not to imply that there have been no co-ordinated attempts to collate information, for instance, Mrs Stafford was asked by another home educator to submit requests to named local authorities in order to obtain data on home education and suitable education. She, and a few other home educators, were asked to submit Freedom of Information requests to local authorities because, given externally imposed deadline, it was not practical for one home educator to submit requests to all 150 local authorities. These requests were necessary because the Review initially failed to collect and publish such data, even though such findings ought to have been a key element of the report. It is astonishing that home educators had to collate data that ought to have been published as part of the report. However, and to repeat, Mrs Stafford has not taken part in any co-ordination nor liaison over Freedom of Information requests to the DCSF.

The Partridge letter provides in Annex C (2009:9) six examples that are meant to show Mrs Stafford:

'… in several instances apparently acting in concert via the website VVhatdotheyknow.com'

(2009:3 and 9)

Most of these six examples suggest to requesters that they seek an internal review. The implication is that the DCSF believes it has the right to apply the Section 14(1) exemption to requesters who give advice to other requesters. Surely Parliament never intended that the rights conveyed under the Act could be denied to those using social networks, blogs and shared public spaces such as that provided by Whatdotheyknow.com simply because they provide a forum to offer support and advice to requesters. Would the DCSF exempt a request if a requester discussed their request with a partner or friend because in doing so they were 'acting in concert'? If the Commissioner were to uphold the DCSF case on grounds of Annex C this would seriously curtail people's rights to discuss their requests on the internet. In effect, any public body could use any comment by a requester on another person's request that is posted on any social space on the Web as grounds for applying Section 14(1). There is no requirement in the Act that people making requests cannot discuss other people's requests or offer them advice and support. Mrs Stafford saw herself as offering support to other home educators, a modern form of civic engagement.

Mrs Stafford is a member of a number of internet based home education groups:

AHED (Action of Home Education)
The Badman Review Action group
Autonomous Education UK (a yahoo list to discuss autonomous education)
HE-Special (an email list to discuss home educating children with special needs)
HEUK (a list to discuss home education)
UKHE (a list to discuss home education)
Not back to school picnic list (an email list to organise bubble blowing picnics to promote home education and demonstrate against the Badman Review)
HEAL (Home Educators in Leicester City and Leicestershire)
East Midlands Home Education (a yahoo list for promoting events in the East Midlands and general home education discussion)
Syston home education (a yahoo list for a home education group that meets around Syston, Leicestershire fortnightly for a science/craft based afternoon. Information about other local events and organised visits is also published on this list)
Stop the Government Stigmatising Home Educators. A Facebook group set up to fight the Badman Review.

Whilst many of these groups are active in opposing the Review and its recommendations, their emails / postings show that Mrs Stafford did not campaign to inundate DCSF with information requests.

That more than one person has submitted similar Freedom of Information requests is evidence of the disjointed nature of the home education community, rather than of any coordinated campaign.

Neither Prof nor Mrs Stafford have any experience of campaigning; and are not members of any political party. In exercising her rights under the Freedom of Information Act Mrs Stafford should be seen as being a responsible citizen carrying out a civic duty through asking legitimate questions about the Review and then blogging responses and commenting on others' blogs and information requests.

An unreasonable fixation on an individual member of staff

Mrs Stafford has not displayed an unreasonable fixation on an individual member of staff in any of her requests. Nor has the DCSF provided any evidence that she did so.

Mingling requests with accusations and complaints

The 12 requests by Mrs Stafford do not contain any accusations and complaints, and the Partridge letter does not claim that they do.
4.1.2 Do the requests impose a significant burden?

To establish that Mrs Stafford's requests impose a significant burden the DCSF must '… consider more than cost of compliance …', including whether '… responding would divert or distract staff from their usual work.' (IOC, 2009a:6).

The Partridge letter (2009:2) says that the Section 12 cost threshold of the Act does not apply, but when applying the 'significant burden' test, claims that 'substantial public resources' have been devoted to Mrs Stafford's requests. It is difficult to see how 'substantial public resources' can have been devoted to Mrs Stafford when the average cost of her request is approximately half the 'appropriate limit' of £600 for central government requests under Section 12 (ICO, 2008b:1).

