Home > Publications > Special Reports - Access to Official Information > AOI: Monitoring of the non-statutory codes of practice 1994-2005 > Section 3 - A brief account of the Office's involvement in the Codes
The beginning
1. With the launch of the Code in April 1994, the five investigating units of 16 staff were in place to await the arrival of the first cases. These began to appear in the summer of that year but the volume was much lower than anticipated; by the end of November 1994 only 24 complaints had been referred to the Ombudsman, of which nine had been taken on for investigation. In a report published in December 1994 1 Sir William Reid commented on this fact, drawing attention to the general lack of publicity for the Code and to public indifference towards trying to obtain information. As the volume of casework continued to remain at a low level, the number of units dealing with Code cases was reduced from five to two, with many staff being deployed elsewhere in the organisation.
2. For the next couple of years the remaining staff responsible for dealing with Code requests continued to carry out that work while helping, at the same time, to reduce backlogs elsewhere. The volume of Code work remained at a steady, although very low, level. It should, however, be said that some of the cases that were investigated led to decisions of some significance in respect of openness, releasing certain kinds of information into the public domain for the first time; reference is made in more detail to one or two of those cases in the next section.
3. In terms of throughput the time taken to investigate some cases, including one or two of the significant ones, was seriously affected by their complexity. The Ombudsman originally set a target of 13 weeks to complete Code investigations, arguing that such cases ought to be dealt with much more quickly than standard investigations as they would not normally require the untangling of detailed narratives or the application of complex regulations. Indeed, it seemed from the first few cases that were investigated that such a target was not unrealistic. [1] From early 1995 onwards, average case investigation times increased markedly; the four cases reported in ‘Selected Cases 1995 - Volume 4’ [2] for example, took an average of 29 weeks to complete. This was partly because some were complex cases, often involving the examination of substantial numbers of detailed files: others were clearly regarded by the departments concerned as test cases. This could lead to an unwillingness on their part to reappraise their position. In paragraph 12 of the section on Access to Official Information in the 1995 Annual Report, [3] Sir William wrote: ‘...also there is a tendency in some departments to use every argument that can be mounted, whether legally-based, Code-based or at times simply obstructive, to help justify a past decision that a particular document or piece of information should not be released instead of re-appraising the matter in the light of the Code with an open mind’. In addition, investigating staff were still being deployed on other work. As a result, the few investigations that the Office did carry out were being processed more and more slowly.
4. The operation of the Code, and the part played by the Ombudsman in that process, was subjected at about this time to detailed scrutiny by the Select Committee on the Parliamentary Commissioner for Administration, which published the report of its conclusions in March 1996.[4] In his evidence Sir William Reid accepted that an immense change of attitude was required in the public service in order to make openness more effective but he did say; ‘I do already discern some changes, and I am satisfied that more information is being made available than in the past’. The Committee noted, with reference to a number of investigations, that intervention by the Ombudsman had resulted in certain classes of information being made available to the public for the first time and commended the practice of departments circulating summaries of PCA decisions to staff. However, in a trailer for later events, the Committee noted the difficulty that some departments apparently had in responding to the Ombudsman within the timescales specified. Attention was also drawn to the continuing lack of publicity for the Code. In evidence, Sir William said; ‘...there remains a wholly insufficient level of awareness of the opportunities afforded by the Code to the citizen’. That the Select Committee endorsed this view is borne out by the fact that their recommendation 18 said:
‘We recommend that there be a considerable increase in the funds devoted both at central and departmental level to the publicising of the Code’.
