Home News

Learning from our recent interventions

Learning from our recent interventions

15 September 2026

We recently closed two FOI interventions with large public authorities that were originally initiated in response to significant performance concerns. 

Supported by our team, both organisations achieved a remarkable transformation, progressing from poor FOI performance to consistently delivering excellent outcomes. Their journeys demonstrate what can be accomplished through effective collaboration, accountability, and a commitment to continuous improvement.

The interventions provide valuable insights into the factors that enable successful organisational change, as well as the challenges that can arise along the way. 

The drop-down sections below capture the key lessons learned from these interventions, highlighting the approaches, behaviours, and practices that contributed to a successful outcome. 

These findings provide practical advice for other public authorities to  inform and strengthen improvement activity in their own organisation.

Learning Reports

NHS Forth Valley

How NHS Forth Valley improved FOI performance: what made the difference?

Responding to Freedom of Information requests on time is essential to openness, accountability and public trust. When NHS Forth Valley’s performance fell below the required standard, the Commissioner escalated an intervention and set clear improvement expectations.

The challenges faced by NHS Forth Valley included the clearance of an accumulated backlog, securing additional staff resources and increasing visibility of FOI across the organisation.

NHS Forth Valley’s team worked positively and constructively with the Commissioner’s team to secure long-term and sustainable improvements.

The key factors that led to these improvements can apply across all sectors and are set out below:

Key factors that led to improvement

1 - Making the issue visible

Weekly reports to the Board’s senior leadership team brought FOI performance into clear view. They showed current performance, requests at risk of becoming overdue, progress against the backlog, and the areas where support or escalation was needed.

This regular visibility helped turn FOI from a specialist team issue into an organisational priority. Leaders had the information they needed to unblock delays and support services to respond on time.

2 - Clear ownership and leadership engagement

Senior leadership focus was reinforced through weekly position meetings chaired by the Medical Director. Representatives from Directorates and Services reviewed live issues, identified pinch points and agreed action before responses became overdue.

Giving leaders sight of individual requests helped enable timely, collaborative problem-solving. It also signalled that FOI compliance mattered and needed active ownership across the system.

3 - The right level — and type — of resource

Additional permanent Information Rights Officer capacity gave the FOI team sufficient resilience to manage current demand while also improving systems and processes.

A key learning was that improvement requires more than extra capacity. Across the organisation, FOI work needs people with the right skills, including communication, influencing, judgement and the authority to prioritise competing pressures.

4 - Tackling the backlog separately from current demand

At the start of the Improvement Action Plan, 202 overdue requests had accumulated. The team designated an experienced officer to focus specifically on the backlog, while others managed incoming requests.

This separation allowed the backlog to be addressed strategically and thematically. Straightforward cases were resolved quickly, while more complex requests received targeted engagement with services. The backlog was eliminated by 13 November 2025, six weeks ahead of schedule.

5 - Standardising local processes

Directorates adopted local Standard Operating Procedures using a standard template from the Information Governance Unit. These SOPs clarified roles, responsibilities, contacts, cover arrangements and local escalation routes.

Standardisation created a shared understanding of how requests should be managed and enabled more consistent practice across services.

6 - Using curiosity to understand how work really happens

Improvement work went beyond high-level assurance. Services reviewed how information requests actually moved through their teams and engaged in process mapping supported by the Quality team.

This helped identify where processes were unclear, where delays occurred and where practical changes could make the biggest difference. In one example, the Finance Directorate redesigned its approach and reduced the average time for providing information to 7.85 working days.

7 - Communicating consistently and positively

The FOI team strengthened communication through performance reporting, guidance, monthly ‘FOI Matters’ updates and the simple message that ‘Every Request Counts’.

Positive recognition also played a role. ‘FOI Stars’ helped celebrate colleagues who supported the process well, reinforcing constructive relationships and encouraging continued engagement.

What this means for improvement in practice

The FOI improvement journey shows that sustained improvement depends on a combination of visibility, leadership, curiosity, capacity, streamlined processes and communication. No single action delivered the change on its own; improvement came from aligning all of these factors around a shared purpose.

  • Make the issue visible with timely, meaningful data.
  • Give leaders enough detail to act, not just direction that action is needed.
  • Match resource to the work, including the skills and authority required.
  • Separate recovery work from live demand, where possible.
  • Standardise processes while allowing services to adapt them locally.
  • Use learning reviews to understand the causes of delay.
  • Communicate regularly, recognise good practice and reinforce the shared goal.