Furthermore, no evidence of diversion of staff is presented in the Partridge letter, it is simply asserted. The Partridge letter observes that (2009:3):

'… the pattern of your requests and communications in Annex A is such that the requests, when answered, have led to further requests and complaints.'

As Table 1 shows above, Annex A only covers five of Mrs Stafford's 12 information requests. A fuller picture of the pattern of requests has been provided in the context and history section above. This clearly shows that requests were solely generated by serious shortcomings in the report and how the DCSF managed the review process post-publication:

The requests were necessary because the DCSF published a report that failed to provide robust evidence for its recommendations, in particular it did not provide a detailed account of the methodology, include key findings from the literature review, the online survey and the survey of local authorities. That home educators, including Mrs Stafford, would request this information was almost inevitable. Mrs Stafford submitted four requests (1, 2, 3 and 4) that follow on from the publication of the report.
As mentioned above, the realisation that the Review's report had selectively quoted qualitative evidence created the conditions under which home educators needed to query and carefully scrutinise anything the Department placed in the public domain.
Early successful Freedom of Information requests revealed that a second initially undisclosed local authority survey had been conducted and that this appeared to be the basis of the notorious paragraph 8.12 claim. The uncertainty surrounding the robustness of the data following the release of the annex/working paper, again, inevitably lead to several further requests by home educators. Mrs Stafford requests 6, 7, 8 and 9 relate to following other people's requests because the initial responses were not satisfactory.
The announcement and publication of the findings for the third survey of local authorities lead directly to information requests 10, 11 and 12 by Mrs Stafford.

The Partridge letter refers to requests and complaints, but fails to mention that Mrs Stafford has had to issue ten requests for internal reviews because the DCSF have failed to meet the 20 day deadline. It is not clear whether Mr Partridge is counting requests for internal reviews as complaints.

In summary, the necessity of following up requests arose from: evidential and methodological deficiencies with the published report - a more informative report would have obviated the need for information requests from Mrs Stafford; the DCSF delays in responding to requests; and the release of information that failed to address underlying concerns about the quality of the evidence and so lead to further requests.

4.2 Repeated requests

The DCSF also rejects Mrs Stafford's requests on grounds of Section 14(2). The Partridge (2009:4) letter merely notes that '… based on the evidence before it that this part of exemption at section 14 is also engaged.' Mrs Stafford asks that the Information Commissioner rejects the DCSF case for a Section 14(2) exemption on grounds that the Department provide no evidence to support its case.

The Commissioner's guidance states that a request can be refused if:

it is made by the same person as a previous request;

it is identical or substantially similar to the previous request; and
no reasonable interval has elapsed since the previous request.'

ICO (2009:8)

Mrs Stafford has not repeated any of her requests (see Table 1). Before submitting any requests she used the search facilities on Whatdotheyknow.com to ensure that similar requests had not been made.

5 Overview

The context and history of Mrs Stafford information requests to the DCSF show that:

they were necessary because of a flawed published report that failed to provide the evidence to back its recommendations;
several requests were necessary partly because of the ad hoc manner in which the DCSF released evidence collected for the Review, and partly because of the partial nature of the information released; and
Mrs Stafford's requests were urgent because of deadlines set by the DCSF for its consultation on the recommendations and by the Select Committee for submissions.

The DCSF had ample opportunity to both publish an initial report that included all relevant evidence or to release unpublished evidence post-publication once it had become aware of the evidential shortcomings of the report. Mrs Stafford notes that it is the Department, not home educators, who chose to misrepresent the views of the Church of England and of a home educator in the report, and who conducted a third survey to gather data after the report was published and then to release the findings after the closing date for submissions to the Select Committee.