Stagnation
5. There was, however, no significant alteration in the Ombudsman's workload. The volume of Selected Cases published in January 1997 [5] (although the word ‘selected’ is somewhat misleading since all of the Ombudsman's investigated Code cases have been published) covered only eight cases reported on during 1996. The total reporting time for these cases was 415 weeks, an average of 52 weeks per case. While this was partly explained by the fact that those staff investigating Code complaints were continuing to work on other, non-Code, cases it was also a reflection of the immense complexity of some of the investigations. This led to one of these cases, which related to information sought from the Department of Trade and Industry about the reprocessing of nuclear fuel at Dounreay, taking 104 weeks to complete while another, involving information sought from the Health and Safety Executive about the THORP plant at Sellafield, took 66 weeks. Both cases required the ability to make sense of a mass of complex, often highly technical, information while the THORP case also raised significant issues about the interpretation of the Health and Safety at Work Act.
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The National Health Service Code
6. From June 1995 the Ombudsman also took on responsibility for monitoring the National Health Service Code of Practice (Appendix 2) in his capacity as Health Service Commissioner. The NHS Code was heavily based on the Government Code, although it contained rather fewer exemptions (nine as against 15). The Ombudsman's approach to this work was very similar. As with the Government Code, the Ombudsman wrote in June 1995 to all the NHS bodies within his jurisdiction to explain the Office's intended approach to investigations. The Ombudsman told them that failure to provide information that complainants thought themselves entitled to under the NHS Code would be taken as sufficient evidence in itself to allow the Office to take the matter further. In addition Sir William also made it clear that he did not see himself as precluded from investigating a complaint under the NHS Code even if it referred to matters that would normally have fallen outside his remit in respect of a standard investigation.
7. In November 1996 Sir William Reid published his first volume reporting on cases that he had investigated under the NHS Code.[6] Interest in, and awareness of, the NHS Code was even lower than with the Government Code and Sir William drew attention to the fact that, after nearly 18 months, he had only carried out three full investigations (all of which were reported in the volume). He said that his approach to these cases had very much been informed by his approach to investigations under the Government Code and, indeed, specific comments made in some of those latter investigations were directly cited in the reports of the three NHS Code cases. In his introduction Sir William recognised that the cases had taken much longer to complete than he would have liked, attributing this in part to the fact that, in two out of the three, questions had been raised about his jurisdiction. He noted that the vast majority of the cases that had been referred to him concerned access to personal health records.
8. By early 1997, as complaints about a failure to be allowed to see personal health records could now be dealt with under the new NHS complaints procedure, what had been at best only a trickle ceased to flow at all, to such an extent that no further volumes of investigated cases were ever published and the NHS Code simply faded away.
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Casework generally
9. When, on 2 December 1997, Sir Michael Buckley (who had replaced Sir William Reid in January 1997) was examined before the Select Committee on Public Administration (which now had responsibility for the Ombudsman) he confirmed the low level of casework. [7] In response to a question about one particular investigation, which had taken over two years and was still not finally resolved, Sir Michael fully recognised that this was not acceptable. He drew attention to the complexity of the case in question and the more general fact that departments were sometimes unwilling to allow him to see the disputed information in the first place or to accept his verdict if he recommended that this information should be released: sometimes it was a case of both. At a further appearance before the Select Committee on 3 February 1998, Sir Michael said: ‘...if the Government wants me to act as referee we cannot have a situation in which every time I award a free kick everyone troops off the field for an elaborate investigation of the rule book and to telephone the FA’. [7]
Revival: the Freedom of Information Bill
10. The catalyst in changing this position, to an extent, was the election in May 1997 of a Labour Government whose election manifesto contained a clear commitment to the passing of a Freedom of Information Act. The Government quickly demonstrated that commitment by issuing, in
December 1997, the White Paper Your Right to Know, setting out their legislative intentions.[8] While this did not lead immediately to an increase in the casework coming into the Office it did ensure that the issue of openness in government began to feature more frequently in the media and it alerted journalists to the existence of the Code, something that they had previously shown surprisingly little interest in using. In particular, The Guardian newspaper discovered that the Code could be used to tease out a considerable amount of information from Government departments, leading to a number of stories: they also discovered that the refusal by departments to release such information often resulted in even better stories. Ironically, therefore, it was the announcement of a Bill that would lead to the end of the Code that helped to publicise its existence and increase its greater use.
