Sarah Sibbald, Information Governance Manager at the Scottish Ambulance Service, shares details of the work done that helped her organisation achieve an on-time FOI performance rate of 100% - along with a Performer of the Year Award at the 2026 eCase Awards.
What FOI Improvement Looks Like in Practice: lessons from the Scottish Ambulance Service
Improving FOI performance is rarely about one change. Our experience shows it requires tackling culture, process, accountability and resilience together.
In December 2020, the Service was placed under a Level 2 intervention by the Scottish Information Commissioner because of consistently late responses against the statutory 20-working-day timescale. Performance had fallen well below the expected 90% compliance threshold, reflecting years of underperformance rather than a short-term issue. In 2020, compliance stood at 36.4%, illustrating the scale of the challenge.
An organisational priority
At that stage, FOI handling was largely seen as a departmental responsibility rather than organisation-wide, and the function relied heavily on a single individual, creating clear risks around resilience and oversight.
A major early change was to reposition FOI as an organisational priority. Responsibility for the function was transferred into the Information Governance Team, with backing from the Chief Executive, Executive Team and wider governance structure. This moved FOI from being seen as a narrow operational task to being recognised as a core part of the Service’s accountability, openness and legal compliance responsibilities. The team reviewed arrangements and identified improvement opportunities across staffing, systems, process, governance and culture.
Getting ahead of FOI
One key lesson was the value of working ahead of the statutory deadline rather than towards it. An internal expectation was introduced that information should be returned within 10 working days, allowing the FOI team to aim to respond within two weeks. In a large, operationally busy organisation, that buffer was critical. It created time for clarification, review, redaction, sign-off and escalation before a request risked breaching the legal timescale. Rather than relying on the final deadline as the working target, the change built resilience into the process and significantly improved compliance.
This approach only worked because it was supported by clearer accountability and escalation pathways. Executive Directors identified lead contacts in their service areas who were responsible for reviewing and releasing information directly to the FOI team. This created greater clarity about responsibility for contributing to requests and gave the FOI team a practical route for escalating delays or issues early. In real terms, this meant problems were identified earlier in a request’s lifecycle, when they could still be resolved. A robust sign-off process also strengthened the quality and confidence of disclosures by ensuring relevant expertise was brought in where needed.
A change of culture
Culture change also proved essential. Improvement was not achieved simply by rewriting process documents; it required engagement with staff across the Service. The FOI team delivered staff engagement sessions open to all staff, tailored presentations for departments, and support through meetings with key teams and information leads. These sessions refreshed understanding of FOI legislation, clarified expectations and explained why timely, high-quality responses matter. Just as importantly, they made the FOI team more visible and approachable, helping break down barriers and encourage collaboration between the central team and operational colleagues. Engagement matters because compliance depends on people understanding both their role and the wider purpose behind it.
Focussing on reporting
Another improvement came through monitoring and reporting. The organisation’s original FOI system had become unsupported and could not provide reliable reporting, so a back-to-basics approach was adopted using a spreadsheet. Although simple, it gave the team control and visibility of requests, deadlines and trends, while providing essential internal and external reporting. Governance and reporting arrangements were also strengthened: FOI actions were monitored through the Information Governance Group, escalated to the Audit Committee, and reported to the Executive Board, while monthly compliance reporting went to the Planning and Performance Steering Group. This increased FOI visibility and reinforced that FOI performance required ongoing executive attention.
Working together
Looking back, the biggest impact came from combined measures rather than any single intervention: earlier internal deadlines, clearer escalation routes, stronger governance, greater staff engagement and increased team resilience. Additional resource was important, reducing reliance on one individual and helping embed FOI handling within a broader team structure. The most persistent challenge has been resilience, particularly as request volumes have continued to rise year on year without equivalent growth in staffing. Sustaining improvement has required ongoing leadership, active process management and a team culture focused on support, adaptability and shared responsibility.
The results show what sustained improvement can achieve. Compliance improved from 36.4% in 2020 to 83.6% in 2021, 85.5% in 2022, 93.2% in 2023, 99.0% in 2024 and 100% in 2025 to June. The Commissioner’s intervention was formally closed after sustained progress. The key learning for other public bodies is that meaningful FOI improvement is possible, even from a difficult starting point, but it depends on treating FOI as an organisational responsibility, not simply a technical process. When accountability, culture, monitoring and leadership all move in the same direction, change becomes measurable and sustainable.
Got a question about the work done by the Scottish Ambulance Service? You can contact their FOI team at sas.foi@nhs.scot.