The DCSF applies the Section 14(1) and 14(2) exemptions. Mrs Stafford believes that it is unreasonable to do so:

the volume and frequency of requests is simply a result of the evidential shortcomings of the report and the need to obtain the evidence to meet two externally imposed deadlines;
Mrs Stafford had to issue ten internal reviews because DCSF had not met the 20 day target – inevitably this will have generated additional correspondence;
the examples of alleged abusive language are taken out of context (see Table 2) and, of the 12 examples provided, eight relate to annotations on Whatdotheyknow.com and staff could only know of these if they actively went looking for them; they are not part of any information requests to the DCSF;
in the circumstances, the number of requests made by Mrs Stafford was reasonable and proportionate, and their average cost was less that the appropriate limit;
no evidence is provided by the DCSF of repeat requests.

If the DCSF refusal to reply to Mrs Stafford's requests was upheld by the Commissioner it would in effect stifle democratic debate on a fundamental issue affecting the civil rights of a minority of parents.

Bibliography

Badman, G. (2009a) Report to the Secretary of State on the Review of Elective Home Education in England, HC 610, London: TSO.

Badman, G. (2009b, 17^th September) Select Committee hearing on the Review of Elective Home Education in England, Letter to Directors of Children's Services, Retrieved from http://www.dcsf.gov.uk/everychildmatters/publications/documents/laeelectivehomeeducation/ on 6^th December 2009.

Badman, G. (2009c, 9^th October) Review of
Elective Home Education in England, Letter to Mr Barry Sheerman MP, Retrieved from http://www.dcsf.gov.uk/everychildmatters/_download/?id=6671 on 6^th December 2009.

Information Commissioner's Office (2008a) Freedom of Information Act Vexatious or repeated requests, Retrieved from http://www.ico.gov.uk/upload/documents/library/freedom_of_information/detailed_specialist_guides/awareness_guidance_22_vexatious_and_repeated_requests_final.pdf on 7th December 2009.

Information Commissioner's Office (2008b) Freedom of Information Act Using the Fees Regulations, Retrieved from http://www.ico.gov.uk/upload/documents/library/freedom_of_information/practical_application/usingthefeesregulations.pdf on 7th December 2009.

Partridge, A. (2009, 13^th November) Your FOI and other communications with the Department, Letter to Mrs Stafford.