11. While welcoming the decision to put freedom of information on a statutory footing Sir Michael Buckley, in common with fellow public sector ombudsmen, took the view that creating a new independent complaints investigator (an Information Commissioner) would complicate the situation. Members of the public were often already confused about who to complain to, and Sir Michael reiterated his concerns in paragraph 1.15 of the Office's Annual Report for 1997-98. [9] Sir Michael favoured allowing existing public sector ombudsmen to deal with information complaints within their own sector, with a ‘college of Ombudsmen’ overseeing matters to ensure a consistency of approach. The Government took the view, however, that the increased number of complaints that would be likely under a legislative scheme covering the whole of the public sector required the creation of an expert, and very visible, appeals machinery and that this would, in fact, help to simplify matters.
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Haymes Garth (A32/96)
12. In December 1997 the Office issued its report into the Haymes Garth case. [10] In this case the complainant had asked for a copy of a report commissioned by the Ministry of Defence (MOD) into the refurbishing of Haymes Garth, an official RAF residence, where there had been a substantial failure of financial control. MOD had cited six Code exemptions to justify withholding the information, none of which the Office found applicable: the recommendation was that the factual information contained in the report should be released, although the names of individuals should not be identified. The investigation had taken 63 weeks to complete, a good part of which had involved detailed negotiations with MOD about the findings.
13. The investigation brought to the surface concerns both within MOD and, more widely, in Whitehall about how the Office carried out Code investigations. The Ombudsman also had concerns of his own and it was agreed, following discussion over a lengthy period, that the Office of Public Service would produce a guidance note which would remind bodies covered by the Code of their responsibilities under it, with particular emphasis on practices designed to reduce the length of investigation times. This note was subsequently circulated to departments by the Home Office following their assumption of responsibility for Code matters in the summer of 1998. By then matters had already begun to improve. In paragraph 6.11 of the 1997-98 Annual Report 9 Sir Michael Buckley was able to say that, although the influx of cases remained low, the backlog had largely been dealt with. To reflect the investigation position more realistically, new targets had been set: 16 weeks for straightforward cases and 23 weeks for more complicated investigations.
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Devolution
14. The election of the Labour Government in May 1997 also took forward the proposals resulting in the creation of the Scottish Executive and the National Assembly for Wales. As part of those developments the Ombudsman agreed that (under transitional arrangements operating from 1 July 1999) the Office would investigate complaints that information requested from devolved bodies had not been released in accordance with the requirements of the respective non-statutory Scottish and Welsh Codes. (These Codes had been revised in 1999 to reflect the position following devolution: the Welsh Code was subsequently revised a second time to bring it more into line with the proposals in the FOI Bill).
15. It was agreed that any cases arising under these Codes would be dealt with, initially, in London because that was where the expertise on the Code was based; the long-term intention was that the Ombudsman's Offices in Edinburgh and Cardiff would deal with such cases direct. As it happened, no investigations were ever carried out under the Scottish Code and only three under the Welsh Code, all of which were handled from London. The Ombudsman's responsibility for dealing with the Scottish Code ended on 1 April 2002 but the London office continued to consider cases under the Welsh Code until 31 December 2004. Special Report - the Prison Service
16. Section 10 (4) of the Parliamentary Commissioner Act 1967 requires the Ombudsman to lay annually before each House of Parliament
a general report on the performance of his functions under the Act and allows also for other reports (known as special reports) to be laid when appropriate. In March 1999 Sir Michael Buckley laid such a report entitled Disclosure of Information Relating to Deaths in Prison.[11] This report set out the results of two investigations relating to the deaths of prisoners in custody (a third would also have been included had the family concerned agreed). The investigations involved not only matters relating to the circumstances in which the prisoners had died but also the refusal of the Prison Service to release copies of the internal inquiry reports to the prisoners' families. A significant outcome of these investigations was that, from 1 April 1999, the Prison Service agreed to release such information as a matter of routine to relevant parties before any inquest took place, although this decision did not operate retrospectively.