Conclusion

NHS Forth Valley’s experience demonstrates that improvement is most effective when organisations combine clear accountability with practical support. By making performance visible, strengthening local processes and creating space to learn from real cases, teams can move from reactive recovery to sustainable improvement.

Scottish Fire and Rescue Service

How intervention helped improve FOI performance at the Scottish Fire and Rescue Service

After a period of consistently low compliance with statutory response times, the Commissioner opened a Level 2 intervention with the Scottish Fire and Rescue Service (SFRS) in October 2024. The intervention focused on improving response times for freedom of information and environmental information requests, strengthening review handling, resolving tracking issues, and ensuring the FOI function had the capacity and resilience it needed.

The intervention closed on 7 August 2026 after SFRS met the agreed improvement targets and demonstrated sustained progress.

Why intervention was needed

Performance information showed that SFRS had been missing statutory timescales for responding to requests over a prolonged period. In 2023-24, SFRS responded to an average of 73% of requests on time, across 2,182 requests. On average, 24% of responses were late and 12% were recorded as failures to respond.

Review performance also raised concerns. Although the number of reviews was relatively low, only an average of 24% were completed on time in 2023-24, while 51% were late. The Commissioner also wanted to understand why no reviews had been reported between April and June 2024.

There were three main reasons for intervention: sustained low compliance with statutory timescales, concerns about whether requests for review were being properly identified and tracked, and a need to confirm that the FOI function was adequately staffed and resilient.

What the Commissioner required

The Commissioner set a clear improvement target: SFRS was expected to respond to at least 85% of requests and reviews on time consistently from 31 March 2025 onwards, with the aim of reaching higher levels of regular compliance.

SFRS was asked to provide an action plan, evidence of internal monitoring and reporting, its review procedure and letter template, details of requests for review between April and June 2024, information about any recording or tracking problems, details of FOI and EIR training, its staff procedures, and a completed self-assessment on responding on time.

Actions taken by SFRS

SFRS responded with a programme of changes covering systems, staffing, processes and training.
Improved tracking: SFRS introduced a specific email address for review requests and used interim tracking arrangements while developing a more reliable internal recording tool.

  • Better performance monitoring: new reporting arrangements, tracker data and dashboards helped the FOI team monitor cases, identify trends and report performance internally.
  • More resource and resilience: SFRS sought additional staffing, introduced cover for absence, used temporary support to address backlogs and later appointed an Information Governance Team Lead.
  • Clearer processes: the FOI team reviewed outstanding requests, introduced regular performance meetings, clarified responsibilities across directorates and improved arrangements for requests involving communications input.
  • Targeted training: SFRS delivered FOI and EIR training to senior managers, middle managers, fire investigation officers and directorates that handled higher volumes of requests.
  • Proactive publication: SFRS worked with directorates to identify information suitable for publication, including committee papers, to reduce the need for some future requests.

Key learning points

The intervention highlighted practical lessons for any public authority handling FOI and EIR requests.
Technical systems must be reliable. Authorities must be confident that their systems can identify, receive and track both requests and requests for review.

  • FOI teams need enough capacity. A small team can quickly become vulnerable when request volumes rise, requests become more complex, or staff are absent.
  • Processes must work across the organisation. Where responses depend on several teams, everyone involved must understand their role, the statutory timescales and the escalation route.
  • Training must cover both law and process. Staff need to understand FOI and EIR duties, but they also need practical guidance on how the authority handles requests internally.
  • Monitoring helps drive improvement. Regular reporting, dashboards and team meetings helped SFRS identify risks earlier and take action before timescales were missed.
  • Proactive publication can reduce pressure. Publishing frequently requested information can reduce demand on the FOI function and improve access to information.

Results

SFRS’s performance improved during the intervention. In Quarter 4 of 2024-25, only 29.7% of FOI and EIR requests and 19% of reviews were responded to within time. By early 2025, request response performance had improved significantly, and from November 2025 onwards SFRS regularly achieved more than 90% of requests answered on time.

Monthly request performance included 93% in January and February 2026, 90% in March 2026 and 98% in April 2026.

Review performance remained more variable because of lower volumes, but there were clear improvements at several points, including 100% of reviews responded to on time in March and November 2025, 88.89% in June 2025 and January 2026, and 90.91% in August 2026.

Closing the intervention

The case shows that sustained improvement in FOI performance depends on more than monitoring response times. It requires reliable systems, enough staffing, clear internal ownership, regular reporting, targeted training and a willingness to publish information proactively where possible.