Annex A: Timeline

Table 1 number	Date (2009)	Event	DCSF reference number	Link
	19^th Jan	Review announced as a consultation		http://www.dcsf.gov.uk/everychildmatters/ete/independentreviewofhomeeducation/irhomeeducation/.
	20^th Jan	Press release		http://www.dailymail.co.uk/news/article-1123182/Home-schooling-cover-child-abuse-sexual-exploitation.html
	20^th Feb	Online questionnaire deadline
	11^th June	Report published and accepted in full by Ministers
	11^th June	Press release		http://www.dcsf.gov.uk/pns/DisplayPN.cgi?pn_id=2009_0105
	11^th June	Consultation into registration and monitoring of Home Education launched
1	13^th June	M Stafford requests the literature review for the report		http://www.whatdotheyknow.com/request/literature_review_produced_for_g#incoming-36463
1	15^th June	DCSF standard acknowledgement	2009/0053009
2	1^st July	Request for LA statistical returns and any other (comparable) evidence that would support Badman report in the media on 11 June 2009: "Children educated at home are twice as likely to be on social services registers for being at risk of abuse as the rest of the population."		http://www.whatdotheyknow.com/request/evidence_in_support_of_badmans_r#comment-6774
2	1^st July	DCSF standard acknowledgement	2009/0059859
3	11^th July	M Stafford request post-Report of the Review of Elective Home Education briefings given to anyone by Graham Badman or anyone else from or associated with the DCSF	2009/0062825	http://www.whatdotheyknow.com/request/post_report_of_the_review_of_ele#incoming-55610
3	13^th July	DCSF standard acknowledgement reference number 2009/0062825	2009/0062825
1	18^th July	M Stafford requests internal review	2009/0053009
4	19^th July	M Stafford requests frequency count of answers to online questionnaire	2009/0065106	http://www.whatdotheyknow.com/request/frequency_count_of_responses_to#comment-4541
4	20^th July	DCSF standard acknowledgement reference number 2009/0065106	2009/0065106
	22^nd July	DCSF Select Committee announce a short inquiry into the Badman report		http://www.parliament.uk/parliamentary_committees/csf/csfpn220709.cfm )
1	24^th July	M Stafford makes further request for internal review as she has received no acknowledgement of her first request	2009/0053009
5	28^th July	M Stafford requests a summary of the answers to question 22/51 of the questionnaire to local authorities for the Badman Review of Elective Home Education	2009/0076600	http://www.whatdotheyknow.com/request/a_summary_of_the_answers_to_ques#incoming-55600
1	29^th July	M Stafford receives literature review from DCSF	2009/0053009
6	30^th July	M Stafford request a copy of the questions administered to the 25 local authorities (the second survey)	2009/0068590	http://www.whatdotheyknow.com/request/questions_in_the_in_depth_survey#incoming-41655
2	31^st July	Internal review requested	2009/0059859
2	31^st July	DCSF apologise and promise to consider internal review	2009/0059859
3	6^th Aug	DCSF say they do not hold the information requested	2009/0062825
3	6^th Aug	M Stafford responds with example of a briefing with Church of England and clarification of what we are looking for	2009/0062825
3	7^th Aug	DCSF standard acknowledgement	2009/0070413
3	7^th Aug	M Stafford request that the DCSF do not take another 29 days to answer this request	2009/0070413
4	17^th Aug	DCSF release the frequency count	2009/0065106
4	23^rd Aug	M Stafford thanks the DCSF for the information and notes that the frequency count shows majority of respondent's opinion was significantly different from Review conclusions	2009/0065106
	26^th Aug	Explanatory note to 'safeguarding working paper' released		http://www.whatdotheyknow.com/request/badman_review_of_home_education#incoming-41308
3	27^th Aug	M Stafford request an immediate reply	2009/0070413
5	27^th Aug	M Stafford reminds DCSF that they are breaking the law and requests a prompt response	2009/0076600
6	27^th Aug	DCSF release questionnaire for second survey of local authorities	2009/0068590
7	27^th Aug	M Stafford requests clarification of the data in the explanatory note for the Badman Review
8	27^th Aug	M Stafford requests more clarification of the data in the explanatory note/working paper produced for the Badman Report including which local authority has 55% of EHE children known to social care
9	27^th Aug	Request for Annex A referred to in the explanatory note connected with the Badman Review	2009/0074965
8	28^th Aug	DCSF standard acknowledgement	2009/0074943
8	28^th Aug	M Stafford request amendment	2009/0074943
9	28^th Aug	DCSF standard acknowledgement	2009/0074965
3	28^th Aug	DCSF repeat that they do not have information sought	2009/0070413
2	29^th Aug	Further request for internal review as DCSF have not responded	2009/0059859
2	1^st Sept	Standard acknowledgement giving reference number 2009/007529	2009/0075295
2	1^st Sept	M Stafford replies saying no new reference number needed and do not take another 40 days to release information sought	2009/0075295
2	2^nd Sept	Reply from DCSF asking for reference number	2009/0075295
2	2^nd Sept	M Stafford replies with a complaint about being asked for reference number that the DCSF themselves have given, she states she does not believe the delay to be accidental, threat of referral to Information Commissioner	2009/0075295
2	3^rd Sept	DCSF thanks for number and will consider internal review	2009/0075295
2	10^th Sept	As only 12 days until Select Committee deadline M Stafford referred this request to Information Commissioner	2009/0075295
5	11^th Sept	DCSF make specific acknowledgement and give reference number 2009/0076600 but then ask for a reference number	2009/0076600