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Changes and developments
17. Around 1999-2000 a number of changes began to take place in respect of Code investigations. First, the average time for completing investigations began to reduce. The volume of investigated cases published in June 1998, 10 which included 25 investigations, contained three cases which had taken over two years to complete (although one of these was partly an orthodox maladministration investigation) and another eight which had taken over 12 months. These, however, were more or less the last of these long-standing, at times becalmed, investigations. Between 1998 and the end of March 2001 (by this time the investigative year had been brought into line with the financial year) the average throughput time for investigations remained at around the 23 week mark. Along with this welcome development came a noticeable shift in the nature of the complaints received. Although the number of complainants seeking personal information under the Code had always been small these virtually disappeared following the changes made in the Data Protection Act 1998 which meant that this legislation now applied to manual files. However, there was a very measurable increase in
complaints being put by journalists and, also, by Members of Parliament.
18. Enhanced interest from the media and from Parliament led to a substantial increase in ‘politically sensitive’ information requests. Journalists, particularly (although not exclusively) from The Guardian had, as mentioned earlier, already seen the possibilities of the Code for pursuing traditional investigative journalism but had also seen the possibilities for readable articles when such requests were refused, particularly at a time when the freedom of information legislation was going through the Parliamentary process and was therefore in the public eye. Likewise, Members of Parliament realised that the Code might provide an opportunity to gain access to information which had been refused by the more traditional route of a Parliamentary Question (the Ombudsman 's jurisdiction does not extend to the investigation of complaints about answers to Parliamentary Questions: those are matters for Parliament itself). This development became more pronounced when, partly as a result of pressure from more than one Select Committee over a number of years, Ministers began more regularly to cite Code exemptions when refusing to provide information in response to Parliamentary Questions. Much of the information sought in this area was of a kind which those requesting it fully recognised would cause political difficulty for the department concerned, whatever the strength of the arguments in Code terms might be. The publicity these cases attracted enhanced the visibility of the Code, leading to a small but significant increase in the number of cases referred. This was no doubt assisted by the fact that on 13 November 2001, the Government announced that individual rights of access under the Freedom of Information Act would not be brought in until 2005, thus giving the Code another three years of shelf-life.
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Delay and disagreement
19. The year 2001 proved a watershed in the history of the Code. Until then, the regular publication routine of occasional volumes of investigated Code cases plus a short chapter on the subject in the annual report had done little to permeate public consciousness. However, two investigations which occupied much of the Office's time and energy during 2001 helped to change that position. The Robathan case
20. The first of these was the complaint submitted by Andrew Robathan MP, which formed the subject of a Special Report to Parliament, published on 13 November 2001.[12] In this case Mr Robathan had sought from the Home Office information as to how many times Ministers in that department had made declarations of interest to colleagues or sought the advice of the Permanent Secretary in relation to various requirements set out in the Ministerial Code of Conduct. The Home Office refused to provide that information, citing Exemptions 2 and 12 of the Code. The Ombudsman disagreed, arguing that Exemption 2 was designed to cover advice and opinion rather than factual information and that there could not be an unwarranted invasion of privacy of the kind envisaged by Exemption 12 when the information sought related only to a number, not to identifiable individuals. The Ombudsman recommended the release of the information. The Home Office refused, the first time that there had been such a refusal in relation to an Ombudsman's decision in a Code investigation; it was this refusal that had led to the special report. Later, in the Annual Report for 2001-02 15 Sir Michael Buckley was also highly critical of the fact that it had taken the Home Office seven months to respond to his draft report, allegedly because of the need to consult other departments as well as the Prime Minister.
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The Hinduja case
21. In a second case [13] the Office investigated a refusal by the Home Office to provide certain information relating to their dealings with the Hinduja brothers, aspects of which had already formed the subject of a separate inquiry by Sir Anthony Hammond QC.[14] Although the Home Office provided their papers for examination it became apparent that a number of key documents referred to in the Hammond report were not on the files. In addition, a number of papers relevant to the investigation were held by the Cabinet Office, who did not prove responsive to requests for access to them either from the Home Office or from Sir Michael Buckley. Faced with this position, Sir Michael issued a draft report to the Home Office saying that the lack of co-operation from both departments had effectively made it impossible for him to carry out his work properly. This had the effect of producing the relevant papers in short order but, in the same paragraph of the 2001-02 Annual Report quoted earlier, Sir Michael made it clear that a delay of nine months in simply making the relevant papers available was entirely unacceptable. In his introductory chapter to the report Sir Michael went on to say that, if this were to continue, his ability to conduct Code investigations properly in the future would be open to serious doubt.
The impact of delay
22. In paragraph 5.5 of 2001-02 Annual Report Sir Michael noted the impact that these extended delays had inevitably had on overall throughput times. He drew attention to another frustrating cause of delay, the habit some departments had of citing new exemptions at a very late stage in order to justify withholding information; in one case as late as the issuing of the draft report (A2/01, A4/01 and A6/02 are good examples of this). All of this had conspired to cause investigation throughput times, which had been relatively steady at around the 23 week mark, to regress during that reporting year to 33 weeks.
23. These issues were thoroughly discussed during evidence given to the Select Committee on Public Administration at a hearing on 11 July 2002 at which Sir Michael Buckley, the then Secretary to the Cabinet and the Permanent Secretary of the Home Office all gave evidence.[15]
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Continuing delay
24. Following this hearing, and in response to other more general issues relating to the Ombudsman raised in other hearings, the Select Committee issued a report in February 2003.[16] In the section of the report covering Access to Official Information (paragraphs 36-45) the Committee recommended that the Government should reconsider its decision to refuse to release the information requested in the Robathan case (see previous paragraph). This the Government declined to do.[17] The Committee had also expressed great concern at the failure of departments to respond in a timely and adequate fashion to the Ombudsman at various stages of the investigative process. As a result it had also recommended that:
‘…the Government should ensure that every organisation within the remit of the Ombudsman has a designated contact, tasked with ensuring the replies to the Ombudsman are both prompt and comprehensive.’ [16]
The Government accepted this recommendation.[17] In her first annual report as
25. Ombudsman[18] Ann Abraham noted that, although the Office had managed to reduce investigation throughput times more or less to the new targets of 26 weeks for straightforward cases and 30 weeks for more complex ones, delays of the kind
set out in the previous year's report and subsequently considered by the Select Committee were continuing to cause difficulties. As a result, towards the end of 2002, she opened detailed discussions with both the Cabinet Office and the Lord Chancellor's Department with a view to preparing a joint Memorandum of Understanding for issue to all bodies within jurisdiction. This Memorandum (a copy is at Appendix 3) set out not only the requirements of the Code in terms of responses to information requests but, more particularly, the Ombudsman's requirements once a case was taken on for investigation. It was hoped that the issuing of this Memorandum, which subsequently took place in July 2003 as part of the Government's response to the Select Committee's recommendations, would ensure a substantial reduction in the delays and frustrations that had bedevilled investigations over the previous two years.
Further difficulties and a novelty
26. While the issuing of the Memorandum of Understanding helped in general to produce a more consistent level of response from departments, it continued to fail to have much impact in those cases involving the politically sensitive areas of Ministerial interests and the Ministerial Code of Conduct. Ironically it was the Cabinet Office, joint signatory to the Memorandum of Understanding, who were by far the principal offender. The case of A7/03,[19] in which the complaint was against both the Department for Constitutional Affairs and the Cabinet Office, involved information requested from nearly 20 departments relating to Ministerial gifts. Following a delay of nearly 16 months, during which time departments were waiting for advice from the Cabinet Office (as guardians of the Ministerial Code) as to how to deal with the matter, the Cabinet Office advised departments to refuse to release it on the grounds that the information was covered by Exemption 12 of the Code (personal privacy). The Ombudsman, in her report, took the view that this exemption had been incorrectly applied and recommended that the information be released. The Cabinet Office, while agreeing to the release of related information, would not release the information sought by the complainant; this therefore became the second case in which there had been a refusal to release information following a recommendation by the Ombudsman in a Code investigation.