5	11^th Sept	M Stafford objects to having to give a reference number, but gives the only one available 2009/0076600	2009/0076600
2	16^th Sept	DCSF use Section 40, 41 and 38 to deny information although some information is given but is not clear how release answers the request	2009/0075295
	17^th Sept	Badman asks local authorities for more data to help make the data behind the Review stand up to scrutiny (the third survey)		(http://www.dcsf.gov.uk/everychildmatters/publications/documents/laeelectivehomeeducation/)
10	18^th Sept	M Stafford requests who initiated the request for supplementary evidence to support the Badman Review of Home Education
10	18^th Sept	DCSF standard acknowledgement	2009/0079983
2	19^th Sept	M Stafford responds requesting clarification of information given and arguments against denial of information. (Have tried to tie in the new reference numbers given by DCSF to this challenge to their decision to refuse.)	2009/0080057
2	19^th Sept	M Stafford makes second comment pointing out errors in DCSF refusal. (Have tried to tie in the new reference numbers given by DCSF to this challenge to their decision to refuse.)	2009/0079990
2	20^th Sept	M Stafford makes correction to the name in the request
2	21^st Sept	DCSF standard acknowledgement giving reference number 2009/0079990; not sure if they are treating this correction as a new request	2009/0080057
2	21^st Sep	DCSF standard acknowledgement giving reference number 2009/008005; not sure if they are treating this correction as a new request	2009/0080057
	21^st Sept	Draft Children Schools and Families Bill Consultation closes (approx 200 responses on home education)
	22^nd Sept	Select Committee call for evidence closes with over 200 submissions. All bar 1 of the submissions from home educators arguing against the proposals
3	24^th Sept	M Stafford requests an internal review as the DCSF have released notes from the press briefing meaning that their statement that nothing was held was not completely true	2009/0070413
3	25^th Sept	DCSF standard acknowledgement.	2009/0081535
8	26^th Sept	M Stafford requests internal review	2009/0074943
8	26^th Sept	M Stafford provides reference number 2009/0081887	2009/0081887
9	26^th Sept	M Stafford requests an internal review	2009/0074965
8	28^th Sept	DCSF standard acknowledgement	2009/0081887
8	28^th Sept	DCSF request reference number	2009/0081887
8	28^th Sept	M Stafford provides reference number 2009/0081887	2009/0081887
9	28^th Sept	DCSF standard acknowledgement	2009/0074965
9	28^th Sept	M Stafford asks if DCSF has noticed that request is for an internal review	2009/0074965
9	28^th Sept	DCSF standard acknowledgement	2009/0074965
9	28^th Sept	DCSF request reference number	2009/0081882
9	28^th Sept	M Stafford supplies reference number 2009/0081882	2009/0081882
9	30^th Sept	DCSF apologises but say make every effort to answer on time	2009/0081882
9	30^th Sept	M Stafford says not convinced they are making every effort	2009/0081882
8	30^th Sept	DCSF saying M Stafford has supplied the internal review number not the case number	2009/0081887
8	30^th Sept	M Stafford provides reference number 2009/0074943	2009/0081887
7	3^rd Oct	M Stafford requests internal review, no response yet from DCSF	2009/0083915
7	5^th Oct	DCSF standard acknowledgement	2009/0083915
7	6^th Oct	M Stafford requests that the DCSF notes the request is for an internal review	2009/0083915
	10^th Oct	Badman writes to Select Committee re his statistics from his third attempt to collect data to support the conclusions of the review
9	19^th Oct	DCSF reply says the Department considers that section 21 of the Act is engaged. This is because the information is already reasonably accessible through the Department's Freedom of Information Publication Scheme at www.dcsf.gov.uk/foischeme. The Annex is disclosed at the end of the Safeguarding Evidence Briefing Paper available at http://www.dcsf.gov.uk/foischeme/subPage.ocument&i_documentID=806&i_collectionID=329	2009/0081882
	19^th Oct	Consultation on registration and monitoring closed: 5432 submissions
10	20^th Oct	DCSF answers the request	2009/0087703
12	26^th Oct	M Stafford request information about data in third survey
9	26^th Oct	M Stafford request clarification as to which document or part of document is Annex A as none contain that label	2009/0081882
	3^rd Nov	Select Committee memoranda published		http://www.publications.parliament.uk/pa/cm200809/cmselect/cmchilsch/memo/elehomed/contents.htm
12	4^th Nov	M Stafford requests an acknowledgement	2009/0090678
7	4^th Nov	DCSF apologises for lack of response and promises to respond as soon as possible	2009/0074942
12	5^th Nov	DCSF standard acknowledgement	2009/0090678
	12^th Nov	Andrew Partridge asks if M Stafford wants the DCSF response to outstanding FOIs to be private. M Stafford responds with a request that the response is published on Whatdotheyknow.com public forum
	13^th Nov	Letter from Andrew Partridge refusing all outstanding FOI requests to the DCSF
	19^th Nov	Children Schools and Families Bill announced in Queen's speech
	19^th Nov	Leader of Commons publishes response to consultations on draft Bills With thanks to Ciaran McHale not only for his support in writing to the Information Commissioner regarding the DCSF's refusal to answer FOI requests but also in reading and making comments on the final draft of this letter. Another home educator, Tania Berlow has also recieved a similar letter to ours, it seems the DCSF doesn't like people actually using the Freedom of Information Act as they object to the number of FOIs she has had to make in order to create her superb Suitable Education document.		http://www.commonsleader.gov.uk/files/pdf/803%20Cm%207739.pdf