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Section 11(3) cases
27. Two other cases led to a constitutional novelty. Under section 11(3) of the Parliamentary Commissioner Act 1967 it is possible for a Minister of the Crown to give notice that, in respect of any document or information, in the opinion of the Minister ‘…disclosure of that document or information, or of documents or information of that class, would be prejudicial to the safety of the state or otherwise contrary to the public interest.’ Throughout the duration of the Ombudsman's office there was no evidence to suggest that this power had ever been used before: in 2003 it occurred twice, both times in Code cases. In both instances, the issuing of the notice resulted in the Ombudsman deciding to discontinue her investigation. The first of these was A3/03.[20] The second, A16/03, in which the bodies complained about were the Lord Chancellor's Department and the Cabinet Office, has a more complicated history.
28. In this case, which also related to the private interests of Ministers, a similar notice was issued. As before, the Ombudsman discontinued her investigation. However, in this case the complainant, a journalist, took the step of seeking a judicial review of the Government's decision to issue the section 11(3) notice. Shortly before the hearing was due to take place the Government withdrew the notice, enabling the
Ombudsman to re-open the investigation. Once again, however, the departments concerned, in particular the Cabinet Office, handled matters very poorly, resulting in a failure to respond to the Office's recommendations despite repeated promptings. The Ombudsman therefore had to issue a report without the benefit of any substantive comments from the departments. The future
29. While work on the Code continued, with the number of investigations showing a small but significant increase, attention was also turning towards the approaching implementation of the Freedom of Information Act. As well as continuing to sit on the Advisory Committee set up to oversee the implementation of the Act, the Office began to develop a closer working relationship with the Information Commissioner's Office (ICO). Under the legislation the ICO would adjudicate on those cases where a body covered by the Act had refused to release information requested under it. As part of this process, which continued up to and beyond full implementation on 1 January 2005, ICO staff visited the Ombudsman's Office to find out how they had carried out investigations under the Code. It was also recognised that procedures needed to be put in place for those cases where the Ombudsman received a complaint that should have been more appropriately directed to the Information Commissioner and vice versa. Equally, procedures needed to be established for dealing with those, not infrequent, hybrid complaints which involved both access to information and orthodox maladministration and for determining how they should be dealt with.
30. These issues formed the subject of a Memorandum of Understanding between the two offices.
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The last three months
31. As 31 December 2004 approached the Office found itself, quite ironically given the history of the Code, with more investigations than it had ever had before. While the idea of simply not taking on any more Code work in order to complete everything outstanding before the end of the year had its attractions, it was widely accepted that it would be wrong to create a situation in which, to all intents and purposes, the public would, for several months, have no independent body to which to turn in relation to refusals to release information. It was therefore accepted that the Office would continue to deal with those cases it had already taken on for investigation, with the intention of completing all of them by no later than 31 March 2005.
32. When the reports of those investigations began to issue in early 2005 it became apparent that, even in spite of the more positive approach now expected under the legislative regime, the evidence for this remained elusive in Code cases. As mentioned earlier, when the report on A16/03 was finally issued in February 2005 after chronic delay by the Cabinet Office, Ann Abraham was forced yet again to criticise that department for their reluctance to engage with the issues and for their unwillingness to accept her recommendations. In the same month the Foreign and Commonwealth Office refused to accept a recommendation that the date on which legal advice had first been sought in relation to the legality of a possible invasion of Iraq should be released, providing that the context of the seeking of that advice was also explained (A16/05). The Office's argument, once again, was that Exemption 2 (the only exemption cited) could not be applied to purely factual information. In this case the complainant immediately announced his intention of putting in a request for the same information under the Act. So, how much had really changed remained very much open to question.