11 comments:

Deb said...: Thank you for posting this. I can only imagine how long it took to put this together, and the stress it must have caused. Let's see the *paid* staff of the DCSF brush it off as they seem to with anything that inconveniences them.; 21 December 2009 at 10:29
Kelly said...: So amazing. You both deserve a medal. Or something way better than that.; 21 December 2009 at 13:18
Michelle, Nottingham said...: I admire your tenacity and hard work. A very comprehensive report. Did Dr Bowbrick's information help? Good luck in getting a positive conclusion.; 21 December 2009 at 14:14
Maire said...: Thanks Debs, it has been stressful, especially for Bruce who has really had no leisure time for about five weeks. The post above has been amended to thank Ciaran and to link to Tania's letter from Partridge in the same vein as ours.

The disempowering of Badman Balls and all the enemies of home education would do Kelly, that would be better. We can hope!

Thanks Michelle, the emails from Dr Bowbrick were very helpful in establishing a structure and giving us the idea of a timeline.; 21 December 2009 at 20:40
Anonymous said...: The fact that you have had to do this is in itself a powerful indictment of the DSCF and their "paid" staff.

The fact is that the Badman Review should have had ALL the information in the original text. When writing a dissertation or even an essay you don't hold back the relevant research-or you would soon find an "F" on the mark sheet.
The Report from Badman was of higher importance in light of the impact it was going to have on so many of us and yet they seem quite incapable of providing full, honest information.
I can only assume these people are products of a school education.; 22 December 2009 at 08:17
Grit said...: i'm still sitting here, open mouthed, 24 hours later at this amaze-making work. your dedication is formidable.; 22 December 2009 at 10:39
Anonymous said...: Wow, that is amazing and convincing. Perhaps you should send it to Michael Gove and David Cameron.

The simple fact is that Mum6kids is correct. The Badman review was not a complete report. It wouldn't have even rated an F in an undergraduate course. It seems to me that the DCSF, by not responding fully to information requests, in fact by hiding behind spurious claims of harassment, are proving our case for us. That, in fact, there is no case and that the DCSF has it 'in for us.'

The whole system has shown itself to be lying, prejudiced and incompetent and, if it were a business, would be out of business within a few months. The whole system lacks accountability and is completely without oversight by we who pay for it.

I hope that wiser heads than mine can engineer change in the political system within the near future. We deserve better than this.; 22 December 2009 at 11:20
R said...: This is fantastic!
I am disgusted at the way the DSCF has treated the citizens of this country.
It is about time they were downsized!; 22 December 2009 at 18:07
Mieke said...: Just catching up on blogreading, so a belated thank you Bruce and Maire for the fantastic and dedicated work you two are doing for the home ed community. If only Badman cs would have put a fraction of that work - can't expect dedication - in his report, none of this would have been necessary. For a department that is supposed to set standards for education DCSF have a lot to learn.; 24 December 2009 at 13:12
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Anonymous said...: Your blog keeps getting better and better! Your older articles are not as good as newer ones you have a lot more creativity and originality now keep it up!; 3 January 2010 at 15:36

Staffordshire

Sunday, 20 December 2009

Our submission to the Information Commissioner

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