33. For the Office, trying to complete all of these investigations by the target date was a demanding task, given that 25 were still uncompleted on 1 January 2005. It was greatly to the credit of the staff concerned that this target was reached, particularly as that total included a number of contentious and sensitive cases. Achieving the target meant that, in the final operational year of the Code, the Office issued the impressive total of 46 investigation reports.
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Summary
34. During the decade or so of its existence the Code, and the Ombudsman's policing of it, resulted in a significant enlargement in the kind of information that was routinely released into the public domain. The next chapter looks at some of those cases in more detail. But it was not a smooth process and, although the Ombudsman frequently dragged departments to water, departments often showed a marked reluctance (or outright refusal) to drink. This manifested itself most noticeably through delays in responding to the Ombudsman; very often this was in response to statements of complaint and draft reports but sometimes showed itself in a refusal to even provide the Ombudsman with relevant papers. In the section on Access to Official Information in the first chapter of the Ombudsman's 2003-04 Annual Report [21] Ann Abraham confirmed that the issuing of the Memorandum of Understanding appeared to have improved matters in general terms but that there were still too many instances where departments were taking too long to reply: she warned of the implications that this might have for how departments might behave under the imminent statutory regime. A fuller report of the first nine months' working of the Memorandum of Understanding can be found in Investigations Completed July 2003 - June 2004 and an update of the position in the final volume of completed cases.)[19]
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References
1 Parliamentary Commissioner for Administration - Second Report - Session 1994-95 Access to Official Information: the First Eight Months (HC 91)
2 Parliamentary Commissioner for Administration Ninth Report - Session 1994-95 (HC 758)
3 Parliamentary Commissioner for Administration. Annual report for 1995 (HC 296)
4 Select Committee on the Parliamentary Commissioner for Administration - Second Report - Open Government March 1996
5 Parliamentary Commissioner for Administration - First Report - Session 1996-97
6 Report of the Health Service Commissioner Selected Investigations - Access to Official Information in the National Health Service (HC 62) 1996
7 Select Committee on Public Administration - Third Report - Your Right to Know: the Government's Proposals for a Freedom of Information Act Volume I
8 Your Right to Know: The Government’s proposals for a Freedom of Information Act (Cm 3818) 1997
9 Parliamentary Commissioner for Administration Annual Report for 1997-98 (HC 845)
10 Parliamentary Commissioner for Administration - Fourth Report - Session 1997-98 (HC 804)
11 Parliamentary Ombudsman Disclosure of Information Relating to Deaths in Prison (HC 342)
12 Parliamentary Ombudsman Access to Official Information: Declarations Made Under the Ministerial Code of Conduct (HC 353)
13 Parliamentary Ombudsman Investigations Completed February - April 2002 (HC 844)
14 Review of the Circumstances Surrounding an Application for Naturalisation by Mr S P Hinduja in 1998 (HC 287) March 2001
15 Public Administration Select Committee Minutes of Evidence (HC 563 iv) July 2002
16 Public Administration Select Committee Ombudsman Issues: Third Report of Session 2002-03 (HC 448) February 2003
17 Cabinet Office. Government Response to the Public Administration Select Committee's Third Report of Session 2002-03 ‘Ombudsman Issues’ [HC 448] (Cm 5890) July 2003
18 Parliamentary Ombudsman Annual Report 2002-03 (HC 847)
19 Parliamentary Ombudsman Investigations Completed November 2002 - June 2003 (HC 951)
20 Parliamentary Ombudsman Investigations Completed July 2003 - June 2004. (HC 701)
21 Parliamentary Ombudsman Annual Report 2003-04 (HC 702)
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